Sarbanes-Oxley and New Opportunities

							                                                      TRENDS04
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SARBANES-
OXLEY
     &
     New
     Opportunities
      BY HOLLY E. HARKNESS, Atlanta Chapter
     Editor’s note: This article pertains to technical communicators living in the United States.



16                                                                                                  January 2004
                                                                                                                              your career

        aving trouble finding work as a         ers on my team were part of a large proj-      to mitigate those risks. An example of a


H       technical writer? Try reinventing
        yourself as a Sarbanes-Oxley doc-
        umentation specialist! Many
companies need to staff these positions,
but they may not yet recognize that tech-
                                                ect to reorganize financial operations.
                                                The company hired expensive consul-
                                                tants from several firms to aid this effort,
                                                but we continually reminded the project
                                                leadership that the best resources for
                                                                                               risk is that an employee might use com-
                                                                                               pany funds to purchase an item for per-
                                                                                               sonal use. An internal control for that
                                                                                               risk would be the requirement that all
                                                                                               purchases be approved by a manager.
nical communicators have the skills and         documentation were in-house. For this          Wherever a gap is identified, you will
background to get the job done right.           project, we wrote training materials, poli-    work with the process owner to define
                                                cies, online help for management report-       and document a new internal control,
What Is Sarbanes-Oxley?                         ing software, and numerous quick               which will probably be a procedure, a
   Congress passed the Sarbanes-Oxley Act       references. The materials we produced          checklist, or a policy.
of 2002 in response to the wave of              were top-notch. This project established          Another aspect of Sarbanes-Oxley is
accounting scandals at such companies as        our reputation as a quality service            documenting the controls on your finan-
Enron, Tyco, and WorldCom. The intent           provider for documentation.                    cial software. How do users get access?
of the law is to make corporate executives         When Sarbanes-Oxley came along, our         What kind of security exists to safeguard
accountable for their companies’ finan-         company formed a new team to address           sensitive financial information from hack-
cial statements and to require strict adher-    Sarbanes-Oxley requirements. The lead-         ers? To meet this requirement, you’ll
ence to accepted accounting practices.          ership of the new team remembered our          have to take some technical information
   Under Section 404 of Sarbanes-Oxley,         work and asked for our services again.         and make it understandable to an out-
the management of all publicly owned            We readily agreed. This time we were           sider. Sound familiar?
companies must document and evaluate            allowed to charge our hours to the                Gwen Thomas, an STC member in
the effectiveness of their internal controls    Sarbanes-Oxley project, taking some pres-      Florida, is the senior Sarbanes-Oxley
and their procedures for financial report-      sure off the IT budget. When the IT bud-       resource for CIBER, Inc., a global IT ser-
ing. An independent auditor must sign           get was cut, our group survived the layoffs    vices provider and editorial director of
off on this report. After June 14, 2004,        because of our commitment to Sarbanes-         the Vendor-Neutral Sarbanes-Oxley Web
every company must comply with this stip-       Oxley compliance.                              site, www.sox-online.com.
ulation by the end of its fiscal year. Penal-      Another happy consequence of our               She explains, “As data enters the com-
ties for failure to comply include large        participation in this project is that many     pany and moves from person to person
fines and even prison sentences for finan-      of the procedural documents and poli-          and from IT system to IT system, the
cial officers and chief executive officers.     cies we’ve written can serve as documen-       company must have adequate controls
   As you might imagine, companies all          tation of internal controls or processes.      on who can change the data, the data-
over the United States are scrambling to        Other documents provide much-needed            bases holding the data, the utilities and
put their documentation in order to             background information for team mem-           programs that extract, transform, and
comply and meet the deadline. The Big           bers who are preparing to interview sub-       load data, and the reports that display
Four accounting firms—Deloitte and              ject matter experts. This result brings a      data. These controls need to specify when
Touche, Ernst and Young, KPMG, and              renewed appreciation for our team and          changes can occur, and why. They need
PricewaterhouseCoopers—are offering             reinforces the value we contribute to the      to indicate who is accountable for every
their consulting and auditing services (at      company.                                       link in these data chains, and how
hefty fees) to help with this effort.                                                          accountability is managed.
   According to CNET News, “U.S. com-           What Role for a Technical                         “And, of course, none of this can be
panies are expected to spend more than          Communicator?                                  managed if those involved aren’t clear
$2.5 billion to comply with new account-           A central feature of a Sarbanes-Oxley       [about] what they’re managing. Gaps in
ing rules required by the Sarbanes-Oxley        project is documentation of key financial      documentation will need to be evaluated.
Act, with a significant chunk going to          processes such as accounts payable activi-     Data dictionaries need to be updated
information technology projects.”               ties, cash disbursement, purchases, and        (which some tech writers can do as well as
                                                earnings statements. Many organizations        data architecture resources). Processes
How My Team Is Contributing                     document these processes inadequately          need to be captured. Metadata reposito-
  The technical writers on my team are          or sporadically, if at all.                    ries might need to be consolidated or
integrally involved with the Sarbanes-             If you’ve participated in a software        updated. This might be new work for
Oxley project. How we got there is an           implementation project where you’ve            some writers, but extremely familiar to
interesting story. All of our technical writ-   created Visio charts showing “as is” and       some.”
ers work within the Information Tech-           “to be” processes, you’ll have no trouble         Finally, we can use our editing skills to
nology (IT) department. We write                creating process flows for Sarbanes-Oxley.     ensure that the documents are written
software and hardware instructions, pri-        You will work with subject matter experts      consistently. We can help develop style
marily for proprietary products.                to identify the risks involved in each         guides and glossaries.
  Two years ago, several technical writ-        process and the internal controls in place        If you join the Sarbanes-Oxley project


January 2004                                                                                                                             17
your career

   where you work, you’ll meet employees         to familiarize yourself with the law and       controls. Call the HR departments and
   who will come to appreciate your unique       how it’s being interpreted. I’ve provided      make some inquiries.
   skills—and who may request your help          some links you can use for reference at          Another suggestion is to approach
   with future projects.                         the end of this article.                       recruiters and market your skills to them.
                                                    The law is cumbersome to read and           The advantage here is that they have a
   How to Get Started                            understand, so stick with summaries            wide range of contacts at many firms.
     You probably already have the skills        instead. An important term to learn is         The disadvantage is that they will take a
   needed to become a Sarbanes-Oxley doc-        “internal control.” Most companies and         percentage of your pay when you get the
   umentation specialist. But it’s a good idea   auditors are using the definition pro-         job. Set your rate high to offset this factor.
                                                 vided by the Committee of Sponsoring
                                                 Organizations of the Treadway Commis-          Conclusion
                                                 sion (COSO). COSO was founded in                 Sarbanes-Oxley presents an opportu-
   Content management                            1985 as a result of the banking scandals
                                                 of that era.
                                                                                                nity similar to Y2K. Practically everyone
                                                                                                must comply with it, and practically no
   and version control                              COSO is a voluntary private organiza-       one is ready to do so. Here’s a chance
                                                 tion, jointly sponsored by the five major      to jump into the breach, show what you
   experience is                                 financial professional associations in the     can do, and get paid for it. Remember
                                                 U.S., dedicated to improving the quality       the closing line of Casablanca: “This
   helpful, as are                               of financial reporting. COSO has taken         may be the beginning of a beautiful
                                                 the lead in setting standards and best         relationship!”
   your skills as an                             practices for Sarbanes-Oxley compliance.         The clock is ticking for compliance.
                                                    If you are employed at a publicly           Get started now if this sounds like an
   interviewer of subject                        owned company, find out who is head-           opportunity for you!
                                                 ing up the Sarbanes-Oxley work. Ask your
   matter experts.                               manager to approach that person to             SUGGESTED READINGS
                                                 offer documentation services. Many com-        For a copy of the Sarbanes-Oxley law
                                                 panies are running behind and will             itself, go to news.findlaw.com/hdocs/
                                                 appreciate any help you can provide.           docs/gwbush/sarbanesoxley072302.pdf
                                                    If you are unemployed, read up on the
                                                 law, then review your résumé. Make sure        Protivity Consulting has published a
                                                 to stress any business processes you’ve        good introduction to Sarbanes-Oxley,
                                                 documented. If you’ve done any work            “Frequently Asked Questions Regarding
                                                 writing financial software manuals or pro-     the Sarbanes-Oxley Act,” at www.protiviti
                                                 cedures, highlight it. Stress your skills in   consulting.com/knowledge/sarbanes_oxley.html.
                                                 workflow programs like Visio or ProVision.
                                                 Content management and version con-            COSO’s Web site is www.coso.org.
                                                 trol experience is helpful, as are your
                                                 skills as an interviewer of subject matter     Gwen Thomas has set up a “vendor-
                                                 experts. Remember that many Sarbanes-          neutral” site with lots of links at www.sox-
                                                 Oxley hiring managers are in finance,          online.com.
                                                 risk control, or compliance. The title
                                                 “technical communicator” may not strike        Web sites for the Big Four accounting
                                                 them as a “fit” for their project. Use the     firms are as follows:
                                                 word “documentation” rather than “tech-
                                                 nical writer” to improve your chances for         Deloitte and Touche: www.deloitte.com
                                                 success.
                                                    I did a quick search of the job boards         Ernst and Young: www.ey.com
                                                 by entering “Sarbanes-Oxley” as a key
                                                 word. Not much turned up, which means             KPMG: www.kpmg.com
                                                 you’ll need to do some detective work to
                                                 find the openings. Remember that every            PricewaterhouseCoopers: www.pwc
                                                 publicly owned company must comply                global.com
                                                 with the regulation; therefore, some-
                                                 where at each of those companies, some-        A good article on the costs of Sarbanes-
                                                 one is documenting (or trying to               Oxley is at www.cfo.com/article/
                                                 document) their “404” processes and            1,5309,10546,00.html?f=featured.


   18                                                                                                                         January 2004