How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

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Mobile Security

Today’s advanced enterprises make extensive use of mobile devices in order for team members to exchange information, collaborate, and carry out business whenever and wherever they need to. BlackBerries, iPhones, Google Phones, and other smartphones as well as PocketPCs and PDAs are now allowed wireless remote access to the enterprise network.

As a result, they introduce additional vulnerabilities into the system.

  • Bluetooth exploits and unencrypted passwords can allow malicious individuals to gain access to private information.
  • Various wireless technologies that have substantially simplified the task of transferring data have provided openings for malicious code. In addition, the diversity of these wireless technologies combined with the constrained environments of these devices have made it difficult to come up with an all-in-one solution.
  • All PocketPCs, PDAs and smartphones can be synchronised with PCs and laptops, giving malware an entry point into computers and networks. Memory cards are guilty of this too.
  • VoIP, which are usually unencrypted, allow other people to perform unauthorised capture and recording of private conversations.

Mobile security is still an emerging discipline. Because of this, many organisations that allow members’ mobile phone access into the network don’t actually have a specific security policy for such devices.

That’s why we’re here to help. We’ll conduct a thorough evaluation of your security policies and systems in relation to mobile devices and seal gaps we spot along the way. If you don’t have the needed policies or if what you have needs an overhaul, we’ll set everything up (including the needed applications and infrastructure) for you.

Once we’ve got everything in place, you won’t have to worry about the vulnerabilities mentioned earlier. In addition to that, your organisation will already be capable of preventing the following:

  • Access to company information when the phone ends up in the hands of anyone other than the authorised user.
  • Being billed for phone usage due to virus activity
  • Unauthorised phone activity monitoring through spyware
  • Other disruptions caused by mobile-based malware

Other defences we’re capable of putting up include:

Eck Industries Sheds Fresh Light

William Eck began his business in 1948 in a 650m2 garage building. The aluminium foundry prospered, and now has an 18,500m2 factory in Manitowoc, Wisconsin employing 250 people casting a variety of casings. Like high-tech industries around the globe it needs effective illumination. After it measured its carbon footprint, it realised it needed energy efficient lighting too.

When Eck Industries began its review it had around 360 high-pressure sodium lights throughout the plant. Their operating cost was substantial. After taking independent advice from an independent agency they realised they needed to replace these with more energy-efficient fluorescent lights that consume half as much energy.

The feasibility team conducted performance tests to determine the optimum solution. After selecting enclosed, gasketed and waterproof T8 fluorescents (available in G13 bipin, single pin and recessed double contacts) they collaborated with the supplier to calculate the best combination of 4 and 6 bulb fixtures.

The fittings they chose cost $60,000 plus $10,000 installation. However a $33,000 energy rebate wrote down 47% of this immediately. They achieved further energy savings by attaching motion sensors to lights over low-traffic walkways.

The retrofit was a huge success, with an 8 month payback via a direct operating saving of $55,000 a year. Over and above enhanced illumination Eck Industries slashed 674,000 kilowatt hours off its annual lighting bill. During the 20 year design life, this equates to a total 13.5 million kilowatt hours. Other quantifiable benefits include 443 tons less carbon, 2 tons less sulphur dioxide, and 1 ton less nitrogen oxide per year.

Many companies face similar opportunities but fail to capitalise on them for a number of reasons. These may include not being aware of what is available, lacking technical insight, being short of working capital and simply being too busy to focus on them.

Eck Industries got several things right. Firstly, they consulted an independent specialist; secondly they trusted their supplier to provide honest advice, and thirdly they accepted that any significant saving is worth chasing down. Other spin-offs were safer, more attractive working conditions and an opportunity to take their foot off the carbon pedal. This is an excellent example of what is possible when you try.

If you have measured your illumination cost and are concerned about it (but are unsure what the metric means within the bigger picture) then Ecovaro offers online reports comparing it with your industry average, and highlights the cost-benefits of alternative lighting. 

Enhance and Streamline IT Processes

You can’t be assured of a competitive advantage by just buying the latest technology. Your top competitor can easily match that feat by simply spending as much on the same tools. To be always at least a step ahead, you’ll need to perform tweaks on your IT processes aligned with the strengths of your organisation.

IT solutions are like a pair of sneakers. If they fit perfectly, they’ll help you run the extra mile. If they don’t, you can develop blisters faster than you can reach a single mile.

In all our efforts to enhance and streamline your IT processes, we’ll start by looking at all your logistical advantages, limitations, and objectives to determine which technologies suit you best. Once we’ve obtained them, we’ll perform the appropriate customisation to make them perform optimally under the conditions unique to your organisation.

Below are just some of the enhancements we can apply to your organisation:

  • Put up application and systems monitoring to identify bottlenecks and underutilised resources in your IT infrastructure.
  • Propose areas where you can plough back the generated savings to further improve your ROI.
  • Take scalability into consideration when pushing for certain IT investments to ensure that the IT solution will work for your organisation not only today but even as your organisation grows.
  • Introduce mobile-capable enterprise-class IT solutions that allow seamless collaboration between team members working at different locations on the globe so that pressing matters can be resolved and decisions can be arrived at as quickly as possible.
  • Integrate Business Intelligence into your IT system so that massive collections of data can be processed into insightful information which managers can draw on to make intuitive decisions.
  • Introduce avant-garde solutions, like virtualisation and infrastructure sharing, which may require large scale changes but can also significantly reduce operational costs.

Find out how we can increase your efficiency even more:

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