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and-effect relations throughout the enterprise value chain This will help improve internal controls for compliance:
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Section 404 In the hands of a good forensic accountant, data mining can be a useful tool for internal auditing of the internal controls It can reveal whether someone has tampered with the data, using the frequencies of real data Section 409 Data mining can also potentially alert the enterprise by detecting unforeseen patterns, such as any material events that might already have taken place or be in the offing
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ENDNOTES
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1 http://wwwfederalreservegov/boarddocs/hh/2001/february/testi monyhtm (accessed 11/28/05) 2 See J Woods, A White, K Peterson, and M Jimenez, Demand Chain Management Synchronizes CRM and SCM (Gartner Research Note, October 28, 2002); Simon Pollard, Count the Money when Sales and Marketing Work with Logistics (AMR Research, October 2001) 3 http://wwweconomistcom/surveys/displayStorycfm Story_id= 949105 Hau Lee, Ultimate Enterprise Value Creation Using Demand-Based Management (Stanford Global Supply Chain Management Forum, September 2001) 4 Cap Gemini Ernst & Young, CFOs: Driving Finance Transformation for the 21st Century, http://wwwcacgeycom/knowledge_ centre/insights/findrivingfinancetransformationpdf 5 D Freeman, How to Make Spreadsheets Error-Proof, Journal of Accountancy 181, no 5 (1996): 75 77; KPMG Management Consulting, Supporting the Decision Maker: A Guide to the Value of Business Modeling, press release, July 30, 1998, http://wwwkpmgcouk/uk/services/manage/press/970605ahtml 6 PricewaterhouseCoopers, Global Data Management Survey 2001
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CHAPTER
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ccording to some estimates, more than 70 percent of the documents owned by an enterprise are in digital format and might never be seen in hard copy Enterprise information management, or document management, is perhaps one of the most important of the enterprise technologies that will provide a solution to the various requirements of Sarbanes-Oxley Without proper systems for managing the information held within the company, compliance with Sarbanes-Oxley will be very difficult This chapter presents the various Sarbanes-Oxley provisions and regulations that relate directly to effective document management
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Several sections of Sarbanes-Oxley have a direct bearing on the manner in which the digital documents or records of the enterprise are created, reviewed, approved, stored, retrieved, transferred, and destroyed According to Gartner, records management will become a top 10 issue for many CIOs in the coming years1 On the following pages, we discuss the particular sections of Sarbanes-Oxley for which a document management solution might help with compliance Section 302 According to Section 302, the CEO and CFO have to personally certify the financial statements and disclosures made by the company,
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vouching for their authenticity and accuracy This requires a system to be in place that will make the CEO and the CFO confident that all the disclosures the company makes are in fact accurate and authentic This can be done in two ways: 1 First is to trickle down the responsibility of the CEO and the CFO to the lower management levels, and in response bubble up the signoffs from lower management on all data and documents that become part of the company filings 2 Second is to design comprehensive business processes that produce the company filings The business processes must be designed in a very rigorous manner to comply with all the Sarbanes-Oxley provisions, and proper implementation and training of all personnel involving the business processes should initially be done thoroughly and tested thereafter on a periodic basis Further, the business processes themselves should be open to the stringent internal audits that will be carried out from time to time A combination of both of these methods will go a long way toward ensuring compliance For both these options, it is clear that a strong, enterprise-wide document management system is needed as the foundation on which the compliance measures will actually be carried out In the first case, the signoffs can be configured using a workflow module of the document management system (DMS) In the second case, the business process itself is configured in the DMS and all the relevant supporting or input documents are part of the DMS as well; this makes it easy to do the appropriate subordination and linking between the official company filings and the documents in the DMS As proof of the records supporting the final company financials, as filed or reported, it is important to archive all e-mails, spreadsheets, instant messages, and other communications and documents that were exchanged that led to a final certified filing by the CEO and CFO This will safeguard the executives claims that all the financial reports are true to their knowledge and that due diligence was carried out before they certified the reports
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