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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Why DevOps Matters: Things You Need to Know

DevOps creates an agile relationship between system development and operating departments, so the two collaborate in providing results that are technically effective, and work well for customers and users. This is an improvement over the traditional model where development delivers a complete design ? and then spends weeks and even months afterwards, fixing client side problems that should never have occurred.
Writing for Tech Radar Nigel Wilson explains why it is important to roll out innovation quickly to leverage advantage. This implies the need for a flexible organisation capable of thinking on its feet and forming matrix-based project teams to ensure that development is reliable and cost effective.
Skirmishes in Boardrooms
This cooperative approach runs counter to traditional silo thinking, where Operations does not understand Development, while Development treats the former as problem children. This is a natural outcome of team-centred psychology. It is also the reason why different functions pull up drawbridges at the entrance to their silos. This situation needs managing before it corrodes organization effectiveness. DevOps aims to cut through this spider web of conflict and produce faster results.

The Seeds of Collaboration

Social and personal relationships work best when the strengths of each party compensate the deficiencies of the other. In the case of development and operations, development lacks full understanding of the daily practicalities operating staff face. Conversely, operations lacks ? and should lack knowledge of the nuances of digital automation, for the very reason it is not their business.
DevOps straddles the gap between these silos by building bridges towards a co-operative way of thinking, in which matrix-teams work together to define a problem, translate it into needs and spec the system to resolve these. It is more a culture than a method. Behavioural change naturally leads to contiguous delivery and ongoing deployment. Needless to say only the very best need apply for the roles of client representative, functional tester and developer lead.

Is DevOps Worth the Pain of Change?

Breaking down silos encroaches on individual managers? turf. We should only automate to improve quality and save money. These savings often distil into organisational change. The matrix team may find itself in the middle of a catfight. Despite the pain associated with change resistance, DevOps more than pays its way in terms of benefits gained. We close by considering what these advantages are.

An Agile Matrix Structure ? Technical innovation is happening at a blistering rate. The IT industry can no longer afford to churn out inferior designs that take longer to fix than to create. We cannot afford to allow office politics to stand in the way of progress. Silos and team builds are custodians of routine and that does not sit well with development.

An Integrated Organization ? DevOps not only delivers operational systems faster through contiguous testing. It also creates an environment whereby cross-border teams work together towards achieving a shared objective. When development understands the challenges that operations faces ? and operations understands the technical limiters – a new perspective emerges of ?we are in this together?.

The Final Word ? With understanding of human dynamics pocketed, a DevOps project may be easier to commission than you first think. The traditional way of doing development – and the waterfall delivery at the end is akin to a two-phase production line, in which liaison is the weakest link and loss of quality inevitable.

DevOps avoids this risk by having parties work side-by-side. We need them both to produce the desired results. This is least until robotics takes over and there is no longer a human element in play.

Energy Management Tips

Energy management is of interest to various stakeholders; be it heads of facilities, heads of procurement, heads of environment and sustainability, financial officers, renewable energy managers and heads of energy. Some of the energy management tips that can be used to achieve considerable energy savings are:

1) Purchasing energy supplies at the lowest possible price

2) Managing energy use at peak efficiency

3) Utilising the most appropriate technology

1. Purchasing energy supplies at the lowest possible price
Purchasing energy supplies at the lowest possible price could be the starting point to great savings of energy costs. This can be achieved through switching your energy supplier. It is always advisable for companies to always take time to compare the energy tariffs to ensure they are on the best tariff and make great savings.

2. Managing energy use at peak efficiency

(a) Free help

There are some online tools that offer energy-efficiency improvements. These could come in handy in helping someone find out where to make energy-efficiency improvements.

(b) Energy monitors

An energy monitor is a gadget that estimate in real time how much energy you’re using. This can help one see where to cut back on energy consumption.

(c) Turning down thermostats

Turning down radiators especially in rooms that are rarely used/empty rooms or programming the heating to turn off when no one is there can go a long way in saving energy and energy costs.

(d) Use energy saving bulbs

Use of energy-saving light bulbs can cut down on energy usage drastically. Replacing all the light bulbs with energy-saving ones could make significant savings on energy usage and replacement costs since energy saving bulbs also have a longer life.

(e) Switching off unnecessary lights

It is also important to switch off lights that are not in use and to use the best bulb for the size of room.

(f) Sealing all heat escape routes

It is recommended that all gaps should be sealed in order to stop heat from escaping. Some of the heat escape routes are: windows, doors, chimneys and fireplaces, floorboards and skirting and loft hatches. The ways through which this can be achieved are:

? Windows- use of draught-proofing strips around the frame, brush strips work better for sash windows

? Doors – use of draught-proofing strips for gaps around the edges and brush or hinged-flap draught excluders on the bottom of doors

? Chimney and fireplace – inflatable cushions can be used to block the chimney or fit a cap over the chimney pot on fireplaces that are not used often

? Floorboards and skirting – Using a flexible silicon-based filler to fill the gaps

? Loft hatches – the use of draught-proofing strips can help to prevent hot air escaping
It is also important to consider smaller holes of air such as keyholes and letterboxes.

3. Utilising the most appropriate technology
Utilisation of technology as an energy management tool can be by way of choosing more energy efficient gadgets and by way of running technological gadgets in an energy efficient manner.

A Definitive List of the Business Benefits of Cloud Computing ? Part 3

Strengthens business continuity/disaster recovery capabilities

Today’s business landscape calls for companies to have reliable business continuity and disaster recovery capabilities. After all, when the system goes down, customers and even employees would rarely ask ‘why‘ or ‘what happened‘ but instead go directly to the ‘how soon can we get back up‘ part.

So unless they’ve been struck by the same unforeseen disaster your business is also experiencing, a couple of hours downtime is plenty enough for most of these people. What’s worse is when they simply don’t wait until they get access again and just go to other providers that can offer the same services. In short, your inability to provide continuous IT and business services could translate to lost opportunities which your competition would only be too willing to gain. And that’s not even counting the possibility of losing essential data and other potential negative impact that critical IT failure can bring about.

The answer to avoiding such a scenario is of course, having a sound business continuity and disaster recovery plan in place. But this is actually easier said than done.

Traditionally, setting up a business continuity plan entailed some tedious procedures in addition to very costly infrastructure. We’re talking here about acquiring and maintaining practically a replication of the hardware infrastructure and environments currently existing for business-critical systems and data. Note that these mirror systems should be set-up, housed, and maintained in a remote facility or location.

Making the deployment even more complex is the constant need to update the data in storage as well as keep software applications in sync between the system in use and the one on standby mode. This process would involve the physical transfer of data and syncing of applications, which is cumbersome and again, expensive.

While large enterprises would not even think twice about having to spend so much to ensure that operations would never come to a grinding halt, most small and mid-sized organisations would not have the required financial means for them to even start considering this option. Often, the bulk of their disaster recovery plan would simply consist of some tape backups, and a lot of hoping that they would never have to suffer from any outage or IT failure.

But all that can be changed with the arrival of cloud computing.

A cloud strategy offers an affordable solution for business continuity and disaster recovery for SMBs with limited resources and even big companies trying to minimise expenses by looking for alternative options.

A reliable service provider would already have the required infrastructure and software vital to a viable BC/DR plan and complete with the appropriate security measures. Organisations need not spend upfront for these facilities, but get to benefit from having updated data backup and a virtualised mirror system that would allow them to quickly get back up in the event of an outage or catastrophic disaster.

When looking to the cloud for a cost-effective BC/DR plan however, it’s worth keeping in mind that not all cloud providers are created equal. That’s why businesses also have many important factors to take into account before signing cloud contracts.

Yes, provision for continuity and and taking necessary precautions against outages are inherent in the cloud service itself, but you’d be surprised how many of these providers don’t actually take responsibility for service interruption. To give organisations some assurance of the cloud company’s capacity for continued service, contracts should stipulate availability guarantees and liability for downtime that the provider is willing to answer for.

Once these relevant issues are ironed out however, it’s easy for business to see how cloud-based data storage and computing can significantly lower the costs involved for SMB BC/DR while greatly improving efficiency, mobility, and collaboration capabilities.

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