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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Saving Energy Step 4 – Breathing Life into the Project

Today we consider the fourth step on the road to energy saving, when we introduce key contributors who will pull it all together. We have been on quite a journey. We started by developing a management system and then followed up with practical improvements, while challenging the assumptions behind the energy bills we may have paid unchallenged in the past.

After we knock off the big-ticket savings, managing energy becomes a process of improvement characterised by smaller increments. Kaizen is the classic model and it includes everybody in the organization from the janitor to the CEO. I inverted the pyramid deliberately, because ideas deserve considering no matter where the originator parks in the company yard.

People ? our people ?are truly central to the process. Energy adds extra leverage to their efforts, keeps them warm in winter, cool in summer and powers up the ovens in the company canteen. They are brimming over with ideas because that is the nature of being human. The best managers are those who release this potential and participate in its flowering,

It is important not to threaten job security. So many savings-driven initiatives have ended in job losses that people on the shop floor automatically suspect another round. Shrinking carbon footprints is about making the world a better place for everyone. We become more effective when we turn ?increasing profit? into making the enterprise sustainable in itself.

Engaging employees is more than office circulars and speeches at the Christmas Party. Organizations are organic places where trust grows slowly but conflict can flare in a moment. Before involving your people in your energy ?kaizan? make sure your words and intentions overlap perfectly. You will be amazed at the power you unlock in your people.

The best way I know of doing this is through your health and safety structure, which then becomes your environment, health and safety structure EHS. As you explore this idea at safety committees you find these things overlap, in the sense of creating people-centric environments at work and home.

That said, there is no magic formula for achieving employee engagement. The fact that people universally want a cleaner planet is the power to tap into. One way to form a team is to create one artificially and give it a task. The other is to work together towards a shared objective. Which one do you prefer?

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Cloud Computing Trends: Where is the Cloud Headed Next?

Cloud adoption has been quick and painless at the consumer level. For instance, everyone’s on Gmail, YouTube, Facebook and Twitter on a daily basis yet most think nothing of the fact that they’re already using cloud-based services. Small businesses have also discovered how cloud solutions have raised efficiency in the workplace up a notch or two, while also bringing about significant cost savings. Cloud applications, particularly those for communication, file sharing, office software, backup and storage, and customer management, have rapidly grown in usage among SMBs.

In the same manner, large corporations are starting to see the potential of moving some of their IT department, whether its infrastructure or network management, to the cloud. By all indications it would seem that whether we are ready for it or not, cloud computing technology is here for the long haul.

So where is the cloud headed to next? In this post we examine the trends in the world of cloud computing and what likely lies in store in the near future for cloud users.

Focus on Security

Security has always been a key concern in the cloud computing industry and this will not go away anytime soon. If anything, data security in the cloud will only get to be in the limelight even more as cloud adopters grow in number. That’s why we expect professional cloud services providers to start implementing measures that will help slowly build up confidence in cloud security.

We should soon see more advanced security techniques and protocols that would increase the overall level of privacy and protection for cloud-stored information. Tighter security for login encryptions and prevention of unauthorized access are priority although there are a lot more issues that may need to be addressed. Now it remains to be seen whether these moves are enough for corporate clients to put their full trust in the cloud. But then again, they can always find ways to stay secure while making use of cloud computing where they can, which brings us to the next cloud trend.

Hybrid Approach

Large businesses are taking a longer time to get used to and actually use cloud services, and understandably so. After all, these companies have more at stake when it comes to dealing with such valid issues as security, compliance, outages, legacy systems, and more. However, they also cannot ignore the very appealing characteristics of the cloud. For big companies that have substantial IT needs, scalability, business agility, and faster deployment are listed as the biggest draws of the cloud.

This is why analysts predict that as as these businesses look toward leveraging the benefits of the cloud while at the same time maintaining control over mission critical data and systems, the use of a hybrid approach, i.e. putting some services in a public and at the same time opting to utilize a private cloud for other applications, will see enormous growth.

Mobile Cloud Computing

The BYOD or Bring Your Own Device business policy is another emerging trend that would not have been possible if not for cloud technology. This practice involves having employees bring their mobile devices to work, allowing them to access company files, data, and applications from their personally-owned gadgets in and out of the workplace.

As with any new business practice, the concept of BYOD can be both advantageous and disadvantageous. On the one hand, some believe it helps increase employee productivity and lifts their morale, while reducing overall IT costs. On the other hand, BYOD also opens up a whole new set of problems that are quite consistent with what many businesses take issue with with cloud technology: security. Do the pros outweigh the cons or vice versa? This much isn’t clear yet but what is evident is that more cloud apps are going mobile.

Efficiency, Innovation

While cost savings has always been one benefit that cloud proponents are quick to point out, its capability to improve and streamline business processes, thereby increasing efficiency and agility within the organization, is another key opportunity that the cloud offers. This is evident when you take a look at the most commonly used cloud services: backup and archiving, business continuity, collaboration tools, and big data processing.

Moreover, the cloud is making it easier for individuals to create new products and produce new lines of business. With access to higher IT capacity at lesser cost and at faster deployment rates, businesses can scale into more innovation without having to worry about the availability of computing resources.

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Symbion Pharmacy Services? Definition of Responsibility

A ?symbion? is an organism in a symbiotic (i.e. mutually beneficial) relationship with another one. In the case of Australia?s giant Symbion Pharmacy Services, this means supplying and delivering over-counter Chemmart medicines to more than 3,000 hospital and retail pharmacies, while remaining mindful of its carbon footprint.

In 1999, the company with the tagline ?life matters? and a desire to be seen as ?a good corporate citizen? decided it was time to measure exactly what it was pumping out from 12 facilities and over 200 vehicles. This was a voluntary decision as even now there is still no carbon emissions law in Australia (although no doubt being a ?first mover? will put the company in a competitive position when this inevitably comes).

Symbion decided to install emission detection devices and connect these to a central monitoring system with the intention of managing what these measured. There were two stages to this process. First, Symbion determined its reporting requirements based on one of its larger warehouses. Following that, it established a carbon footprint for each of its wholly owned and managed facilities. This put it in a position to:

  • Analyse total emissions down to a level of detail where it understood the contribution of each source
  • Use big data management tools to identify carbon hotspots for priority remedial action
  • Inform the affected workforce, explain the monitoring system and keep them in the loop
  • Separately manage energy abatement programs such as lighting and delivery routes

The program also had productivity spin-offs in that it focused management attention on the processes behind the emissions that were ripe for material and system improvements. It also provided marketing leverage. Symbion?s customers are in the wellness business, ahead of the curve when it comes to how emissions contribute to chronic illness, and aware of the cost of this in terms of human capital.

EcoVaro could help you manage your throughputs by analysing your data on our cloud-based system. This includes trending your metrics, comparing them to your industry seasonal average, and providing you with a business-like view of how well you are doing.

Our service reduces your reliance on (and the cost of) third party audits, and simplifies the reporting process to your controlling authority. It simply makes more sense to contract your software out this way, and only pay for it when you need it.

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