Almost four years ago now, President Bush signed
into legislation the U.S. Public Accounting
Reform and Investor Protection Act of 2002. More
commonly known as the Sarbanes-Oxley Act, or
SOX, the goal of this act is to regulate
corporations in order to reduce fraud and
conflicts of interest, to improve disclosure and
financial reporting, and to strengthen
confidence in public accounting.
SOX is the most significant government
legislation affecting accounting and auditing in
more than 70 years. Section 404 of this act, the
one giving IT shops fits, specifies that the CFO
must do more than simply vow that the company’s
finances are accurate; he or she must guarantee
the processes used to add up the numbers. Those
processes are typically computer programs that
access data in a database, and DBAs create and
manage that data as well as many of those
processes.
So SOX will bring visibility and additional
rigor into DBA practices and procedures. One of
the provisions of the Act states that financial
data—whether live or at rest—must be hardened
against unauthorized access, invalid
transactions, or any other type of modification
that invalidates the integrity of the financial
reports. How stringent are the security controls
on your databases? Do you have automated
controls in place to scan databases for
compliance and vulnerability exposures? Are
practices in place to audit access to your data
to report on any unusual activity? Are these
controls in place for all your mainframe
financial data whether it’s stored in DB2, IMS,
VSAM, or flat files?
And how robust is your backup and recovery? SOX
demands that your company’s financial data be
completely recoverable in the event of a logical
or physical failure— without loss of data that
would invalidate the integrity of the financial
reports. Do you have an enterprise backup and
recovery policy you manage? Has backup and
recovery been fully automated and tested? Can
you demonstrate your ability to recover both
locally and remotely in case of a disaster?
And how do you manage and track database change?
SOX contains provisions for that, as well,
stating that changes made to the data structures
must be done using an authorized process. All
impacts and deltas must be tracked and reported
to ensure there are no unauthorized changes that
could invalidate the financial reporting
systems. Do you have a workflow and task
approval process in place? And do you track all
changes to data structures and catch those made
outside the authorized change approval process?
What about keeping track of the changes between
releases to provide a complete summary of data
structure changes for compliance reporting?
Furthermore, SOX specifies a five-year data
retention period (beginning from the end of the
fiscal period in which the audit or review was
concluded) for your relevant financial data and
work papers. Are you confident you can access
all your five-year-old financial data? Is all
the data there? If not, has it been archived or
backed up in a format that can be accessed? And
what do you do if the database schema has
changed over those five years?
DBAs have had to deal with security and
authorization, auditing, backup and recovery,
and change management as long as databases have
been used. But in many cases, these tasks were
attacked in a low-cost, ad hoc manner. Maybe
there wasn’t sufficient capital to expend on DBA
processes; maybe the DBAs were capable enough to
keep the databases up and running without the
aid of tools. Such an approach is no longer
sufficient.
DBMSes are being extended to provide additional
capabilities for securing data, ensuring
integrity, and making changes accurately with
limited outages. But in most cases, to
completely assure database operations are
accurate, sustainable, and ongoing, robust
third-party tools are required. For example, do
you feel comfortable scanning database log
records to produce database audit reports?
Without a tool that understands log records and
legibly formats the data, most DBAs will be
unable to glean anything usable from the
information-rich database transaction logs.
The Bottom Line
Now that executives have to vouch for the
accuracy of your company’s data, it becomes more
likely you can procure a budget for proper
tools. When someone’s neck is on the line, tools
that can help ensure data accuracy will suddenly
be more important than they were just a little
while ago. Imagine that …