SOX Plus Five: Compliance Matures
It’s now been several years since the most significant compliance mandates swept through U.S.-based businesses, up-ending long baked-in routines and causing untold numbers of sleepless nights.
The 800-pound gorilla of mandates, Sarbanes-Oxley, is marking its fifth year of existence, and it’s been eight years since the Financial Modernization Act (Gramm-Leach-Bliley) arrived. It’s been more than 11 years since the Health Insurance Portability and Accountability Act (HIPAA) was passed and put into action. Most organizations and the auditors charged with policing these mandates have had some time and experience, then, to develop or recognize best practices in data management, security, and accountability.
Probably the most potent response to date has been evolving under the banner of governance, risk and compliance (GRC) management. With GRC, these distinct categories are taken together as one, with the goal of transforming burdensome information sharing and reporting processes. Effective compliance with regulations such as SarbanesOxley requires a governance structure that incorporates input from various parts of the enterprise, with the ability to recognize the risks inherent in failing to establish proper controls over information that is reported.
Governance, Risk and Compliance
Awareness of GRC runs high, a recent survey 392 members of the Oracle Applications Users Group (OAUG), in partnership with Unisphere Research and LogicalApps, found. GRC has particularly gained traction among larger firms, in which many are working proactively to improve the effectiveness of their compliance management and risk mitigation efforts.
Information technology and data management play a critical role in this process, the survey also confirmed. Four out of 10 companies reported making headway with automating and providing continuous monitoring of their internal controls environments, but there is still much work to be done. Only a handful, 15 percent, said that the majority of their critical processes are automated, meaning their internal controls environments are well-documented and continuously and automatically enforced to the point where violations are immediately caught and remedied. Another 42 percent said that while they have well- documented controls environments, these controls are subject to regular evaluations, with ensuing remediation cycles to address whatever issues may be identified. Another 30 percent said controls and enforcement are erratic at best.
Lately, there’s been a change in thinking and tactics as to what, exactly, needs to have such controls. In the early days of the compliance era, companies tended to focus on application- level controls. However, after attempts to police access to potentially hundreds of different applications, many companies recognized that they needed to drill down to a more fundamental level – to the database itself. “People have gotten over the initial hump of looking at internal controls at the application level; now there’s a broader view that the foundation of compliance needs to address the data repositories that contain the application data,” Harald Collet, director of risk assurance solutions at Oracle, told DBTA. “There was this false sense of security that this was taken care of in the database environment. Now, internal auditors are finding deficiencies in the data management processes.”
The ability to manage user access, protect data and monitor transactions is key to compliance efforts. Technology needs to be employed to better automate compliance processes, as well as enforce controls. GRC is “much broader than Sarbanes-Oxley. SOX has created an environment where people start to evaluate risks much more rigorously within their company,” said Collet. “Customers are starting to get hold of their internal controls process, and are starting to look at all their controls.”
Trust but Verify
Other industry observers agree that there has been a shift in auditing from applications to databases themselves. “The impact of compliance mandates on the area of database auditing has been significant – where there was none, now the effort to monitor and manage user activity on the database is real,” Murray Mazer, co-founder and vice president of Lumigent Technologies, told DBTA. “Previously, most organizations did not have auditing controls in place that allowed them to validate the actions of privileged users. Many organizations employed a ‘trust my users’ approach when really a ‘trust but verify’ approach was required.”
Such was the challenge at Coldwater Creek, which needed to provide database access to a widely fluctuating seasonal workforce. “The first kind of compliance challenge ends up being, how do you manage requests for user accounts, and how do you authorize access and things of that nature?” Michael Carper, vice president of technology operations for Coldwater Creek, said in an interview with DBTA. “Although we do have a formal process for requesting user accounts, it’s not automated, so it’s prone to human error. We’re going to be tightening that fairly soon, but that’s been kind of a challenge.” Carper said that this is especially important to Coldwater Creek, since its staff size can double during the fourth quarter to handle holiday sales.
To a large degree, mandates such as Sarbanes-Oxley have benefited companies in ways beyond simply meeting the letter of the law. Effective governance, in which professionals from various functions are brought together through oversight committees, regular meetings, and project initiatives not only serve to better plan and manage compliance activities, but also build more bridges between formerly siloed departments.
“SOX forced everybody to follow procedure,” remarked Arup Nanda, director of database engineering and architecture for Starwood Hotels & Resorts Worldwide, which maintains more than 500 Oracle 10g databases at sites across the globe. “Three years ago, we had no single data management strategy,” he told DBTA. “Each business area or functional area had their own database or their own DBA staff, or application DBAs. With SOX, we combined them into a single DBA group and architecture group to develop a single strategy and a single data model. I also got budget to buy additional hardware, and hire additional bodies. Our organization as a whole benefited from SOX.”
Phil Neray, vice president at Guardium, noted that “ SOX gave organizations the board-level visibility and IT budgets – they needed to implement best practices controls around corporate financial data, such as implementing real-time security and automated monitoring of privileged users to prevent unauthorized changes.” Such standards and controls are being extended to other areas where sensitive data is managed, he told DBTA.
Where’s the Data?
The first step in this engagement is to develop a data map to pinpoint where the most sensitive business data resides, Collet explained. “Where does it sit? What repositories contain this data? Then they start looking at what kinds of preventive controls, and what kinds of detective controls can they put in place on those data repositories. That means, for example, making sure you can prevent DBAs and super users from modifying critical data, implementing separation of duties for administrators and detect inappropriate behavior.”
“Compliance mandates can be divided into two parts: the ‘do this’ part and the ‘or else’ part,” Jim Doherty, chief marketing officer of CipherOptics, told DBTA. “The ‘or else’ part changes based on regulation and industry, and over time, has become more and more demanding. However, the ‘do this’ part is pretty consistent across all regulations and industries: control your data. Make sure that the only people who see your data are the ones who are supposed to see it. If you can control your data end to end then you will be compliant.”
Less Firefighting
Coldwater Creek is rolling out BMC’s Identity Management Suite as a means to automate account management, and therefore address SOX-related compliance requirements. “Our goal is to spend less time on unplanned work, or firefighting,” said Carper. “If we spend so much time firefighting, we’re absolutely not able to build a new development environment for SAP or other development or business projects.”
Automation will reduce this firefighting, especially when it comes to compliance, Carper continued. “Maintaining our position with regards to compliance and being able to get through an audit cleanly and quickly decreases the amount of unplanned work that we do, and therefore gives us more time to be working on more innovative projects for the business.” Carper noted that over the summer, “we will roll out BMC’s identity management suite, concurrent with our implementation of SAP for HR and finance. With the implementation of those products, we will completely have automated the tasks that in the first quarter took up 70 percent of one person’s time.”
The Unisphere Research-OAUG survey found that on a monthly basis, most organizations commit 30 hours or more in documenting, testing, or reporting on internal controls. At least 18 percent reported that they commit at least half a week (20 hours) or more in staff time for the effort. Another 15 percent reported spending 10 to 20 hours of staff time each month. Another 29 percent said they simply did not know what type of time investment was involved.
“People are still using the same tools to manage the data itself, but they’ve gotten smarter about how they manage the audit data,” said Neray. “Instead of manually examining reams of traditional log data, many are leveraging automation and data mining techniques to identify unauthorized or suspicious access to sensitive databases. People are also more aware of data governance issues such as ‘Where is my sensitive data stored?’ and are looking for tools that can help them find sensitive data in their environments, especially after mergers and acquisitions or if they’re still using legacy systems.”
Hundreds of Repositories
Ultimately, GRC and compliance automation helps systemize compliance management while reducing the complexity built up over the years in many companies’ systems.
“For you to put proper internal controls in place that are not manual, it forces you to take a view on your systems,” said Collet. “You need to look at how you can streamline. You might ask, ‘Why do I have 25 different content repositories? Why do I have 10 different business identities? Why do I have hundreds and hundreds of data repositories? Can I consolidate, can I take all that and have a single source of truth?’ That in itself, weeding complexity out of the IT systems, means that less of your IT budget is going to be tied up in non-discretionary spending. You’ll have more discretionary spending to make the IT department more agile, so you can effect more change with the same budget.”
Automation of compliance reporting through GRC management represents a great untapped opportunity. For Coldwater Creek, such efforts represent the beginning of new opportunities, Carper said. “With the kind of automation we’ll be doing, we won’t spend so much time on unplanned or mundane work. We’ll be spending more time on innovation.”