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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Field service and improved visibility

A manager is someone who has control over a company. They are given the responsibility of overseeing what the company does and making important decisions. The manager is the most important person in the empire and needs to be in the know at all times. Not what happened a day ago but in real-time and from any place.

Information is necessary for this to happen. It needs to be concise, brief and straightforward. Ideally, access to job status, location information, customer information, notifications and location information should be on the palms of their hands.

To sum it all up, there should be fluid communication among personnel in the field. Information should be accessed easily from one place as it flows to another to maintain steady two-way communication. This is possible with automation meaning that no amount of data will be left unseen or unused because of paperwork that was never handed over or looked into, reducing the chance of misinformation or missing information to a minimum.

Ways improved visibility will help your business through Field Service

Organisations using field services will agree that improved visibility has more business benefits and the real question is what aspect needs improving rather than discussing the benefits.

Real-time visibility

Managers need to be in the know from anywhere at any time. The manager needs information about the company. The need not to be physically present to have an idea of what’s going on. They should know everything at all times, from what was planned for the day to real-time events.

All this information should be easily accessed from one central point and should contain everything about the company and other relevant information.

Extending the back office into the field

This two-way communication is virtually irreplaceable. At any time, the information should flow among technicians in the field and those in the back office. This will help to have a better idea of how to manage the workload and come up with solutions to some work-related issues.

Everyone in the team should be informed and be up to speed about real-time events. Keeping everyone updated improves visibility because they can make updates and decisions based on the kind of information they get.

No more lost paperwork

Managing paper trail can be quite a hassle for organisations. With tons of workload, there can be many delays meaning that some information might be missed or forgotten. People might also choose not to turn up for work for days on end and can affect how much info is processed. Some work can be left undone, and work not invoiced.

When organisations use field service management services, information is fed only once and everything else is done automatically. Say goodbye to lags or relying on last month?s data. Work will move faster because people will have more time to focus on important things rather than chasing an endless paper trail.

Business intelligence

Field service management technology will let you know what is being done in the field and with such an abundance of data, will make sound decisions for the business.

Every decision is hinged on cold facts. Information needs to be easily accessed and filtered into the right categories so that sound business decisions are made from the collected data.

Growing revenue

The abundance of real-time information and improved visibility can determine whether a business will grow or not. Each piece of information can show trends that are critical for any business to improve. Trends show how each sector is doing and sheds more light into specific areas that need a total overhaul. This may include improving customer service, products on retail or hiring more technicians.

Without information, a company is one step closer to going out of business. Every action should be geared to increase the revenue and this starts by making the right choices.

Visibility when working offline

Working offline is an issue that can affect visibility. Sometimes agents will need to work in areas that have little network coverage or are deep down working in tunnels or are around heavy machines and turbines. Field service solutions are built for the mobile environment and for workers who may find themselves in non-connected areas so that they can still use their device while offline. This makes sure that there is no loss of information while working in-field

Time-saving

Certainly, business is constrained to its environments and if the demand changes it should prove to be flexible enough to adjust to changes as they happen. Field service solutions operations like schedule need to update instantly. Once activities start rolling, nothing should create lags in the schedule so that operations flow seamlessly at all time.

Field workers can then make updates and document changes easily on the job site directly on their device by using responsive site menus, drastically saving time while feeding data and complete orders.

Improved customer service

It is not a clich? to say that the customer is always right. With real-time information, both field service and back-office technicians can improve customer relations and satisfaction. With a unified system of sharing information like the ERPs and CRMs, the field officer can know more about specific clients, their history and other data to know more about what should be done in current and future orders. This means that better decisions will be made for each customer.

How improved visibility benefits different parts of the organisation

Improved visibility in all areas of the business makes information more accessible. Here are some of the benefits that various sects of a business can get from improved visibility.

? The business owner
The manager owns the company and can access all information with just a single tap. A lot of data can be used to analyse the health of the venture. This includes revenue, inventory, customer surveys, employee hours, invoices and customer data.
Profitability is increased by putting more emphasis on customer satisfaction and improving the quality of end products and services.

? The service manager
The service manager can see what is going on in the field in real-time, and look into measures that can improve the productivity of staff members in various departments.
And with workflow automation, time-saving is at the maximum because there is less paperwork consequently improving scheduling and job completion rates.

? Service administrator/ dispatcher
For the team in the office, they can assign tasks faster. Scheduling is automatically done and updated in real-time. It eliminates the need for paperwork and leaves more time to be productive on other errands.

? The field technician
Improved visibility for a field worker means that they can do their best in any task. They can share or get critical information about orders and customers. This drastically improves job completion rates and customer satisfaction.

? HR
Live information can be used to track certain orders, the time it takes to complete orders, and the number of staff required in the organisation. Such data can be used in HR to reduce payroll errors and erroneous overtime costs.

? Finance
Field service management software can also benefit the finance team by automation of invoices. A work order can be tracked from start to the end and invoiced immediately to retain faster payments. Relevant data can be used to track revenue and expenditures, and costs.

Real-time visibility gives a company many solutions to manage the workload. In the end, visibility is also useful in increasing revenue and a smooth transition of information for the company.

The Rights of Individuals Under The General Data Protection Regulation

The General Data Protection Regulation or GDPR is a European Union law reinforcing the rights of citizens concerning the confidentiality of their information, and confirming that they own it. We thought it would be interesting to examine the GDPR effective 25 May 2018 from an Irish citizen?s perspective. This article is a summary of information on the Data Protection Commissioner?s website, but as viewed through a businessperson?s lens.

How the Office Defines Data Protection

The Office believes that organisations receiving personal details have a duty to keep them private and safe. This applies inter alia to information that individuals supply to government, financial institutions, insurance companies, medical providers, telecoms services, and lenders. It also applies to information provided when they open accounts.

This information may be on paper, on computers, or in video, voice, or photographic records. The true owners of this information, the individuals have a right:

  • To make sure that it is factually correct
  • To the assurance that it is shared responsibly
  • That all with access only use it for stated purposes

Any organisation requesting personal information must state who they are, what the information is for, why they need to have it, and to whom else they may provide it.

Consumer Rights to Access Their Personal Information

Private persons have a right under the GDPR to a copy of all their information held or processed by a business. The regulation refers to such businesses as ?data controllers? as opposed to owners, which is interesting. They have to provide both paper and digital data, and ‘related information?.

Data controller fees for this are discretionary within limits. The request may be denied under certain circumstances. The data controller may release information about children to parents and guardians, only if it considers a minor too young to understand its significance. Other third parties such as attorneys must prove they have consent.

Consumer Rights to Port Their Data to Different Services

Since the personal information belongs to the individual, they have a right not only to access it, but also to copy or move it from one digital environment to another. The GDPR requires this be ?in a safe way, without hindrance to usability?. An application could be a banking client that wants to upload their transaction history to a third party price comparison website.

However, the right to data portability only applies to data originally provided by the consumer. Moreover, an automated method must be available for porting. Data controllers must release the information in an open format, and may not charge for the porting service.

Consumer Rights to Complain About Personal Data Abuse

Individuals have a right under the General Data Protection Regulation to have their information rectified if they discover errors. This right extends to an assurance that third parties know about the changes – and who these third party entities are. Data controllers must respond within one month. If they decline the request, they must inform the complainant of their right to further remedial action.

If a data controller refuses to release personal information to the owner, or to correct errors, then the Data Protection Office has legal power to enforce the consumer?s rights. The complainant must make full disclosure of the history of their complaint, and the steps they have taken themselves to attempt to set things right.

Further Advice on Getting Things Ready for 25 May 2018

The General Data Protection Regulation has the full force of law from 25 May 2018 onward, and supersedes all applicable Irish laws, regulations, and policies from that date. We recommend incorporating rights of data owners who are also your customers into your immediate plans. We doubt that forgetting to do so will cut much sway with the Data Commissioner. Remember, you have one month to respond to consumer requests, and only one more month to close things out subject to the matter being complex.

Align IT Investments With Organization Goals

While some organisation leaders loathe spending on IT, a growing number are already convinced of the necessity of investing in it. Unfortunately, a substantial fraction of those convinced to pursue IT investments are misguided as to which initiatives are really contributory to reaching their organisation’s goals.

In the end, many of their purchases either end up underutilised or become white elephants altogether. There are also those difficult to spot – IT purchases that do become integrated into daily operations but have little effect on the organisation’s growth, positioning, profitability, or efficiency.

If a purchase is to cost your company a fortune, then its positive impact on established company objectives should reflect accordingly. But how would you know it would? You can’t hope to foresee all its benefits especially if the IT solution is still quite new to you.

Our job is not only to identify the strengths of an IT system but also to determine whether these strengths are at all useful to your organisation’s thrusts.

Basically, here’s what we’ll do:

  • Conduct a rigorous analysis of your organisation to determine the specific and overall impact of certain IT solutions. We’ll be looking for areas where the effects of IT can result in the most rapid reduction of costs and, at the same time, drive the organisation in the direction of its established goals.
  • Propose cohesive best-of-breed solutions in line with the results of our analysis. Our familiarity with the IT landscape and our extensive selection of contacts in the industry will allow us to conduct insightful picks from a vast field of choices.
  • Establish best practices to make sure IT investments are optimally utilised.
  • Perform periodic reviews to ensure practices and processes are still in line with the established goals.

Find out how we can increase your efficiency even more:

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK

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