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  IT Asset Management - Sarbanes-Oxley Act


Sarbanes-Oxley Act - Impact on IT Assets

As previously stated, due to many corporate failures Risk Management has become a necessity in Corporate compliance. Sarbannes-Oxley legislation specific addresses the need for better control of assets and accounting systems. Sections 107 and 108 deal specific with Risk Assement and Prioritisation of Risk. By identifying and mitigating risks with 'best practice' IT Asset Management solutions, an organisation is able to demonstrate their willingness to comply with Sarbanes-Oxley legislative requirements.

Sarbanes-OxleySection 107 Risk Assessment Risk Assessment. .............risk assessment, is the process of identifying and analyzing both internal and external risks and threats to achieving an entity’s goals and objectives. Risk assessment can be performed either on the level of the whole enterprise or entity or on the level of a specific application or transaction. Processes for both enterprise-level and application-level risk assessment form the basis of determining how to manage risk. Some of these risks are:
  • Changes in operating environment
  • New technology
  • New or revamped information systems
  • New personnel
  • Rapid growth
  • New lines, products, or activities
  • Corporate restructurings
  • Foreign operations
  • Accounting pronouncements


The risk assessment component process itself can be expressed in terms of five key subcomponents. Each step in the risk assessment process can be linked to other related tasks and actions to form a consistent and repeatable evaluation methodology:
1.Determine control objectives
2. Prioritize requirements
3. Identify risks
4. Determine likelihood
5. Manage risk
Systems Model. For Sarbanes-Oxely, a risk assessment analysis should be performed within the context of the total operating environment. (Note: SEC rules regarding certification of periodic reports incorporate a broader standard than just financial reporting.) By evaluating entitywide and application-level risks in a systematic and linked manner, a complete and balanced measure of the control activities necessary to meet the entity’s control objectives can be developed. The following paragraphs illustrate a general layered model that can be used to describe an overall systems environment. Assurance Methodology, provides a more comprehensive discussion of the concepts covered here.
The basic elements of this model typically include: Entity-Level Risk Assessment
  • Strategic risks
Application-Level Risk Assessment
  • Business/transaction services (Inbound and Outbound)
Determine Control Objectives. Control objectives form the specific entitywide or application-level goals the entity wishes to achieve. Some common control objectives for an information-system environment may include:
  • Adequate business planning and sufficient needs analysis
  • Systems confidentiality and transaction integrity
  • Information availability and authenticity
  • Accurate, valid, authorized, and timely transaction processing
  • Correct implementation and integration
  • Sufficient end-user support and training
  • Adequate systems and data protection

Section 108 Prioritize Prioritize Requirements. In order to perform an overall risk assessment, specific assets or processes should be prioritized in terms of their criticality to the enterprise. To help identify which assets are most important and need to be protected and safeguarded, the entity can rank assets on the basis of their significance to the core requirements it needs to meet. Using this methodology, assets can be ordered into two general groups:
  • Tangibles— property, plant equipment - computer systems, applications, and data
  • Intangibles—business reputation, continuity, and quality of service or products
Identify Risks. After ranking and prioritizing important assets that need to be protected and safeguarded, specific threats to those assets can be identified. To understand and assess the significance of the various risk factors, the entity can evaluate risk factors by determining what can go wrong, what the weaknesses are, and how vulnerable it is to them. Risks and threats can be grouped into three general categories:
  • Internal and external threats
  • Authorized and unauthorized actions
  • Intentional and unintentional (mistaken) activities
Determine Likelihood. After identifying all of the major risks that represent the greatest threats to the most valuable assets of the enterprise, the entity should estimate the likelihood of these risks occurring. This process can be determined by establishing a basis to estimate the frequency, magnitude, and duration of the threats on three different levels:
  • Aggregate level—cumulative effect
  • Transaction level—individual effect
  • System level—environmental effect
Manage Risk. Once a decision matrix has been created that identifies and links the various control objectives, asset prioritization rankings, potential risks and threats, and likelihood of occurrence, a risk management decision can be made in the context of balancing each of these elements with the others.
Both quantitative and qualitative risk management decisions can be supported using a value-based approach, as opposed to a “weak link” model, to measure when a threshold limit has been reached. An economic value method identifies specific assets or processes that are considered important to the entity, and then directs resources towards protecting those critical areas. It recognizes that while other types of security threats may exist (i.e., weak links), if they do not pose a significant risk or can be controlled through other means, they will receive less attention than priority areas. In general, there are three basic types of risk management decisions, of which only one considers what action should be taken to reduce or mitigate the risk:
  • Accept or ignore risk
  • Transfer risk (to insurance carriers, etc.)
  • Reduce or mitigate risk:
~ Measure and manage—institute and monitor a logical, systematic, traceable, and repeatable process ~ Teach and train—develop awareness and skills~ Reduce—take action and safeguard; determine what combination is the most effective
 
   
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