How to Reduce Costs when Complying with SOX 404

Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.

Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.

SOX 404 in a nutshell

Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.

This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.

Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.

Why compliance of Section 404 is costly

Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.

Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.

According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.

The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.

Read why spreadsheets post a burden when complying with SOX and other regulations.

Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.

Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:

  • Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
  • Companies with revenues between $1B – $4.9B spent about 0.16%
  • Companies with revenues between $500M – $999M spent about 0.27%
  • Companies with revenues between $100M – $499M spent about 0.53%
  • Companies with revenues less than $100M spent a whopping 2.55% on Section 404

Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.

How to alleviate costs of section 404

If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.

Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?

From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.

For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?

It’s really not a trivial problem.

Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.

Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.

For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

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Computer Forensics

So you had a customer data security breach last weekend? Do you know you could be held liable in court for failing to implement required security procedures? That’s right. Due to the overwhelming surge in identity theft wherein nearly 20 million Americans have already been affected, most states have enacted laws to curtail this fast rising crime. Therefore, it is important to redefine how your company deals with customer data security.

  • First, you’ll want to know what your obligations are as dictated by law. Some places, for example, require the destruction or deletion of personal data through shredding, erasing, or by rendering them undecipherable.
  • Second, not only do you need to comply with the said requirements, you’ll also have to prove in court that you actually complied if ever a security breach does happen.
  • Third, you need to be aware of your post-breach duties to avoid being dealt additional penalties.

Obviously, such situations now call for individuals who are experts in both the legal and technical aspects regarding data security. Such individuals are practitioners of a relatively new discipline known as computer forensics.

Armed with our computer forensics specialists, we’ll be able to help you deal with the above concerns. As a result, you can be prevented from having to pay fines that can go up to hundreds of thousands of euros.

There are other equally important reasons why you would want to avail of computer forensics services. For example, you’ll need computer forensics specialists because you want to:

  • Catch a person involved in criminal activities such as child porn, stealing of personal data, and destroying intellectual property.
  • Investigate a computer, network, or even a mobile device for clues that may lead to the culprit.
  • Determine the extent and possible causes when you discover your digital data has been damaged.
  • Find and recover damaged, deleted or encrypted data regardless of whether the cause was intentional or not. If the data in question will be used as evidence in a legal action, there are certain procedures that need to be followed during recovery operations to retain the integrity of the data. Computer forensic specialists are highly qualified for such operations.
  • Implement security policies in your organisation. Such policies have to operate within legal bounds if you want to avoid possible sanctions in the future. These policies should also be designed such that future forensic operations can be conducted with a high likelihood of success.

That said, a company that integrates computer forensics into its IT security policies and practices will be better equipped to remedy the situation once data security has already been compromised than a company that doesn’t.

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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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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.

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