Compliance School

Step 3: Establishing an IT Control Framework

As we mentioned, COSO is the de facto internal control framework associated with Sarbanes-Oxley. Therefore, COBIT is a natural choice for the IT Control Framework. The COBIT Framework is a set of 34 high-level control objectives organized into the four areas described in the financial and technical standards section.

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The diagram above shows the 34 high-level control objectives and their relationship to the four areas. While a majority of the controls have elements that are important in SOX compliance, a number of the high-level objectives stand out.

In the area of Planning and Organization:

  • Determine the information architecture
  • Define the IT organization and relationships
  • Ensure compliance with external requirements
  • Assess risks
Virtually all of the elements of Acquisition and Implementation:
  • Acquire and maintain application software
  • Acquire and maintain technology infrastructure
  • Develop and maintain procedures
  • Install and accredit systems
  • Manage changes
Many of the elements of Delivery and Support:
  • Ensure systems security
  • Educate and train users
  • Manage the configuration
  • Manage problems and incidents
  • Manage data
  • Manage facilities
  • Manage operations
And all of the elements associated with Monitoring:
  • Monitor the processes
  • Assess internal control adequacy
  • Obtain independent assurance
  • Provide for independent audit
Using these objectives, COBIT recommends organizations follow a plan, do, check, correct cycle. This philosophy, if followed, will help to improve the effectiveness of IT operations and, at the same time, help an organization achieve SOX compliance.

Home: Introduction
Step 1: Understanding compliance -- Financial and technical standards
Step 2: Scope of compliance
Step 3: Establishing an IT Control Framework
Step 4: Detailed objectives and policies
Step 5: Measuring compliance
Step 6: Managing and tracking compliance
Step 7: The changing nature of compliance

This was first published in February 2006

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