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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9 Cloud Security Questions you need to ask Service Providers

Companies in Ireland and the UK who are considering cloud adoption might already have a general idea of the security risks inherent in cloud computing. However, since different providers may not offer the same levels of risk mitigation, it is important to know which providers can give sufficient assurance on cloud security.

Here are 10 cloud security questions to ask service providers vying for your attention.

1. Where will my data be located?

There are a variety of reasons why you will want to ask this question. One big reason is that there are certain countries that don’t have strict legislation (or any legislation at all) pertaining to cloud computing. In that case, the provider won’t be as motivated to apply high levels of risk mitigation.

So if your data is hosted off shore, then you might want to reconsider or at least conduct a deeper study regarding the security conditions there.

2. Do you have provisions for regulatory compliance?

Certain standards and regulations (e.g. PCI DSS and possibly the EU Data Protection Directive) have specific guidelines pertaining to data stored in the cloud. If your organisation is covered by any of these legislation, then you need to know whether your provider can help you meet requirements for compliance.

3. Who will have access to my data?

In a cloud environment, where your data is going to be managed by people who aren’t under your direct supervision, you’ll have to worry as much about internal threats as you would with external threats.

Therefore, you need to know how many individuals will have access to your data. You also need to know relevant information such as how admins and technicians with data access rights are screened prior to getting hired. You also need to determine what access controls are being implemented.

4. How is data segregated?

Since there will be other clients, you will want to know how your data is going to be segregated from theirs. Is there any possibility of an accidental or intentional data breach due to poor data segregation? Find out if your data is going to be encrypted and how strong the encryption algorithm is.

5. How will you support investigative activities?

Sometimes, even if strong cloud security measures are in place, a data breach can still happen. If it does happen, the provider should have ways to track each user/administrator’s activity that can sufficiently support a detailed data forensics investigation.

Find out whether logs are being kept and how detailed they are.

6. Are we protected by a Disaster Recovery/Business Continuity plan? How?

Don’t be fooled by sales talk of 100% up-time. Even the most robust cloud infrastructures can suffer outages too. But the important thing is that, when they do fail, they should be able to get up and running in the soonest time possible.

Don’t just ask about their guaranteed RPOs and RTOs. Find out whether your data and applications will be replicated across multiple sites. Unless the provider says they will be, you need to find a provider with a better infrastructure.

7. Can I get copies of my VMs?

In a cloud infrastructure, your servers are actually in the form of files known as virtual machines (VMs). Because VMs are just files, they should be easily copied. There may be issues though, like the VMs might be stored in a not-so-popular proprietary format. Another possible issue is that the provider may simply not allow copying.

Having copies of your VMs can be useful should you later on decide to transfer to another provider or even duplicate your cloud infrastructure on your own.

8. What will happen to my data when I scale down?

One outstanding benefit of cloud computing is that when your business demands drop, you can easily scale down computing resources and reduce your cloud spending. ?But what will happen to your data when you decommission virtual servers? Will they be discarded?

You might want your data to be retained up to a certain period. On the other hand, you might also want them to be deleted immediately. Ask about the provider’s data deletion/data retention policies and see if they are in line with yours.

9. What will happen to my data if I decide to close my account?

There might come a time when you’ll want to terminate your contract with your cloud provider. Just like in issue #8, you’ll want to find out more about data deletion/data retention policies.

Although some providers can give you detailed answers, many of these answers can include a lot of technical jargon that can leave you totally confused. If you want someone you can trust to:

  • simplify those answers;
  • help you pick the right cloud service provider, and
  • even make sure cloud security is really upheld once your cloud engagement is ?under way

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
2015 – What’s ahead for UK Business?

According to reports just in, the global environment industry is down. Less money is available for what some CEO?s still see as grudge expenditure, and many U.S. agencies are seeking soft budget cuts. The UK is proving to be an exception following the announcement of ESOS, and EcoVaro does not expect the May elections will have much impact in this regard.

ESOS calls for mandatory energy assessments in companies above a certain size, and requires specific proposals to cut consumption. There is no indication of compulsory follow-through, although it is clear the Environment Agency hopes rising electricity prices and the prospect of monetary savings will do the trick.

It is an open question whether the Tory government would have interfered with commerce to this extent, were it not for the European directive that enforced it. The overall goal is to cut EU energy consumption across the board by 20% by 2020. Energy consultants are rubbing their hands in glee. EcoVaro?s response is to provide cloud-based software.

We will be interested to see how many UK companies make the first deadline of 5 December 2015, in the light of reports that half the 9,000 firms affected appear not to even know that ESOS exists. Some will no doubt pay last-minute lip service. Those with an eye on their own sustainability will grasp the Energy Saving Opportunity Scheme with both hands.

The initial ESOS deadline was always going to be a challenge. Some big corporates have stolen a march albeit egged on by green stakeholders. The next challenge comes in June 2015 with the implementation of the European Union?s ?Waste Catalogue? of hazardous substances, and rules for their disposal. We hope a new ISO 14001 will arrive soon and pull the loose threads together.

The introduction of carbon trading late this year brings further opportunities to increase profits through wise stewardship. Auditable metrics are essential for this.

EcoVaro can assist by processing your raw data. We provide this service on a virtual cloud. In return, you can get advice on optimising the quality of your graphs for presentations. 

Maturing Into CMMI

 

In all likelihood, the reason why you landed on this page was because you were seeking CMMI experts to help you meet the demands of a growing number of potential clients who require CMMI compliance.

Whether or not you’re here for that reason, you might want to know why CMMI or Capability Maturity Model Integration is steadily becoming a common denominator among highly successful software and engineering development companies. If you stay for a while, we can show you how CMMI can substantially increase your organisation’s chances of:

  • reducing development costs;
  • acquiring new customers and retaining old ones;
  • beating deadlines;
  • bringing down development time;
  • increasing the overall quality of your products and services; and
  • improving the level of satisfaction of customers, employees, and all other stakeholders.

Surely, no organisation can be too small or too big to aspire for such benefits of attaining high levels of maturity and capability.

If you want to look beyond Maturity Level ratings, then you’ve come to the right place. We focus on introducing CMMI principles and blending them into your organisation’s culture to achieve a truly superior and sustainable business advantage. Compliance will then be an inevitable offshoot of the actions you make.

Likewise, if you simply want to obtain a deeper understanding of CMMI and learn how it can be applied either to your entire organisation or to specific projects, we’d be happy to assist you in that regard as well.

Finally, when you’re ready, we can also conduct CMMI appraisals either for benchmarking purposes or simply for determining how well your process improvement initiatives are going.

CMMI Consulting

Are you worried that implementing CMMI might entail an overhaul of your current processes? Don’t be.

CMMI is all about improving current processes, not replacing them. Ideally, the final result of all process improvement activities should be hinged on your own business objectives and context, so we’ll make sure it remains that way when we work with you.

We rely on our extensive knowledge and experience in CMMI, engineering, software development, and technologies as well as in change and project management in providing model-based process improvement services. Whether you’re gearing up for an appraisal or simply want to employ CMMI-based practices, these are the things we can do for you.

  • Help you interpret how CMMI can be implemented in relation to your business.
  • Assist in convincing sponsors and stakeholders to support your CMMI implementation initiatives.
  • Introduce the necessary training to all individuals who need to undertake them.
  • Conduct a Gap Analysis to find out where your company’s current processes stand relative to their CMMI specifications.
  • Assemble a process group that will champion your process improvement initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
  • Introduce tools and practices that will improve the efficiency of our process improvement initiatives.
  • Carry out periodic evaluations and produce reports to provide sponsors and stakeholders a clear picture of our progress.

CMMI Training

Still not convinced CMMI is right for you? There’s only one way to fully grasp the benefits of implementing CMMI – take the Introduction to CMMI course. Although what happens next is entirely up to you, we’re pretty sure you’ll make the right decision after passing it.

Do you need to include people from your organisation in a SCAMPI (Standard CMMI Appraisal Method for Process Improvement) team? They’ll have to undergo this course too. The Introduction to CMMI is for systems and software engineering managers and practitioners, appraisal team members, process group members, and basically anyone who want to grasp CMMI fundamentals.

This is what you’ll be able to do after going through 3 days of lectures and exercises:

  • Gain a deeper understanding of the various components of CMMI-DEV models and their relationships.
  • Discuss the process areas in CMMI-DEV models.
  • Extract and interpret aspects in the model relevant to your own organisation’s processes.

We also offer highly specialised training and workshops such as those for:

  • Achieving High Maturity Levels
  • Top Executives
  • Team Building in Preparation for Appraisals

CMMI Appraisal

An organisation new to CMMI will want to know first how far their current processes are relative to the implementation of model-based improvements in order to determine the resources and time that have to be spent to get there.

Similarly, an organisation already well acquainted with CMMI and has begun taking steps in improving processes, will eventually want to know how close it has come to the Maturity Level it has aimed for.

In both cases, these organisations will have to be assessed by a qualified CMMI appraiser to obtain an accurate picture of their current status. We can perform appraisals on either your entire organisation or on specific projects/practices within a process area. Our appraisers can conduct the following SCAMPI (Standard CMMI Appraisal Method for Process Improvement) appraisals:

  • SCAMPI Class A – This is what you’ll need if you’re aiming for a level rating.
  • SCAMPI Class B – You may want to use this for process reviews or for preparing for a SCAMPI Class A.
  • SCAMPI Class C or Gap Analysis – We typically conduct this for organisations who have yet to implement CMMI-based initiatives so that they can design the most cost-effective road map for the implementation proper.

Ready to work with Denizon?

Contact Us Today