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instant messaging or work suites that include meetings, voice, multimedia, and so on; and internal and external means of information transmission such as XBRL IT will also have to work with the compliance focus as it works with the business processes in certifying compliance with outside standards IT will be a leading force in the integration of financial processes and internal control and their monitoring and reporting By working together with internal controls, IT can provide the technology for control monitoring, testing, evaluation, reporting, and documentation In order to move from a project mentality to a process approach, IT may want to consider developing applications that use analytics and continuous monitoring systems There will be times when the demands of compliance will not fit with the needs of any particular business process E-mail is a good example For business process purposes, a good e-mail system is one that transmits messages reliably and maybe ties in with some collaborative functions such as personal calendars Compliance requires the archiving of e-mail messages This function does not pertain to any business process, yet it is a need that the IT area must address Another example is an electronic archival system that is needed for compliance purposes Although not a requirement for many business processes, once this archiving system has been installed and implemented, it may be found to provide a definite benefit for many of the processes; thus, it becomes a matter of good governance to require that level of control especially if it is done right If IT is considered an enabling tool, it can be used to reduce costs, complexities, and even risk When evaluating the IT area as a closed system for compliance purposes, the IT area may want to consider using standard maturity models such as Capability Maturity Model Integrated (CMMI) This is part of Carnegie Mellon s Software Engineering Institute (SEI) and focuses on process improvements It deals with the various development and delivery life cycles (product life cycles, project life cycles, etc) that many IT groups already use These complement the Sarbanes-Oxley requirements of project management, requirements management, metrics, quality, and configuration management IT needs to work with the risk management focus again for the IT technology and applications used throughout the organization and also for itself Often when a risk is identified, it can be controlled
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through IT applications before it becomes a reality, or it can be monitored and reported after it crosses a predetermined threshold One of the biggest risk scenarios that risk management will face will be the IT practices relating to a disaster recovery plan and/or business continuity The risks of having to relocate the physical IT sites, or of using backup systems, either hot (already up and running) or cold (having to be configured and set up before use); the risks of having the necessary operators at these other sites; and the need for the network to be duplicated from these other sites, with all the security measures intact, is daunting, to say the least Nevertheless, incidents such as 9/11 and natural disasters such as hurricanes have shown that these risks are real and must be addressed, no matter how daunting or complex they are Another model is the Information Technology Infrastructure Library (ITIL), which has become popular in Europe and is becoming increasingly popular in the United States ITIL is an integrated set of best practices with common definitions and terminology ITIL covers areas such as change management, release management, problem management, and incident management ITIL divides IT services into two domains: service support and service delivery Service support includes the best practices of those disciplines that enable IT services to be provided effectively and efficiently Service delivery refers to the management of the IT services themselves It includes a number of management best practices to ensure that IT services are actually provided according to the agreement between the IT provider and the customer stakeholder One of the more popular models for IT compliance is the CobiT/COSO cube CobiT (Control Objectives for Information and related Technology) is an accepted reference tool dealing with IT controls The CobiT framework, which deals primarily with IT, is used widely by IT management and internal and external auditors The tool is published jointly by the IT Governance Institute (ITGI) and the Information Systems Audit and Control Association (ISACA) CobiT defines 34 high-level IT control objectives For an overview of CobiT, see Appendix E and F The COSO Framework is explicitly recommended for SarbanesOxley compliance by both the Public Company Accounting Oversight Board (PCAOB) and the SEC COSO s framework consists of five components, and requires competency in all five areas to achieve
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