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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Becoming Nimble the Agile Project Management Way

In dictionary terms, ?agile? means ?able to move quickly and easily?. In project management terms, the definition is ?project management characterized by division of tasks into short work phases called ?sprints?, with frequent reassessments and adaptation of plans?. This technique is popular in software development but is also useful when rolling out other projects.

Managing the Seven Agile Development Phases

  • Stage 1: Vision. Define the software product in terms of how it will support the company vision and strategy, and what value it will provide the user. Customer satisfaction is of paramount value including accommodating user requirement changes.
  • Stage 2: Product Roadmap. Appoint a product owner responsible for liaising with the customer, business stakeholders and the development team. Task the owner with writing a high-level product description, creating a loose time frame and estimating effort for each phase.
  • Stage 3: Release Plan. Agile always looks ahead towards the benefits that will flow. Once agreed, the Product Road-map becomes the target deadline for delivery. With Vision, Road Map and Release Plan in place the next stage is to divide the project into manageable chunks, which may be parallel or serial.
  • Stage 4: Sprint Plans. Manage each of these phases as individual ?sprints?, with emphasis on speed and meeting targets. Before the development team starts working, make sure it agrees a common goal, identifies requirements and lists the tasks it will perform.
  • Stage 5: Daily Meetings. Meet with the development team each morning for a 15-minute review. Discuss what happened yesterday, identify and celebrate progress, and find a way to resolve or work around roadblocks. The goal is to get to alpha phase quickly. Nice-to-haves can be part of subsequent upgrades.
  • Stage 6: Sprint Review. When the phase of the project is complete, facilitate a sprint review with the team to confirm this. Invite the customer, business stakeholders and development team to a presentation where you demonstrate the project/ project phase that is implemented.
  • Stage 7: Sprint Retrospective. Call the team together again (the next day if possible) for a project review to discuss lessons learned. Focus on achievements and how to do even better next time. Document and implement process changes.

The Seven Agile Development Phases ? Conclusions and Thoughts

The Agile method is an excellent way of motivating project teams, achieving goals and building result-based communities. It is however, not a static system. The product owner must conduct regular, separate reviews with the customer too.

Migrating from CRM to Big Data

Big data moved to centre stage from being just another fad, and is being punted as the latest cure-all for information woes. It may well be, although like all transitions there are pitfalls. Denizon decided to highlight the major ones in the hope of fostering better understanding of what is involved.

Accurate data and interpretation of it have become increasingly critical. Ideas Laboratory reports that 84% of managers regard understanding their clients and predicting market trends essential, with accelerating demand for data savvy people the inevitable result. However Inc 5000 thinks many of them may have little idea of where to start. We should apply the lessons learned from when we implemented CRM because the dynamics are similar.

Be More Results Oriented

Denizon believes the key is focusing on the results we expect from Big Data first. Only then is it appropriate to apply our minds to the technology. By working the other way round we may end up with less than optimum solutions. We should understand the differences between options before committing to a choice, because it is expensive to switch software platforms in midstream. data lakes, hadoop, nosql, and graph databases all have their places, provided the solution you buy is scalable.

Clean Up Data First

The golden rule is not to automate anything before you understand it. Know the origin of your data, and if this is not reliable clean it up before you automate it. Big Data projects fail when executives become so enthused by results that they forget to ask themselves, ?Does this make sense in terms of what I expected??

Beware First Impressions

Big Data is just that. Many bits of information aggregated into averages and summaries. It does not make recommendations. It only prompts questions and what-if?s. Overlooking the need for the analytics that must follow can have you blindly relying on algorithms while setting your business sense aside.

Hire the Best Brains

Big Data?s competitive advantage depends on what human minds make with the processed information it spits out. This means tracing and affording creative talent able to make the shift from reactive analytics to proactive interaction with the data, and the customer decisions behind it.

If this provides a d?j? vu moment then you are not alone. Every iteration of the software revolution has seen vendors selling while the fish were running, and buyers clamouring for the opportunity. Decide what you want out first, use clean data, beware first impressions and get your analytics right. Then you are on the way to migrating successfully from CRM to Big Data.

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4 Reasons Why You Might be Missing Out on Energy Savings…

?well your company actually, although for many small-to-medium businesses it boils down to the same thing. Governments usually lag behind in terms of innovation but are beating us hands-down when it comes to going green. I have heard that private sector energy savings average less than 1% per year and I for one would not be surprised if that were true. So what is causing this rot, when we started out so enthusiastically? Here are four possibilities for you to mull over.

  1. Your Team is Unevenly Yoked ? A pair of mismatched horses cannot pull a wagon in a straight line any more successfully than a business team can achieve its goals, if there is no agreement on priorities. While your sales team may be all for scoring green points against your competition, your accountant has a budget to balance and your operations department just wants to get on with the job.
  1. Energy?s not in Focus ? The above may in part be due to production goals you set your department heads. Energy is not nearly as greedy as raw materials and human capital. If you tell them to cut 5%, where do you think they are going to look first? You need to put energy savings up there, and agree specific targets as you do with other primary goals.
  1. Your Equipment Could be Over-Spec ? It is a very human thing to put more food on our plates and buy faster cars than we need. Only a few generations ago our ancestors lived through feast and famine, and the shadow of this still influences our thinking. Next time you buy equipment sit around the table and agree the decision criteria together. Then stick to them and repel all attempts at up-selling.
  1. You Are Delegating Too Much ? Delegation is part of company culture, or if you prefer the collective way of doing things. If you delegate something completely it is akin to saying I do not care much about this, make it happen. Energy saving is a financial and moral imperative. The fact the oil price is down does not mean there is no place for sustainability on your desk (and the price is likely to be up again soon).

Governments succeed in saving energy (whereas businesses often do not) because governments have a crowd of stakeholders beating down the door and demanding progress. As business owners we are more likely to do the same when the pressure is upon us, and that pressure surely has to come from us.

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