Matt and Mark have both responded to my response.  Matt writes:

Thanks for keeping us honest Ian! I would be pretty blind to claim that overall regulatory compliance can be solved with any IT solution (…or set of …or service of). But I didn’t [...]]]> Compliance as a Service – Counter-counterpoint

Matt and Mark have both responded to my response.  Matt writes:

Thanks for keeping us honest Ian! I would be pretty blind to claim that overall regulatory compliance can be solved with any IT solution (…or set of …or service of). But I didn’t make that distinction in my previous post. But, is that the basic point you’re making? …that IT compliance is a subset of overall Compliance? Or is there more to it?

Yes and no.  I do believe the IT compliance is a subset of overall Compliance, but that wasn’t my basic point.  My most basic point was, because Big C Compliance is so truly tied to people and process it cannot be delivered as a service.  The reason I responded to you and Mark about this was that I didn’t want the conversation to start off with a definition of Big C that was too limited and too IT-centric.

Understanding that big-C Compliance requires much more than IT controls, would it seem more realistic if we said IT-compliance-as-a-service? or IT-Audit-as-a-service?

IT audit/compliance can and should be delivered as a service.  And not just the tools and tooling for it, but ownership of the compliance state and risk as well.  To me this is a natural extension to Managed Security Services and companies like Counterpane and IBM offer this to an extent.

The main thing I’m wondering is if organizations would get value from an external party taking over the IT audit portion so that the org itself (who might be anticipating regulatory pressure) wouldn’t have to figure out which questions to ask, how to ask them, how to build controls to get the right answers, and how to prove that the answers are what they should be.

This is spot on and I believe this is valuable to companies of all sizes.

There are obvious benefits to implementing Oracle [...]]]> 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!

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 [...]]]> (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?

To say that governance, risk, and compliance (GRC) is an ill-defined piece of buzzword bingo may be the understatement of the last few years. If someone says they have a complete GRC platform to meet all enterprise needs, kindly escort them out of the building via the nearest window. The point is that we, vendors, service providers, and customers, are still feeling out what truly needs to be in a complete GRC solution set and over time “GRC” will continue to evolve before it solidifies into a commonly accepted set of capabilities. Accepting this limited definition of controls automation that ERP vendors are serving up will cost their customers and force them to reinvest over time. By definition, a constrained, embedded approach to controls automation is shortsighted. It cannot meet the future needs of GRC because it cannot adapt to other systems and other processes that will eventually fall under the controls monitoring umbrella.

Approva’s approach has been and will continue to be fundamentally different. By staying independent and ERP agnostic, while at the same time providing rich domain expertise in those ERP packages, we provide customers better controls monitoring capabilities than the ERP vendors. We do this not only in these ERP applications, but we also provide the ability to do so in any application. Furthermore, we do this for any kind of automate-able control, be it traditional authorization-related segregation of duty or any kind of business process that our customers and business partners dream up. And we do all of this without the premium or baggage associated with ERP vendors.

Freedom to monitor any kind of control. Freedom to leverage our deep domain expertise as well as that of our partners in the audit world. Yep, staying independent is all about freedom for Approva and it is this freedom we give to our customers – even Oracle’s red haired step kids. I may not know what the final definition of GRC will be, but I do know that Approva’s independent approach to controls monitoring will serve its customers better than any controls monitoring tool shackled to just a single ERP package.