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RSCA Tracking

trackingTools and Manual Tracking

As I mentioned in the RSCA Methodology overview, there are many tools on the market to help you perform tracking and reporting for regulatory compliance. I strongly suggest you invest in one of these tools and share it with your Internal Audit, SOx Audit and IT Compliance organizations. Having a single source for your tracking and reporting needs saves a great deal of time, and will cut down on the miscommunications between these organizations.

Most audit software companies have tools that will track all these data types and more. They also provide multi-user authenticated signon where project leaders and managers who own actions plans can update their the status of their assigned remediation items directly.

If however, your organization simply cannot afford these tools, you can perform the tracking and reporting through a manual process using MS Excel spreadsheets. If that’s the method you chose, there are specific data types to keep track of. Continue reading

The RSCA Process

processProcess Documentation

The Risk, Security & Compliance Assessment (RSCA) approach is used to evaluate the current state of security and compliance activities for SOx remediation initiatives. RSCA is a three-step methodology that covers Planning and Data Collection, Risk and Security Assessment, and Tracking and Reporting.

Each organization has their own Audit process to define the scope of an audit, the methodology for implementing that audit and how findings are reported. When findings fall into the realm of GRC, they should be handed off to a RSCA team for tracking and oversight for remediation.

See my IT Governance section for more information about IT Audit, and Governance, Risk Management & Compliance (GRC) and Risk, Security & Compliance Assessments (RSCA).
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RSCA Methodology

riskRisk, Security & Compliance Assessments

The RSCA approach is used to evaluate the current state of Security and Compliance activities for SOx remediation within a business. RSCA is a three-step methodology designed to manage and provide oversight for business risk and compliance. But keep in mind that neither SOx nor RSCA are designed to eliminate all risk. They are designed to ensure risks are known and either corrected or accepted.

To that end, RSCA addresses your companies governance through:

  1. Planning and Data Collection
  2. Risk and Security Assessment
  3. Tracking and Reporting

These steps have been implemented at many large corporations facing large remediation initiatives. But it’s a method that can be easily scaled to any size business. These steps help to ensure both your business and IT processes are being adhered to, identifies gaps or risks that need to be resolved, tracks those resolution efforts and provides a method of reporting through each chain of command necessary for Governance, Risk Management and Compliance (GRC) Assessments.

See my IT Governance section for more information about IT Audit, and Governance, Risk Management & Compliance (GRC) and Risk, Security & Compliance Assessments (RSCA).

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Segregation Of Duties

sodRoles & Responsibilities

Segregation of Duties (SOD) is one of the biggest issues to hit IT organizations. Especially for those that have been in business for 40 years or more. Companies typically start out with open environments that relied on developers to implement new code straight into production. Many organizations have no change management or change control tools to help strengthen and secure their development, testing, implementation into production and subsequent maintenance changes and emergency fix processes.

Compliance initiatives have done away with the same ole procedures and now require organizations to maintain stronger and more restrictive control over their IT environments. Those that don’t make efforts for control, end up with significant deficiencies called out by their auditors. Continue reading

Management Attestations

signatureAttesting To Compliance

An Attestation is management’s internal assessment and compliance with regulatory compliance certifications. These letters are also known as Compliance Certifications, GRC Agreements and the list goes on.

Typically only the CEO and CFO are required by law to sign an attestation. But more and more corporations are including the CIO in that requirement. Primarily because IT now plays such a critical role in ensuring the corporations data is secured and properly managed to retain reliable accounting systems.

Many CIOs become very uncomfortable in signing a corporate level attestation for their organization. How does the CIO know for sure that his direct staff is properly overseeing the IT components they manage? And how do those senior IT executives know that their directors and managers are giving proper attention and accountability to the processes they manage?

Because of this, many IT organizations are implementing an IT management wide Attestation to their compliance standards. From the lowest manager up, these attestations define the responsibility of each manager to adhere to corporate standards and compliance regulations. Each one roles up into a package for the next level manager to review and certify by signing their own attestation. Until finally, all of IT’s management has attested to the oversight of controls. And the CIO now feels like his/her back is covered.

See my IT Governance section for more information about IT Audit, and Governance, Risk Management & Compliance (GRC) and Risk, Security & Compliance Assessments (RSCA).

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Implementing GRC In IT

sox404IT Governance

All IT organizations need to implement some type of Governance, Risk Management and Compliance (GRC) in their environment. No matter how big or small your organization might be, if your company has 1 password for something, you need oversight.

Oversight of risk has long been a best practice for any company that wants to remain competitive. A controlled environment provides an organization with stream lined processes, reusable procedures, better functioning systems, and typically under budget of expected costs.

This isn’t just some thing to do in order to meet federal, state or industry regulations. It’s about doing being a reliable business partner, a reputable company and an organization that can be trusted with integrity. All the things any size business needs to get an advantage in their local market.

See my IT Governance section for more information about IT Audit, and Governance, Risk Management & Compliance (GRC) and Risk, Security & Compliance Assessments (RSCA).

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