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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How Energy Management Software Benefits Your Business

We’re in an era of price volatility in gas and electricity prices, coupled with greater scrutiny on the environmental impact of businesses in their day-to-day operations. According to the Department of Energy & Climate Change, the average SME can slash its energy bill by 18-25% simply by installing energy efficiency solutions in their facility.

Are you looking to improve energy use in your business? Prevent wastage, track consumption, identify opportunities to save on energy and reduce your carbon footprint while at it? It can be a daunting process to do it all manually. Taking those meter readings, preparing spreadsheets and combing through quotes and energy bills to validate them – this is not something you should be enduring in this day and age. Not when there are dedicated systems built for the task. That’s where Energy Management Software (EMS) comes in.

Importance Of Energy Management Software

Wasted energy = Wasted money

Failing to improve energy efficiency is costing SMEs loads of funds, with it coming to between £5,801 and £12,109 of missed annual savings for individual businesses. These are 18% – 24% of their energy costs. Where do you stand?

Take timers and thermostats for instance. When not properly set and controlled, or even simply forgetting to turn them down when not in the room, it can easily lead to unnecessary costs. How often do your staff forget to turn off the air conditioning when they leave the meeting rooms? Do you account for weekends or bank holidays when setting the controls of the AC? Mistakes like turning the temperature high on the thermostat to “quickly warm the room” are common, yet heating costs go up by about 8% with every 1°C rise.

There are installations that you can make to minimize wastage. For example, the Chinese Contemporary Arts Centre in Manchester is able to save £4,363 annually just by having a £100 timer installed to its heating system.

Some energy saving measures won’t even cost you a penny. For instance, did you know that you can save up to 30% of your heating costs simply by preventing cold air from entering the building? This means not keeping the doors just open for convenience. So how can you find points of weakness and areas of improvements in your facility? Install an EMS.

While businesses vary from one industry to the next, energy management basically boils down to:

Metering systems where the consumption is recorded
Determining how much energy can be saved by identifying opportunities for this
Implementing policies and changing existing systems to take advantage of these opportunities
Tracking progress after the improvements have been made

Benefits Of EMS For Your Business

Data Acquisition – Where accuracy and reliability matters

Energy data comes from different angles and formats. From the building automation systems and IoT devices that have been set up, bills sent in by the utility company to the spreadsheets needed to analyse them – what if you had it all from one point of reference? The EMS gives you a “bird’s eye view” of all your energy data from one interface. It collects the data from any system – and being cloud-based, is accessible from anywhere in the world.

The ecoVaro data loggers can be connected with the Wi-Fi network of the facility or function independently, depending on your specific requirements. They monitor readings 24/7, retaining the data even when they have been powered off. The end-to-end encryption assures you of the security of the information that is being obtained.

Integrating the EMS into the existing systems will simplify the data collection process, and even for the cases where there isn’t a direct method transferring the data into the system, the setup wizards that come with the EMS allow you to prepare the required data and import it.

Data Analysis: From consumption, energy leaks to areas of improvement

The first step is accurately collecting the data. The next step is making sense of it. The analysis modules with the EMS allow you to monitor the energy consumption of the facility in real-time.

The energy data is displayed in engaging graphics that are easy to understand at a glance. The dashboard setup, with its customised layout, enables you to monitor the performance of the specific information you want, toggling through usage and savings data, to the meters and sites that are being tracked. With the ecoVaro Energy Management Software, you get Consumption Charts, Regression Charts, Cusum Charts and Heatmaps right to the submeter level. This information can be broken down into 15-minute durations, with the daily, weekly and monthly consumption reports.

Getting everyone on board

Making changes to company-wide energy policies needs to have the different parties on board – from the energy manager in charge of crunching the numbers and presenting the information, the CFO of the business, the staff running day-to-day operations, all through to plant operators for those in industries. An easy mode of communication is needed, that will be understood and availed in reports that can be shared with the relevant parties in the organization. The graphical displays that come with the EMS enable actionable information to be displayed in a simplified manner – that way all members of the business or organization will be able to comprehend it.

Meet your Energy Goals

The baseline that is created in the EMS is used as a standard when assessing the impact of future changes to the energy consumption. Using the information that has been obtained, the management can set up energy saving policies and implement changes, and track KPIs (key performance indicators) along the way. For instance, the market research company DJS Research installed a timer switch that turns off their two water coolers when they aren’t in use. This action saves them £144 annually, and had already paid for itself within 35 days.

You will be in a position to assess the actions that provide your business with the best ROI over time, monitoring the progress and verifying the savings from one central dashboard. Cutting costs here will enable you to divert the funds to other areas of your business, including promotions, marketing, and product development.

For businesses in the energy sector- including electric, oil and gas plants, they specifically need carbon emission reports, to pinpoint areas where the building’s energy efficiency can be improved. ecoVaro EMS allows you to set alarms and KPIs in the facility for issues to be identified and resolved immediately they crop up.

Turn to ecoVaro

EMS systems are used across the board – from optimising energy use in hotel rooms and hospitals, mapping out usage patterns for those in the agriculture and supply chain niches, running facilities for utility providers, all through to increasing the efficiency of equipment operation for business in the food and beverage sector. Want to learn how you can cut down your energy bills and make your business more eco-friendly? EcoVaro’s team is ready to get you started.

2015 ESOS Guidelines Chapter 6 – Role of Lead Assessor

The primary role of the lead assessor is to make sure the enterprise?s assessment meets ESOS requirements. Their contribution is mandatory, with the only exception being where 100% of energy consumption received attention in an ISO 50001 that forms the basis of the ESOS report.

How to Find a Lead Assessor

An enterprise subject to ESOS must negotiate with a lead assessor with the necessary specialisms from one of the panels approved by the UK government. This can be a person within the organisation or an third party. If independent, then only one director of the enterprise need countersign the assessment report. If an employee, then two signatures are necessary. Before reaching a decision, consider

Whether the person has auditing experience in the sector
Whether they are familiar with the technology and the processes
Whether they have experience of auditing against a standard

The choice rests on the enterprise itself. The lead assessor performs the appointed role.

The Lead Assessor?s Role

The Lead Assessor?s main job is reviewing an ESOS assessment prepared by others against the standard, and deciding whether it meets the requirements. They may also contribute towards it. Typically their role includes:

Checking the calculation for total energy consumption across the entire enterprise
Reviewing the process whereby the 90% areas of significant consumption were identified
Confirming that certifications are in place for all alternate routes to compliance chosen
Checking that the audit reports meet the minimum criteria laid down by the ESOS system

Note: A lead assessor may partly prepare the assessment themselves, or simply verify that others did it correctly.

In the former instance a lead assessor might

Determine energy use profiles
Identify savings opportunities
Calculate savings measures
Present audit findings
Determine future methodology
Define sampling methods
Develop audit timetables
Establish site visit programs
Assemble ESOS information pack

Core Enterprise Responsibilities

The enterprise cannot absolve itself from responsibility for good governance. Accordingly, it remains liable for

Ensuring compliance with ESOS requirements
Selecting and appointing the lead assessor
Drawing attention to previous audit work
Agreeing with what the lead assessor does
Requesting directors to sign the assessment

The Environment Agency does not provide assessment templates as it believes this reduces the administrative burden on the enterprises it serves.

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

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