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the networks that contain the information the user needs, and not allowing access to other parts of the corporate network, user access to information is controlled Access control requires enforced authentication for all users and applications, thereby ensuring the integrity of network authentication services Such a system means that unauthorized users including system administrators with super-user privileges cannot view financial information Within a database system, for example, one individual may be able to create tables and views, while another individual is given the ability to assign the permissions that enable individual users to execute queries If a company follows the ISO 17799 standards, no individual user should be able to access all of the IT systems involved in financial transactions, because knowledge of the full path of transactions through the system makes it easier for this knowledgeable person to commit fraud Separation of duties is an important requirement for corporate governance Some level of separation of duties should be mandatory at all companies, because self-monitoring introduces the possibility of no monitoring ISO 17799 is an excellent source for discovering what aspects of security should to be verified during a Sarbanes-Oxley audit Although many companies have achieved ISO 17799 certification, this may not be practical for other organizations; nevertheless, they should look to the ISO 17799 standard for guidance At a minimum, policies and procedures should be in place to address physical security, intrusion detection and prevention, error/incident logging, antivirus functions, remote access, configuration (eg, networks, servers, installation of new software), authentication/access controls, and regular vulnerability assessment
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Storage, Disaster Recovery, and Continuity Planning Storage is the fundamental requirement for the safekeeping of all the data and documents of an enterprise (ie, enterprise information) Proper storage, and its management, security, and safety, are important issues Today, organizations are literally generating terabytes of data each week Combined with the requirement to store auditor-rel-
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evant documents (such as internal control documentation, internal audit documents, and so forth) safely for seven years, the company s storage requirements are expected to go up even further Given these conditions, choosing the right storage technology and architecture is important Hardware technologies such as RAID (redundant array of inexpensive disks) are much better than JBODs (just a bunch of disks), because RAID provides some fault tolerance at the disk level itself Choosing the architecture to use these in, such as a network attached storage (NAS) or a storage area network (SAN), is still very difficult, but it is expected that most organizations will have several NAS servers in place soon If the enterprise is very large and is looking at a long-term solution for its storage problems, SAN architecture might be the way to go Existing NAS devices, in which an investment has already been made, can be integrated into the SAN architecture Both these architectures are designed to ease the pressure on the network, as well as centralize the enterprise information Although NAS is a good solution at the workgroup or department level, SAN is the solution for long-term, enterprise-level storage requirements Again, Sarbanes-Oxley contains no direct requirement to install SAN or NAS, but the acquisition of these will be essential because the information retention dictated by Sarbanes-Oxley sections definitely requires large amounts of storage capacity Further, the requirements of internal controls and real-time notification of material events dictate storage systems from which data can be retrieved and processed efficiently Disaster recovery is important because a company must prove that all appropriate documents have been retained and are available to investigating agencies; hence, disaster recovery is part of what safeguards the organization against Section 802 violations Further, a disaster recovery policy shows that several potential material events have already been considered and taken care of The bottom line is that all documents must be kept safe for the required seven-year period and for any agency investigations that might need them Business continuity planning will be more important from an operational viewpoint than from a Sarbanes-Oxley requirements perspective Nevertheless, it makes good business sense to do the proper planning and have a policy or procedure in place
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