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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Uncover hidden opportunities with energy data analytics

What springs to mind when you hear the words energy data analytics? To me, I feel like energy data analytics is not my thing. Energy data analytics, however, is of great importance to any organisation or business that wants to run more efficiently, reduce costs, and increase productivity. Energy efficiency is one of the best ways to accomplish these goals.

Energy efficiency is not about investment in expensive equipment and internal reorganization. Enormous energy saving opportunities is hidden in already existing energy data. Given that nowadays, energy data can be recorded from almost any device, a lot of data is captured regularly and therefore a lot of data is readily available.

Organisations can use this data to convert their buildings’ operations from being a cost centre to a revenue centre through reduction of energy-related spending which has a significant impact on the profitability of many businesses. All this is possible through analysis and interpretation of data to predict future events with greater accuracy. Energy data analytics therefore is about using very detailed data for further analysis, and is as a consequence, a crucial aspect of any data-driven energy management plan.

The application of Data and IT could drive significant cost savings in company-owned buildings and vehicle fleets. Virtual energy audits can be performed by combining energy meter data with other basic data about a building e.g. location, to analyse and identify potential energy savings opportunities. Investment in energy dashboards can further enable companies to have an ongoing look at where energy is being consumed in their buildings, and thus predict ways to reduce usage, not to mention that energy data analytics unlock savings opportunities and help companies to understand their everyday practices and operating requirements in a much more comprehensive manner.

Using energy data analytics can enable an organisation to: determine discrepancies between baseline and actual energy data; benchmark and compare previous performance with actual energy usage. Energy data analytics also help businesses and organisations determine whether or not their Building Management System (BMS) is operating efficiently and hitting the targeted energy usage goals. They can then use this data to investigate areas for improvement or energy efficient upgrades. When energy data analytics are closely monitored, companies tend to operate more efficiently and with better control over relevant BMS data.

Web Analytics

There’s a vast ocean of raw customer data on the Web. Ever thought of the implications if somehow you could harness all that data and transform it into useful information? Information that perhaps you can use in your SEO (Search Engine Optimisation) and conversion optimisation?

There are web analytics tools you can employ for these purposes. But using web analytics tools will only win you half the battle. You’ll have to be proficient in configuring these tools to generate insightful and actionable results out of them. A poorly configured tool can produce confusing or even misleading information.

Our web analysts possess the expertise to configure and use web analytics tools, as well as analyse results and leverage information obtained from them.

These are the things we can do to help you take advantage of web analytics.

  • Discuss with your managers to establish your specific goals, to determine what specific data we have to collect/analyse and to plan out how to go about with the entire process.
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  • Monitor the entire web analytics system and implement adjustments when needed.
Benefits Realisation Frameworks – A Useful Handle

One of the greatest challenges of project management is maintaining top-down support in the face of fluctuating priorities. If you elect to take on the role yourself and are peppered by other priorities, it can be a challenge to exactly remember why you are changing things and what your goals are. Sometimes you may not even notice you have reached your goal.

The Benefits Realisation Chart-room

The Benefits Realisation Model is a framework on which to hang key elements of any project. These traditionally include the following, although yours may not necessarily be the same:

  • Definition of the project goal
  • Quantification of intended benefits
  • Project plan versus actual progress
  • How you know you reached your goal
  • Quantification of actual benefits

Another way of describing Benefits Realisation Frameworks is they answer four fundamental questions that every project manager should know by heart:

  • What am I going to do?
  • How am I going to do it?
  • When will I know it’s done?
  • What exactly did I achieve?

The Benefits Realisation Promise

An astounding number of projects fail to reach completion, or miss their targets. It’s not for nothing that the expression ?after the project failed the non-participants were awarded medals? is often used in project rooms. We’re not saying that it is a panacea for success. However it can alert you to warnings that your project is beginning to falter in terms of delivering the over-arching benefits that justify the effort.

When Projects Wander Off-Target

Pinning blame on participants is pointless when project goals are flawed. For example, the goals may be entirely savings-focused and not follow through on what to do with the windfall. At other times realisation targets may be in place, but nobody appointed to recycle the benefits back into the organisation. This is why a Benefits Realisation Framework needs to look beyond the project manager?s role.

Realisation Management in Practice

If the project framework does not look beyond the project manager?s role, then it is over when it reaches its own targets ? and can even run the risk of being an event that feeds entirely off itself. In order to avoid a project being a means to its own end, this first phase must culminate with handover to a benefits realisation custodian.

An example of this might be a project to centralise facilities that is justified in terms of labour savings. The project manager?s job is to build the structure. Someone else needs to rationalise the organisation.

In conclusion, the Benefits Realisation Framework is a useful way of ensuring a project does not only achieve its internal goals, but also remains a focus of management attention because of its extended, tangible benefits.

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