Why Spreadsheets can send the Pillars of Solvency II Crashing Down


Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?

Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.

A little background about spreadsheets might help.

Who needs an IT solution when you can have spreadsheets?

Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?

You probably haven’t heard of spreadsheet hell

Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.

And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.

Solvency II Impact on Spreadsheet-based Financial and IT Systems

Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.

The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.

There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.

A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.

Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.

Because of spreadsheets you now need an IT solution

It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.

One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.

More Spreadsheet Blogs


Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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Quality Assurance

 

There is a truism that goes “The bitterness of poor quality is remembered long after the sweetness of low price has faded from memory”.

While every consumer can probably relate to this idea, business enterprises offering goods and services are the ones that should heed this the most.

Quality Management Systems

The concept of quality was first introduced in the 1800’s. Goods were then still mass-produced, created by the same set of people, with a few individuals assigned to do some “tweaking” on the product to bring it to acceptable levels. Their idea of quality at that time may not have been that well-defined, but it marked the beginnings of product quality and customer satisfaction as we know it now.

Since then, quality has developed into a very basic business principle that every organisation should strive to achieve. Yet while every business recognises the importance of offering product and service quality, it is not something that can be achieved overnight.

If you’ve been in any type of business long enough, you should know that there is no “quick-fix” to achieving quality. Instead, it is an evolving process that needs to be continually worked on. And this is where the importance of having a workable Quality Management System (QMS) in an organisation comes in.

Whatever Quality tools and processes you need to implement the change needed in your organisation, we can help you with it. We are ready to work in partnership with your team to develop strategic systems which will produce significant performance improvements geared towards the achievement of quality.

What is a Quality Management System?

A Quality Management System is defined as the set of inter-related objectives, processes, and operating procedures that organisations use as a guide to help them implement quality policies and attain quality objectives.

Needless to say, the ultimate goal of every quality management system is to establish quality as a core value of the company among all employees, and across all products and services. Why? Because quality services make for happy customers, and satisfied customers ensure continued business for the company.

A Quality Management System does not stop with simply having a set of guidelines that the leaders of a company can easily have their organisation members accept and adhere to. Rather, effective QMS can be implemented when management provides a culture of pride and patience, which will inspire acceptance of individual and group responsibility.

In this manner, not only the heads of the organisation but the employees as well, will develop the desire to achieve company goals that will benefit:

  • All contributing teams;
  • The customers; and
  • The company as a whole.

Find out more about our Quality Assurance services in the following pages:

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.

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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