Posted February 15th, 2008
My friend Mark MacAuley can always be counted on to stir things up. He’s seen plenty of enterprise deployments and architectures and comes at problems with a combination of Yankee ingenuity and healthy cynicism. Over on Identitystuff, Mark writes about offering Compliance as a service:
The new frontier is CaaS – Compliance as a Service. Fixed cost, consistent automated reporting, a defensible model for implementing and showing transparency.
Although the intent of Compliance is good, in Mark’s estimation Compliance is 100% cost with no positive yield to the bottom line.
The trouble is that Mark refers to Compliance as if it is an IT service that can be delivered like outsourced help desk or security management. Compliance, the Big “C,” cannot be delivered as a service. The Big “C” is the interplay between people, processes, and IT systems to achieve the mission of the business in the context of regulatory and market pressures. It isn’t binary; it isn’t something you have one day and not the next. This dynamic interplay requires continuous measurement and feedback loops to ensure that deviations are corrected and, ideally, prevented.
Compliance is a matter of controls – instituting a variety of controls and then charting the business’ distance in relation to those controls at all times. Let’s take a simple common non-business example. When a cop pulls you over for speeding, you often get asked two questions: Continue reading "Why Compliance Cannot be Delivered as a Service"...
- Did you see that speed limit sign?
- Do you know how fast you were going?
Posted October 17th, 2007
Lori Rowland has posted an examination of the state of market given Oracle’s acquisition of LogicalApps. Her analysis of the impact of this acquisition to us independent controls management companies mirrors some of my thoughts on the matter. There was one thing that caught my eye. Lori writes:
There are obvious benefits to implementing Oracle and SAP’s controls management solutions to manage the respective environments. Who knows SAP SOD policies or sensitive transactions better than SAP, right?
Maybe not. I posit that the audit community (both internal and external auditors) have a better sense for what constitutes an SoD violation in their business context than ERP vendors do. Clearly, the ERP vendors know, from a functional stand-point, what each transaction and function does in their products. This enables them to build the “well, duh” SoD policies such as “flag everyone with SAP_ALL.” The “well, duh” SoD policies are the just the ante to play in the controls monitoring game. The meaningful, high value SoD policies come from the audit community and their years of lessons learned working across multiple industry verticals globally. It has yet to been if the ERP vendors will truly cater to this community’s needs. It is the greater audit community that Approva has sought to serve since day one and we’ll continue to do so. Viva independence!
Posted October 11th, 2007
(The following is also available over at Approva’s Audit Trail.)
The deal has been announced and will finally be done in November. Nobody is particularly surprised that Oracle is buying LogicalApps, least of all, us here at Approva. With this transaction Oracle will now have a controls automation tool needed to continue its fight with SAP. Analysts, bloggers, and prospective customers have asked: where does this leave Approva and the answer is – exactly where we want to be: Approva remains the independent controls monitoring company – and the only one with the proven ability to work across applications, in multiple platforms and for any kind of control.
Oracle (and similarly SAP) are taking the approach of strongly tying and embedding their controls monitoring tools in their ERP packages. What’s wrong with this approach? It is fundamentally too limited in scope and vision. Yes, managing controls in ERP systems is critical, especially in a SOX world. But, a tool that scopes controls automation down to SoD analysis for a specific ERP package (and, for that matter, a specific version therein) can only provide a keyhole view and doesn’t truly serve the GRC needs of the enterprise. Since LogicalApps only addressed Oracle E-Business Suite, with this acquisition Oracle continues to neglect its red haired step children: PeopleSoft, JD Edwards, Hyperion, Siebel… where’s the controls love for them? Continue reading "Oracle buys LogicalApps: Approva Remains the Land of Freedom"...
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