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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What are Operational Reviews

Faced with growing competition, businesses continually need to find new innovative solutions and ideas to improved organizational performance, especially in various cut-throat industries where innovation and good management can make or break the company.

This is the reason why, businesses place greater emphasis on the evaluation of efficiency, effectiveness, and economics of its operations.

Conducting regular Operational Reviews are key to keeping your company at peak performance.

What is an Operational Review

An operational review is an in-depth and objective review of an entire organization or a specific segment of that organization. It can be used to identify and address existing concerns within your company such as communication issues between departments, problems with customer relations, operating procedures, lack of profitability issues, and other factors that affect the stability of the business.

Operational reviews allow the organization members to evaluate how well they are performing, given that they perform appropriately according to the procedures set by them, allocating their resources properly, and performing such tasks within time frame set and using cost-effective measures. More importantly, it also shows your company how well it is prepared to meet future challenges.

What are the objectives of an Operational Review

The goals of an operational review are to increase revenue, improve market share, and reduce cost.

An operational review allows the management to see their company in a different light i.e a larger perspective. That is, it gives the management the opportunity to evaluate if the entrusted resources were used wisely to achieve the desired results of operations.

Operational reviews provide a comprehensive assessment of authority in that they help define expectations, and empower people within an organization to enact? up on it. This is due feedback provided will help them to better gauge the value of tasks performed and whether the job is being done the right or wrong way, and on what areas the company can excel and improve on.

The whole is greater than the sum of its parts

Questions worth considering in an Operational Review

Are you able to view your own organization as a whole from an objective angle?

Do the different departments complement each other so that they form a cohesive unit that boosts your business in the right direction?

With our comprehensive assessment of your organization?s current systems, operations, processes, and strategies, our operational review programs aim to help you in achieving these lofty goals: to improve business profitability and identify incompetence in both operations and organizational systems.

Benefits of an Operational Review

The main objective of an operational review is to help organizations like yours to learn how to deal with and address issues, instead of simply reacting to the challenges brought about by growth and change.

Information and data gathered in an Operational Review is practical from both a financial and operational perspective. Using? data, management can then formulate recommendations, which are not only realistic, but more importantly, can help the organization achieve its goals.

The Operational Review recognizes the extent to which your internal controls actually work, and enables you to identify and understand your strengths, weaknesses, opportunities and threats.

What should be included in an operational review

  • Assess compliance within your own organizational objectives, policies and procedures
  • Evaluate specific company operations independently and objectively
  • Impartial assessment regarding the effectiveness of an organization’s control systems
  • Identify the appropriate standards for quantifying achievement of organizational objectives
  • Evaluate the reliability and value of the company’s management data and reports
  • Pinpoint problem areas and their underlying causes
  • Identify opportunities to increase profit, augment revenue, and reduce costs without sacrificing the quality of the product or service.

More Operational Review Blogs

 

Carrying out an Operational Review

 

Operational Reviews

 

Operational Efficiency Initiatives

 

Operational Review Defined

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IT Risk and Control Solutions Specialists – Why you need them more than ever

Over the years, the capabilities of IT systems have certainly grown by leaps and bounds. But so have the risks that accompany them. Countless threats to IT systems now exist that are capable of seriously disrupting business operations. That’s why companies have to conduct assessments aimed at making sure their systems are still capable of functioning effectively, efficiently, and securely all the time.

If you think you’ve been lucky enough to be spared from these threats, then maybe it’s because you haven’t conducted a risk assessment on your IT system recently. All too often, we hear of CIOs who believed their IT system was in tip-top condition, only to be later caught off-guard by a critical system breakdown that would eventually cripple their business for days or weeks.

More information assets to look after

If, before, you only had to worry about regular office applications, workstations, a LAN and a server, today’s varied and more sophisticated information assets are more challenging to maintain.

In addition to network operating systems, database management systems, content management systems, email systems, virtualization platforms, document management systems, business intelligence applications, and accounting software, a typical enterprise may also have to look after firewalls, intrusion detection systems, storage and backup systems, and data loss prevention systems, to mention a few.

These understandably require the services of experts spanning a wide range of skill sets.

Rising threats to corporate identity and privacy

Individuals are no longer just the ones being preyed upon by identity thieves. Businesses can now be subject to corporate identity theft as well. You could wake up one day finding your business already accused of carrying out illegal activities, a big chunk of your money gone, and your directors? seats already occupied by complete strangers.

To make things worse, corporate threats aren’t just coming from the outside.

Threats to corporate privacy, for instance, can come from within the organisation itself. Sensitive information like trade secrets and financial data are often leaked out (purposely or inadvertently) by employees. This is largely caused by the ever growing number of options for communications and transferring data (e.g. emails, instant messaging, blogs, social networking sites, ftp, P2P, etc.).

Greater challenges in designing, developing, and implementing policies and programs

Laws and regulations like SOX and Solvency II, which have direct impacts on IT, are on the rise. That is why corporate policies and programs now require sweeping changes. You now have to be more deliberate in integrating IT when establishing governance, internal controls, change management, incident management, and performance management.

A solid understanding on widely accepted frameworks and good practices like COBIT, COSO, and CMMI will help you considerably in such undertakings. Using these frameworks as guidelines will not only help you keep your policies and programs attuned to the times, they will also keep you in compliance with regulations.

Increasing demand for disaster recovery and business continuity capabilities

Every time you have a down time, you increase the probability of losing your customers to competitors. The longer the down time, the greater that probability becomes. Therefore, when a major disruption strikes, you should be able to recover at the soonest. If possible, you should be able to deliver products and services as usual.

This of course requires spending to increase your disaster recovery (DR) and business continuity (BC) capabilities. Are you ready for it? Migrating your IT infrastructure from traditional systems to the latest technologies that are better equipped for BC/DR requires careful planning and implementation to ensure an optimal return on investment.

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Scrumming Down to Complete Projects

Everybody knows about rugby union scrums. For our purposes, perhaps it is best to view them as mini projects where the goal is to get the ball back to the fly-half no matter what the opposition does. Some scrums are set pieces where players follow planned manoeuvres. Loose / rolling scrums develop on the fly where the team responds as best according to the situation. If that sounds to you like software project management then read on, because there are more similarities?.

Isn’t Scrum Project Management the Same as Agile?

No it’s not, because Scrum is disinterested in customer liaison or project planning, although the team members may be happy to receive the accolades following success. In the same way that rugby players let somebody else decide the rules and arrange the fixtures, a software Scrum team just wants the action.

Scrum does however align closely ? dare I say interchangeably with Agile?s sprints. Stripping it of all the other stages frees the observer up to analyse it more closely in the context of a rough and tumble project, where every morning can begin with a backlog of revised requirements to back fit.

The 3 Main Phases of a Scrum

A Scrum is a single day in the life of a project, building onto what went before and setting the stage for what will happen the following day. The desired output is a block of component software that can be tested separately and inserted later. Scrumming is also a useful technique for managing any project that can be broken into discreet phases. The construction industry is a good example.

Phase 1 – Define the Backlog. A Scrum Team?s day begins with a 15 minute planning meeting where team members agree individual to-do lists called ?backlogs?.

Phase 2 – Sprint Towards the Goal. The team separates to allow each member to complete their individual lines of code. Little or no discussion is needed as this stage.

Phase 3 – Review Meeting. At the end of each working day, the team reconvenes to walk down what has been achieved, and check the interconnected functionality.

The 3 Main Phases of a Scrum ? Conclusions and Thoughts

Scrum is a great way to liberate a competent project team from unnecessary constraints that liberate creativity. The question you need to ask yourself as manager is, are you comfortable enough to watch proceedings from the side lines without rushing onto the field to grab the ball.

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