How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Excel Spreadsheet Conversion to SQL Reports

Spreadsheets are flexible, inexpensive and easy to use. They are especially handy when it comes to beating report submission deadlines or making impromptu data computations.

Unfortunately, organisations heavy reliance on spreadsheets have made these User Developed Applications (UDA) into high-risk office tools. Simple spreadsheet errors like leaving out a negative sign or a cut-and-paste mistake have already caused million-dollar discrepancies. Also, when a fraudulent employee enters into the picture, the risks become unimaginable.
Think TransAlta’s spreadsheet cut-and-paste glitch (the company later called this a ‘simple clerical error’) which caused the energy firm a whopping $24 million loss or Fidelity’s overstatement of its earnings owing to the omission of the minus sign on the spreadsheet of a $1.3 billion net capital loss.

Denizon can convert your Excel Spreadsheets to a web based SQL Server Reporting Services (SSRS). It does not import Excel data, rather it allows the creation and deployment of reports in a more efficient manner by querying the data.

So what is the problem with Spreadsheets?

Plagued with risk issues and vulnerable to fraud
Lacking in control features especially when copied, edited and emailed between many users
A burden to regulation compliance e.g. SOX (Sarbanes-Oxley)

Moreover:

Accidental copy-paste/Omission of a negative sign/Erroneous range selection
Incorrect data input or unintentional deletion of a character, cell, range, column, or row
Possibility of the user working on the wrong version
Prone to inconsistent company-wide reporting
Often ‘defenceless’ against unauthorised access

See Top 10 Disadvantages of Spreadsheets

What makes SQL Server Reporting Services better than Spreadsheets?

Free from spreadsheet risks & equipped with built-in controls that substantially reduce risks to data
Less prone to fraud
More suitable for regulatory compliance e.g. SOX
Designed for an agile business environment

Automatic consolidation eliminates errors and wasted time caused by tedious copy-pasting of data and linking of cells
Better collaboration capabilities allows team members to bring their heads together for planning, budgeting, and reporting even while on the go
Mobility support enables users to input data or retrieve information through their wireless mobile device

Superior sharing features ensures that everyone is exactly on the same page and viewing real-time information
Dashboards provide insightful information at-a-glance through KPIs, graphs, and various metrics
Drill-downs enable users to investigate unusual figures and gain a better understanding of the details that contribute to the big picture
Easy to learn interfaces allow your organisation to cope with fast personnel turnaround or Mergers & Acquisitions

Don’t know how to shift from Spreadsheets to SQL Server Reporting Services?

We’ve got the knowledge and expertise to assist you in:

Making a smooth and cost-efficient transition from risky spreadsheets to reliable reports
Designing and implementing SOX-compliant report-generating methods and procedures
Putting exposure to high-risk reporting methods a thing of the past

Authentication and Access Control

Threats to your data can come from external or internal sources.

There are individuals who don’t have the authorisation but are driven by malicious intentions to gain access to certain information. This may refer to individuals who already belong to your organisation (but don’t have the necessary access rights) as well as those who don’t.
There are individuals who have both the authorisation and, unfortunately, the malicious intentions over certain information.
Finally, there are individuals who have the authorisation, no malicious intentions, but have accidentally exposed the information in question to those without the proper authority.

While curbing threats 2 and 3 would require other methods, threat #1 can be countered if the right authentication and access control systems are in place.

Here’s what we can do for you:

Work with your key personnel to determine who gets access to what.
Help you decide whether a single factor or a two-factor authentication (2FA) is appropriate for your organisation and recommend which factors are most suitable. Login methods may include but are not limited to the following:
- biometric devices
- Kerberos tickets
- mobile phones
- passwords
- PKI certificates
- proximity cards
- smart cards
- tokens
Install the necessary infrastructure needed for the factors chosen. For instance, if you opt to use biometrics, then biometric scanners will be installed. We’ll make sure that the authentication terminals are situated in places where achieving optimal traffic and work flow has been taken into consideration.

Other defences we’re capable of putting up include:

Will UK Retailers Skim the Cream with ESOS?

The British Retail Consortium (BRC) was quick out on the starting blocks with an ambitious plan to cut energy costs by 25% in 5 years. Their ?25-in-5? initiative is chasing a target of ?4.4 billion savings during the duration. Part of this program involves ?cutting a path through a complex and inaccessible policy landscape?. BRC believes this drawback is making its members think twice about making energy efficiency investments.

The UK?s sprawling network of grocers, department stores and malls is the nation?s second most hungry energy customer, having spent ?3.3 billion on it in 2013 when it accounted for almost 20% of carbon released. If you think that sounds bad, it purchased double that amount in 2005. However the consortium believes there is still more to come.

It bases this assumption on the push effect of UK energy rates increasing by a quarter during the duration of the project. ?So it makes sense to be investing in energy efficiency rather than paying bills,? Andrew Bolitho (property, energy, and transport policy adviser) told Business Green. The numbers mentioned exclude third party transport and distribution networks not under the British Retail Consortium umbrella.

The ?complex and inaccessible policy landscape? is the reflection of UK legislators not tidying up as they go along. BRC cites a ?vast number of policies ? spreading confusion, undermining investment and making it harder to raise capital?. The prime culprits are Britain?s CRC Energy Efficient Scheme (previously Carbon Reduction Commitment) which publishes league tables and ESOS. Andrew Bolitho believes this duality is driving confused investors away.

The British Retail Consortium is at pains to point out that this is not about watering things down, but making it simpler for participating companies to report on energy matters at a single point. It will soon go live with its own information hub providing information for retailers wishing to measure consumption at critical points, assemble the bigger picture and implement best practice.

Ecovaro agrees with Andrew Bolitho that lowering energy demand and cutting carbon is not just about technology. We can do much in terms of changing attitudes and providing refresher training and this does not have to cost that much. Studies have shown repeatedly that there is huge benefit in inviting employees to cross over to our side. In fact, they may already be on board to an extent that may surprise.