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What is it?
Commonly called SOX or Sarbox, the Sarbanes-Oxley Act of 2002
establishes enhanced standards for all US public company boards, management and
public accounting firms. The Act contains 11 titles with two key
provisions:
SOX Section 302: Internal Control
Certification
Section 302 mandates a set of internal procedures designed to
ensure accurate financial disclosure.
SOX Section 404: Assessment of Internal
Control
Section 404 requires management and external auditor to report
on the adequacy of the company's internal control over financial reporting.
This is the most costly and resource consuming part.
Impact of Section 404 on IT
Information technology controls that address financial risks are
within the scope of Section 404 assessment. CIOs are typically responsible for
the IT organization and IT personnel involved. The SEC identifies COSO as the
framework for achieving compliance and defines 5 components of internal control,
which help support the requirements set forth in the Sarbanes Oxley legislation,
as follow:
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Control Environment - A control
environment sets the tone and influence the control consciousness of its
people, providing discipline and structure. Factors in the control includes
but not limit to integrity, ethical values, competence, management
philosophy, segregation of authority and responsibility, development, and
operation style.
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Control Activities - Policies
and procedures must be in place to manage directives carried out and
activities occur throughout the organization, such as approvals,
authorizations, verifications, reconciliations, reviews of operating
performance, and security of assets.
In an IT environment, control activities include general
controls, e.g. program changes, access to programs or computer operations,
and application controls.
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Monitoring - Auditing processes
and schedules should be developed to address high-risk areas within the IT
organization. IT personnel must perform frequent internal audits, including
personnel outside of the organization. Management is held responsible for
the understanding and outcome of these audits.
Compliance Solution
Any compliance solution must help the IT organization address these
measurements within SOX:
- DS5.4 Users account management
- DS5.6 Security incident definition
- DS5.11 Exchange of sensitive data
- ME 1.4 Performance assessment
- ME 1.5 Board and Executive reporting
Such solution must be able to provide a complete historical trail with data
values from the past resulting from every read, update, change, delete and
accessed transaction, including those from privileged users.
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