Developing Governance
Developing Governance
IT Governance
Developing a successful governance strategy
A Best Practice guide for decision makers in IT
The effective use of information technology is now an accepted organisational im
perative - for
all businesses, across all sectors - and the primary motivation; improved commun
ications and
commercial effectiveness. The swift pace of change in these technologies has con
signed many
established best practice approaches to the past. Today's IT decision makers and
business
managers face uncertainty - characterised by a lack of relevant, practical, advi
ce and standards
to guide them through this new business revolution.
Recognising the lack of available best practice guidance, the National Computing
Centre has
created the Best Practice Series to capture and define best practice across the
key aspects of
successful business.
Other Titles in the NCC Best Practice series:
IT Skills - Recruitment and Retention ISBN 0-85012-867-6
The New UK Data Protection Law ISBN 0-85012-868-4
Open Source - the UK opportunity ISBN 0-85012-874-9
Intellectual Property Rights - protecting your intellectual assets ISBN 0-85012872-2
Aligning IT with Business Strategy ISBN 0-85012-889-7
Enterprise Architecture - understanding the bigger picture ISBN 0-85012-884-6
IT Governance - developing a successful governance strategy ISBN 0-85012-897-8
Security Management - implementing ISO 27000 ISBN 0-85012-885-4
All title are available from NCC see the website for further details www.ncc.co.
uk
The National Computing Centre - generating best practice
1
IT Governance
Developing a Successful
Governance Strategy
A Best Practice Guide for Decision Makers in IT
IT Governance Developing a Successful Governance Strategy
2 Foreword
For organisational investment in IT to deliver full value, it is recognised that
IT has to be fully aligned to business strategies
and direction, key risks have to be identified and controlled, and legislative a
nd regulatory compliance demonstrated. IT
Governance covers this and more, and in light of recent corporate failures, scan
dals and failure, enjoys a higher profile today
than ever before.
Back in 2003, IMPACT launched an IT Governance Specialist Development Group (SDG
) to identify the issues that need to be
addressed and to share and further develop the practical approaches to IT govern
ance used in their organisations.
Over the past two years, heads of IT governance from Abbey, Aon, Avis, Barclays,
BOC, DfES, Eli Lilly, Learning & Skills
Council, Legal & General, NOMS, Royal Mail and TUI Group have examined what they
identified as the key topics and, with
the guidance of IT governance expert Gary Hardy, have defined the good practices
captured in this guide.
For further information on the IMPACT Programme, its Professional Development Pr
ogramme and the IT Governance and
CobiT Specialist Development Group, please contact Elisabetta Bucciarelli on 020
7 842 7900 or email elisabetta.bucciarelli@
impact-sharing.com. The IMPACT Programme is a division of the National Computing
Centre.
The IMPACT Programme
International Press Centre
76 Shoe Lane
London EC4A 3JB
IT Governance
Developing a successful governance strategy
A Best Practice Guide for decision makers in IT
Published by
The National Computing Centre
Oxford House
Oxford Road
Manchester
M1 7ED
Website: www.ncc.co.uk
Tel: 0161 242 2121
Fax: 0161 242 2499
First published November 2005
Copyright National Computing Centre 2005
ISBN: 0-85012-877-8
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missions should be made to the Publisher.
Disclaimer
Every care has been taken by the authors, and by the National Computing Centre,
and associated working groups, in the preparation of this
publication, but no liability whatsoever can be accepted by the authors or by Na
tional Computing Centre, or associated NCC working groups,
for actions taken based on information contained in this document.
All trademarks acknowledged.
3
The Business Case . . . . . . . . . . . 4
1 IT Governance
1.1 Why is IT Governance important? . . . . . . . . . . 5
1.2 What does IT Governance cover? . . . . . . . . . . 6
1.3 What are the benefits? . . . . . . . . . . . . . . . . . 6
1.4 What is IT Governance best practice? . . . . . . . 7
2 Performance Measurement . . . . . . . . . . . . . . . . . . 9
2.1 Why is performance measurement important? . 9
2.2 What does performance measurement cover? . 10
2.3 Who are the stakeholders and what are
their requirements? . . . . . . . . . . . . . . . . . . . . 11
2.4 What should we measure? . . . . . . . . . . . . . . . 12
2.5 What is best practice? . . . . . . . . . . . . . . . . . . 12
3 Implementation Roadmap . . . . . . . . . . . . . . . . . . . 14
3.1 Goals and success criteria . . . . . . . . . . . . . . . 14
Because organisations are relying more and more on IT, management needs to be
more aware of critical IT risks and whether they are being managed. Furthermore,
if there is a lack of clarity and transparency when taking significant IT decisi
ons,
this can lead to reluctance to take risks and a failure to seize technology
opportunities.
And finally, there is a realisation that because IT is complex and has its own f
ast
changing and unique conditions, the need to apply sound management disciplines
and controls is even greater.
Stakeholders include:
Top level business leaders such as the Board, Executive, non-Execs, and especial
ly
heads of Finance, Operations and IT.
Those that have a responsibility for investor and public relations.
Internal and external auditors and regulators.
Middle level business and IT management.
Key business partners and suppliers.
Shareholders.
Customers.
Concerns they typically have include:
Availability, security and continuity of IT services.
Costs and measurable returns on investments.
no embarrassments.
Quality and reliability of service
IT not appearing to respond to the real needs of the business.
Identification and management of IT related risks to the business.
IT Governance
The Business Case1
IT Governance Developing a Successful Governance Strategy
6 Capability and skills of human resources.
Compliance to legal, regulatory and contractual requirements.
Responsiveness and nimbleness to changing conditions.
1.2 What does IT Governance cover?
IT Governance is a relatively new concept as a defined discipline and is still e
volving.
IT Governance is not just an IT issue or only of interest to the IT function. In
its broadest sense it is a part of the overall
governance of an entity, but with a specific focus on improving the management a
nd control of Information Technology for the
benefit of the primary stakeholders. Ultimately it is the responsibility of the
Board of Directors to ensure that IT along with other
critical activities is adequately governed. Although the principles are not new,
actual implementation requires new thinking
because of the special nature of IT.
IT Governance spans the culture, organisation, policy and practices that provide
for IT management and control across
five key areas1:
A l i g nme n t Provide for strategic direction of IT and the alignment of IT an
d the
business with respect to services and projects.
Va l u e D e l i ve r y
Confirm that the IT/Business organisation is designed to
drive maximum business value from IT. Oversee the delivery of value by IT to the
business, and assess ROI.
R i s k Ma n a geme n t Ascertain that processes are in place to ensure that ris
ks
have been adequately managed. Include assessment of the risk aspects of IT
investments.
Re s o u r c e Ma n a geme n t Provide high-level direction for sourcing and use
of IT
resources. Oversee the aggregate funding of IT at enterprise level. Ensure there
is
Investors
(business management, business partners and IT management)
I n t e r e s t s
they provide the funding and want to see a return on their inv
estment
and alignment with their strategic objectives
Re q u i r eme n t s
- Financial ROI, cost v. budget, productivity, benefits realisation
- Customer surveys and feedback (subjective as well as objective), strategic
objectives v. actual projects/activities
- Process
capability benchmark, performance exceptions, transformation
capability and tactical agility
- L e a r n i n g
attrition, retention, skill profile, resource short fall, trai
ning and
development
Controllers (internal and external audit, risk and compliance officers, finance,
human resources, industry specific
regulators)
I n t e r e s t s
they monitor risk and compliance and have an interest in due p
rocess,
regulatory and legal requirements, evidence of governance and risk management,
amount of rework/repeat effort, and compliance with strategy
Re q u i r eme n t s
- Financial losses, investments in control improvements
- Customer exceptions/breaches, risk management, compliance with legislation
and regulations
- Process
control effectiveness, compliance
- Learning risk identification, risk prevention
Deliverers/Providers
(IT service and product suppliers, in-house and outsourced,
contract and procurement management
and staff involved in IT delivery and support)
I n t e r e s t s
they need to meet customer expectations, and deliver in an eff
icient
and effective way, preserving and enhancing reputation
Re q u i r eme n t s
- Financial operational and project costs, cost allocation/recovery, service
credits, cost optimisation
- Customer performance against SLAs, satisfaction feedback e.g. survey
responses, customer retention and growth statistics, effectiveness of dealing
with business churn
Performance Measurement2
IT Governance Developing a Successful Governance Strategy
12 - Process internal improvement in efficiency and risk reduction, internal v.
outsource decision support
- Learning capability to deliver, readiness for new requirements, time to market
for new initiatives
2.4 What should we measure?
The ownership of measures and accountability for achieving targets should be cle
ar. Furthermore, ownership and the
collection of measurement data will not always be an IT responsibility, e.g. mea
surement of customer-focused outcomes. It
should therefore also be clear whose responsibility collection is. Where appropr
iate, measures should be formalised in Service
Level Agreements (SLAs) based on service descriptions written in a language and
using terms meaningful to the customer.
For third party service providers an SLA should form part of the contractual agr
eement so that performance measurement can
be backed up with contractual recourse in the event of performance failure. To s
upport IT Governance the following top fifteen
areas to measure are recommended, with an indication of who has a primary intere
st and therefore who should approve the
measures (figure 2.4)
3.3 Who needs to be involved and what are their roles and responsibilities? . .
. . . . . . . . . . . . . . . . . . . . . . . . .16
This chapter describes an Implementation Roadmap for activating an effective IT Go
vernance programme to deliver the
above benefits, and is based on the practical implementation experiences gained
by the IMPACT IT Governance SIG
members.
The roadmap begins with establishing clear goals and objectives in order to alig
n effort with the real needs of the enterprise,
to manage expectations, and to ensure continual focus. The roadmap then consists
of activities to get started, followed by
the key implementation tasks with suggested roles and responsibilities. IT Gover
nance is an ongoing task and therefore this
roadmap is only the initial phase of what needs to become an iterative sustainab
le approach.
3.1 What are the goals and success criteria?
Implementing IT Governance for many organisations will mean major changes. It is
important therefore to not only have highlevel
sponsorship but also the active involvement of key stakeholders. The roadmap is
an iterative lifecycle that begins with
an initial phase to define overall goals and to gain the support and commitment
of top management which then leads to the
ongoing effective governance of IT activities.
A generic set of initial objectives has been identified by the SIG and is shown
in Figure 3.1. Figure 3.1.1 suggests some
success criteria for this initial phase of IT Governance.
Typical objectives of the initial implementation phase Agreed v
Define the meaning of governance in your organisation and where/if IT Governance
fits
Identify any organisational/environmental/cultural constraints and enablers
Achieve a broad understanding of IT Governance issues and benefits across all st
akeholders
Agree, publish and gain acceptance of an initial IT Governance framework, tools
and processes
Completion of an initial gap analysis against best practice to demonstrate where
IT Governance is already in place
and to highlight areas of focus for the roadmap
Creation of a Project Initiation Document (PID) and/or Terms of Reference (ToR)
that has the support of stakeholders
Creation of a Project Plan with definition and prioritisation of the initial ITG
project deliverables
Identification and commitment of the resources required to deliver this initial
project
Identification and sign-off of Key Performance Indicators and Critical Success F
actors for this project
Documented estimated timescales and resource (s and FTE) implications as well as
expected ROI
Alignment of the ITG Initiative with business objectives/strategy
Figure 3.1
15
3.2 How to get started the key initial activities
Having set the goals, and gained support, activation consists of two steps
plann
ing, based on analysis of the current
environment, followed by implementation itself.
Planning
These are recommended implementation planning activities together with some crit
ical success factors:
Activities CSFs
Identify champions
- Stakeholders (including partners), Input providers, IT strategy committee
(council) members
Establish IT strategy committee (council)
Identify IT hotspots in the organisation, and where governance could enable
hotspot resolution:
- Strategy? Delivery? IT Cost? Architecture?
- Where current approaches have not worked or caused serious failures
Identify skill set and capabilities needed from people involved
Identify existing good practice ( pseudo governance ) or successes that could be
built on or shared
Identify cost/benefit arguments
why do we need to do anything?
Identify inconsistencies in process/practice
Identify opportunities for rest of business to get involved in IT
Explore opportunity to adopt industry best practice model, or standards
framework
Utilise external influences
Create a measurement approach for an area or activity to expose actual evidence
of problems
Do some gap analysis against industry best practice
v Authoritative and articulate
champions
v Available skills and
capabilities
v Well prepared business
cases approved by
stakeholders
v Real opportunities for the
business to see the benefit of
participating
v Practical and useful
governance approaches
v Effective and useful
measures
v Expose the truth /whole
picture, warts and all, about
project success /failure,
showing how governance can
be helpful
Implementation Roadmap3
Success criteria for the initial implementation phase Done v
Key stakeholders identified, engaged and actively involved
Key stakeholders contributing towards and able to explain and support the busine
ss case for ITG
Stakeholders have an understanding of the expectations of the IT Governance init
iative
Some initial quick wins have been identified and implemented to make governance
l
Acceptance of the published IT Governance framework by those responsible for imp
lementation
An effective communication plan
who to, what, when etc. to overcome any barriers
and to motivate change
Current key IT projects mapped against ITG plan, to look for easy fit/implicatio
ns
Changes are sustainable and institutionalised, i.e. they become Business as Usua
l practices
Figure 3.1.1
IT Governance Developing a Successful Governance Strategy
16 Implementation
These are the recommended activities to start up the implementation roadmap, tog
ether with some critical success factors:
Activities CSFs
rea
realisation
Coordinate overseas/satellite parts of the
enterprise to ensure their interests and
constraints have been considered
Create organisation and structure
to ensure board involvement in the
governance process
by forming
committees, establishing reporting
processes
Monitor performance, monitor risks,
correct deviations
Business and IT senior managers,
business partners and project
sponsors
Implement organisation and necessary
infrastructure
Take ownership of requirements
Champion and collaborate in IT
governance activities
Ensure business strategy and objectives
are set and communicated and aligned
with IT
Assess business risks and impacts
Establish reporting processes meaningful
to stakeholders
Communicate any business concerns in
a balanced and reasoned way
Provide project champions, creating the
seeds of change
User representatives
Take responsibility for Quality Assurance
programme (design and output)
Regularly check actual results against
original (or changed) goals
Provide service feedback to providers
IT management (internal and
external), with support from
business management
Take ownership and set direction of IT
Governance activities
Build and achieve a pilot business case
IT management
Set IT objectives
Define IT governance and control
framework
Identify critical IT processes
Assess risks, identify concerns
Assess IT capability, identify gaps
Initiate a continuous improvement
programme
Develop business cases for
improvements
Design and implement solutions
Commit skilled resources
Establish performance measurement
system
Report to senior management
Respond to QA feedback from customers
Suppliers/business partners
Integrate any own existing or planned
gement approach.
Effective communications are a key enabler of these changes, just as poor commun
ications can create a legacy of
misunderstanding, lack of trust, and technical mystique and hype in many organis
ations. As we said earlier, if it is difficult for
those literate in technology and relatively close to the IT function, then it is
even worse for the end customer who finds technical
jargon a smokescreen and lack of information relevant to his business a major he
adache. Communication and cultural
behaviour, based on appropriate influencing strategies are therefore key ingredi
ents of any IT Governance improvement
programme. In order to best influence stakeholders, and communicate the major ob
jectives and benefits of IT Governance
throughout the organisation, the right language must be used. Given the signific
ance of IT both in terms of investment and
potential impact on the business
the risks of IT and of failing to exploit IT fo
r strategic advantage must be stressed in
any communication about IT Governance. Wake-up calls are sometimes required at t
he highest levels. Stakeholders must
understand and feel responsible for safeguarding against IT risks.
Effective communications will ensure that everyone is on the same page
that key is
sues have been grasped, objectives
have been positively accepted by management and staff, and everyone understands
their role. Every organisation will have its
own existing culture and choice of IT Governance approach that it wishes to adop
t. The roadmap to follow for cultural change
and effective communication will therefore be unique to each organisation, howev
er there may be common elements.
4.1 Who do we need to influence?
A fundamental element of IT Governance is change. When considering who needs to
be influenced for successful IT
Governance, it is important to remember that different messages are needed for d
ifferent stakeholders. Whatever the topic is
about, the language used must be understandable, relevant to the intended audien
ce, and motivate positive attitudes towards
change.
Identifying and gaining the support of key influencers of success and failure he
lp enable successful communications
strategies. It is also vital to recognise the main stakeholders impacted by the
change, identify why we want to influence a
particular stakeholder, and identify any resistance that needs to be overcome. P
ositive attitudes need to be promoted and
used to influence others.
All three generic groups of stakeholders, and their interests, should be involve
d in an IT Governance initiative. It is critical
to influence these groups positively so that they understand the objectives and
benefits of IT Governance and are able to
communicate consistently to each other and within their groups (Figure 4.1).
19
4.2 What are the key messages?
In order to best influence stakeholders, and communicate the major objectives an
d benefits of IT Governance, the right
language must be used. An inability to communicate effectively has been one of t
he major causes of IT failures, with too much
technical jargon, lack of business understanding and poor appreciation of the ot
her party s requirements and issues. Ideally,
a common language is required, and a balance has to be found between the busines
s trying to understand IT and IT trying to
understand the business. Communications will improve if the business views the t
echnology provider not as a simple enabler
but as a valued business partner and if IT presents benefits in the language tha
t the business understands. The following are
examples of some of the key messages that need to be communicated, based on thre
e primary IT Governance objectives and
the related benefits that can be realised (Figure 4.2).
Communication Strategy & Culture4
Who needs to be influenced?
Investors Providers Controllers
The Board
IT Council/Management Team
Senior business unit managers e.g. key
customers of IT services
Business Partners
External investors/shareholders
as part
of corporate governance
Project and change managers (IT and
Business)
Programme managers
Business managers and users
Technical delivery and support teams
Key players e.g. business sponsors,
project champions
Relationship managers and internal
communications teams
Suppliers (especially outsourced service
providers)
Contract and procurement management
Peripheral players/influencers/policy
owners e.g. HR, Facilities Management,
Legal
Internal audit and external audit (due
diligence)
External regulators
Corporate governance coordinator
Risk managers
Compliance
regulatory and internal
Finance/Project Managers/IT and
business managers
reviewers of
benefits/ROI
Post investment appraisal/post project
review teams
Key Messages
Benefits of governance
Why we need to do it
Impact on the business strategy
Commitment to support action plans
Benefits of governance
Why we need to change
Your role and responsibility
How you need to change
Need for independent assessment and
assurance
Relate to real business risks and impacts
Work positively with management to
address control needs
Figure 4.1
Ability to address these Objectives will realise these Benefits
IT and Business strategic and operational alignment
IT and business working towards the same corporate goals
Architecture and other technology approaches seen as relevant
solution.
- Use case studies to illustrate business benefits as a direct result of effecti
ve
governance, e.g. reduced costs, improved quality, productivity, reputation and
marketing advantages.
Scenario modelling with risk assessment and mitigation:
- Consider known and new risks across both business and IT (e.g. external audit
requirements)
- How governance can help mitigate the risk
- Calculate a risk factor = likelihood x impact
- Consider options
accept, mitigate or assign
Using common business language:
- Technological risk in financial/economic/business terms
- Legal/regulatory, contractual implications
Critical Success Factors
Involve all relevant stakeholders in a facilitated workshop environment
Get clear ownership and funding commitment for risk mitigating actions
Monitor/track all actions
4.4 Developing an influencing strategy
Critical to the success of any IT Governance initiative is an effective communic
ations plan. The communications plan should
be based on a well-defined influencing strategy. Behaviours will need to be chan
ged and care should therefore be taken
to ensure that participants will be motivated and see the benefits of the new ap
proaches, as well as understanding the
consequences of accepting responsibility. If this is not positively communicated
, then IT Governance will not be perceived as
part of the corporate mission with Board level support. Management will resist i
t as a barrier to getting the job done, a deviation
from current priorities, or another management fad.
The strategy should identify opportunities for the active involvement of stakeho
lders in developing the governance approach,
planning and implementing IT management changes, and ideally building specific c
hange objectives/targets into personal
performance plans. The stakeholders are likely themselves to be the targets of c
hange and should be involved in discussing/
evolving responses to the change via collaborative workshops, focus groups etc.
21
The influencing strategies need to be designed to work in specific situations wi
th the individual influence targets identified. The
following table shows four typical influencing styles, examples of the communica
tions involved and the associated leadership
styles. It is important to select the most appropriate style taking into account
who needs to be influenced and on what topic.
Focus on Roles and Responsibilities
Identify an overall sponsor and steering group with specific tasks and responsib
ilities
for leading the change
Ensure there is a complete structure of cascaded sponsorship down to team/line
manager level
Focus on individual situations
Identify champions (those high on interest and/or influence)
Use successes as benchmarks
Disseminate across teams and support formation of new teams
Figure 4.4.1 shows different change approaches that can be used. For IT Governan
ce initiatives experience shows that
the best approach is incremental change evolving and adapting of current practic
es to a new collaborative IT management
approach.
Communication Strategy & Culture4
roadmap to follow for cultural change and effective communication will therefore
be unique to your specific situation.
The following techniques (Exploring Strategic, Change Veronica Hope-Hailey, Juli
a Balogun, Gerry Johnson, Kevan
Scholes, Cranfield University) can help guide the best path to follow, and can b
e used to assess how your organisational
culture and management style currently deals with the governance of its IT activ
ities and what cultural style it desires. To
do this you must:
Analyse the existing state
Define the desired state
Cultural style and paradigms are formed from several characterictics which can g
enerally be illustrated as shown in Figure
4.5.
Figure 4.5.1 illustrates some of the typical current and desired IT Governance b
ehaviours found in many organisations
today.
Figure 4.5
Characteristic Current Desired
Myths and Stories Poor business and IT alignment:
Project failures; budget overruns; poor
service, failure to meet business needs.
Effective business and IT alignment:
Demonstrable RoI, project success stories,
user satisfaction, business driving IT.
Symbols Mystique and technical jargon, lack of
business terms.
Common language based on customer
needs. Business literate in IT issues and
opportunities.
Power Structures Them and us attitudes. Collaboration.
Organisational Structures Divisive. IT seen as overhead function. Partnerships.
IT seen as business enabler.
Control System Based on departmental units and who knows
the most.
Based on defined processes, standards and
best practices owned by the organisation.
Routines and Rituals Hidden agendas, measures in provider s
terms and a general lack of transparency
leaving top management in the dark.
Joint forums for monitoring progress,
measures in customer s terms, transparent
reporting to top management.
Figure 4.5.1
23
5 Capability Maturity
Assessment
5.1 Why IT capability is important . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
23
5.2 How to measure IT capability . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23
5.3 Setting maturity targets and considering improvements . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24
5.4 Roadmap for sustaining the approach . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25
5.5 Self-assessment tools . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. .26
Monitoring and assessing the adequacy of IT Resources (people, applications, tec
all staff.
Appropriate facilities are provided and time is available for staff to develop t
he
skills they need.
Capability Maturity Assessment5
IT Governance Developing a Successful Governance Strategy
24 Boards needs to ensure that IT resources are used and managed wisely by ensur
ing that:
Appropriate methods and adequate skills exist in the organisation to manage IT
projects.
The benefits accruing from any service procurement are real and achievable.
IT assets are complex to manage and continually change due to the nature of tech
nology, and changing business
requirements. Effective management of the lifecycle of hardware, software licenc
es, service contracts, and permanent and
contracted human resources is a critical success factor in not only optimising t
he IT cost base, but also for managing changes,
minimising service incidents, and assuring a reliable quality of service.
Of all the IT assets, human resources represent the biggest part of the cost bas
e and on a unit basis the one most likely
to increase. Identifying and anticipating the required core competencies in the
workforce is essential. When these are
understood, an effective recruitment, retention and training programme is necess
ary to ensure that the organisation has the
skills to utilise IT effectively to achieve the stated objectives. 8
5.2 How to measure IT capability
To ensure IT resources are managed effectively, IT capability should be assessed
on a regular basis and whenever
resources are critical to strategic IT decisions. The capability assessment shou
ld be:
Based on alignment of IT goals with business goals
Targeted at the IT processes critical to business success by,
- Assessing the current capability of these IT processes
- Determining the required capability
- Analysing any gaps in capability
- Providing transparent visibility of the capability position
- Defining and justifying necessary improvement projects or
- Re-adjusting the IT strategy
Adjusting goals
Improving capability
Outsourcing when cost-effective
The measurement of IT capability should be an objective assessment oriented towa
rds business requirements. This will
ensure that the current as-is and required to-be capabilities are realistic and meas
urable enabling any gaps to be identified
and a plan to be drawn up to rectify any shortcomings.
The Capability Maturity Model (CMM) approach first developed by the Software Eng
ineering Institute for measuring software
delivery capability is increasingly being adopted as the basis for assessing ove
rall IT capability. This model provides a
standard scale for assessing the maturity of any IT process on a five-point scal
e (figure 5.2).
The following principles are recommended when carrying out an assessment:
Set Scope
Select a reference model based on standards and best practices most suitable
for your business, e.g. CobiT, ITIL, SEI-CCM, SixSigma, ISO9000/9001, PMBOK
perhaps considering weighting measures
Use an acceptable measurement methodology agreed with the stakeholders which
is defined and transparent
Set a baseline in the context of 1 and 2 above and present the current state
Periodically review the objectives and reset goals if necessary, checking validi
ty of
goals against business strategy
5.5 Self-assessment tool
The simple self-assessment diagnostic in figure 5.5 can be used to help show ove
rall capability at a high level. It is based
on the four domains of CobiT, broken down into the 34 CobiT sub-processes. The e
xtent of the analysis depends on how
precise you wish to be. A management workshop can be used to arrive at an approx
imate initial assessment without extensive
analysis.
27
Capability Maturity Assessment5
IT Process/Maturity
Importance
Ad hoc
Repeatable
Defined
Managed
Optimised
Planning & Organisation
PO1 Define a Strategic Information Technology Plan H
PO2 Define the Information Architecture M
PO3 Determine the Technology Direction M
PO4 Define the IT Organisation and Relationships M
PO5 Manage the Investment in Information Technology M
PO6 Communicate Management Aims and Direction L
PO7 Manage Human Resources L
PO8 Ensure Compliance with External Requirements M
PO9 Assess Risks M
PO10 Manage Projects L
PO11 Manage Quality L
Acquisition & Implementation
AI1 Identify Solutions L
AI2 Acquire and Maintain Application Software M
AI3 Acquire and Maintain Technology Architecture M
AI4 Develop and Maintain Information Technology Procedures M
AI5 Install and Accredit Systems L
AI6 Manage Changes M
Delivery & Support
DS1 Define Service Levels M
DS2 Manage Third-Party Services H
DS3 Manage Performance and Capacity M
DS4 Ensure Continuous Service L
DS5 Ensure Systems Security M
DS6 Identify and Allocate Costs L
DS7 Educate and Train Users L
DS8 Assist and Advise Information Technology Customers L
DS9 Manage the Configuration M
DS10 Manage Problems and Incidents H
DS11 Manage Data H
DS12 Manage Facilities L
DS13 Manage Operations M
Monitoring
M1 Monitor the Process M
M2 Assess Internal Control Adequacy M
M3 Obtain Independent Assurance M
M4 Provide for Independent Audit M
Figure 5.5
IT Governance Developing a Successful Governance Strategy
28 6 Risk
Management
6.1 What are the risks? . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . .28
6.2 What is the best approach for risk analysis and management? . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . .29
6.3 How can standards and best practices be used
is certification useful? . . .
. . . . . . . . . . . . . . . . . . . . . . . .30
6.4 What are the roles of management, staff and auditors? . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
6.5 Who needs to be competent? . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
6.6 What competence is required? . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32
6.7 How to obtain, develop, retain and verify competence . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33
6.8 When to source competence from outside . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .35
6.9 Key learning points . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . .35
The management of risks is a cornerstone of IT Governance, ensuring that the str
ategic objectives of the business are
not jeopardised by IT failures. IT related risks are increasingly a Board level
issue as the impact on the business of
an IT failure, be it an operational crash, security breach or a failed project,
can have devastating consequences. However,
managing IT risks and exercising proper governance is a challenging experience f
or business managers faced with technical
complexity, a dependence on an increasing number of service providers, and limit
ed reliable risk monitoring information. As a
consequence, management are often concerned whether risks are being cost effecti
vely addressed, and they need assurance
that risks are under control.
The universal need to demonstrate good enterprise governance to shareholders and
customers is the driver for increased risk
management activities in large organisations. Enterprise risk comes in many vari
eties, not only financial risk. Regulators are
specifically concerned about operational and systemic risk, within which technol
ogy risk and information security issues are
prominent. The Bank for International Settlements, for example, supports that vi
ew because all major past risk issues studied
in the financial industry were caused by breakdowns in internal control, oversig
ht and IT. Infrastructure protection initiatives in
the US and the UK point to the utter dependence of all enterprises on IT infrast
ructures and the vulnerability to new technology
risks. The first recommendation these initiatives make is for risk awareness of
senior corporate officers.
Therefore, the board should manage enterprise risk by4:
Ascertaining that there is transparency about the significant risks to the enter
prise
and clarifying the risk-taking or risk-avoidance policies of the enterprise.
Being aware that the final responsibility for risk management rests with the boa
rd
so, when delegating to executive management, making sure the constraints of that
delegation are communicated and clearly understood.
Being conscious that the system of internal control put in place to manage risks
often has the capacity to generate cost-efficiency.
Considering that a transparent and proactive risk management approach can create
Having defined risk appetite and identified risk exposure, strategies for managi
ng risk can be set and responsibilities
clarified. Dependent on the type of risk and its significance to the business, m
anagement and the board may choose to:
Risk Management6
Figure 6.1
IT Governance Developing a Successful Governance Strategy
30 Mitigate, by implementing controls
Transfer, by sharing risk
Accept, by formally acknowledging that the risk exists and monitoring it
The following framework for managing risk in Figure 6.2 is suggested by the OGC
(OGC Risk Management Framework
www.ogc.gov.uk).
The analysis of IT risks can be very time-consuming and there is a danger of anal
ysis paralysis . To ensure effective
and timely identification of risk, management workshops involving knowledgeable
and interested representatives from the
business, IT, audit and, if necessary external advisors, can help to rapidly pin
point key risks requiring attention, as well as
prioritising risk management actions. It is also important to identify the benef
its of managing a risk as they can help to justify
the business case for taking action. Benefits can include financial savings such
as reduced losses and improved efficiencies
as well as intangibles such as improved reputation and image.
Risk management checklists are useful for raising awareness and reminding everyo
ne of typical risk related issues. Regular
self-assessments, internal audits and external audits/assessments are also helpf
ul to ensure objectivity, and a thorough
approach. For technical areas such as Internet security, the advice of an expert
is likely to be required to ensure any technical
vulnerabilities have been identified.
6.3 Using standards and best practices is certification useful?
There is no doubt that effective management policies and procedures help to ensu
re that risks are identified and managed as
a routine part of everyday activities. Adoption of standards and best practices
will help to enable quick implementation of good
procedures and avoid lengthy delays re-inventing wheels and agreeing approaches.
The best practices adopted have, however, to be consistent with the risk managem
ent framework and be appropriate for the
organisation, and be integrated with other methods and practices that are being
used. Standards and best practices are not a
panacea and their effectiveness will depend on how they have been actually imple
mented and kept up to date. They are most
useful when applied as a set of principles and as a starting point for tailoring
specific procedures. To avoid practices becoming
shelf-ware , change enablement is required, so that management and staff understand
what to do, how to do it, and why it is
important. For risk management to be effective, the use of a common language and
a standardised approach oriented towards
real business requirements is best
making sure everyone follows the same set of
objectives, issues and priorities.
Benchmarking is another very useful way to compare how risk management is being
addressed within the organisation in
relation to best practice, industry peer groups and other organisations. Conform
ance to generally accepted standards and
practices can be very helpful when managing risks relating to outsourced service
s and third party suppliers. Certification
Figure 6.2
31
against a standard may be important for helping to establish trust with trading
Project Managers
Risk Managers
Business Analysts
Infrastructure Management
Procurement/Contract Management
IS Strategy
alignment with the business
Quality Management
Business Relationship Management
Programme Managers
However, there is a need for breadth of business and IT knowledge rather than to
o narrow a specialisation.
Risk Management6
Suppliers/business partners
Integrate any own existing or planned governance practices with
customer
Support and contribute to customer s governance approach
Agree service definitions, incentives, measures and contracts/
agreements
Training and Development
Ensure adequate education and communication
HR function
Incorporate governance principles into induction and performance
measurement process
Core team
Define plan and deliverables
Organise team and roles (architects, senior responsible officer,
facilitator, project manager, process owners)
Undertake core tasks
Report progress to plan
People related IT Governance skills:
- Understanding of roles
- Understanding of competencies required
- Understanding of sources of expertise
Delivery management skills:
- Familiarity with best practices
- Understanding of IT processes, how they should be controlled,
and how to monitor performance
- Knowledge of corporate standards and policies affecting IT
- Ability to provide cost estimates
- Engagement and project management
Figure 6.6.1
Controllers Role & Responsibilities Competence Required
Internal and external audit
Scope audits in coordination with governance strategy
Provide assurance on the control over IT
Provide assurance on the control over the IT performance
management system
Risk management
Ensure that new risks are identified in a timely manner, provide
advice
Compliance officers
Ensure that IT complies with policy, laws and regulations
Finance
Advise on and monitor IT costs and benefits
Provide support for management information reporting
Incorporate governance requirements into purchasing/contract
process
How to apply good Governance practices effectively in
IT:
- Understand the business environment and its impact on IT
Ensure there are clear roles and responsibilities on the customer s side of the
relationship
Ensure there is an Executive level sponsor who will be responsible and accountab
le
for all significant decisions regarding key suppliers
Commit long-term
Establish relationships at multiple levels
Organise suppliers according to criticality and roles
Technical
Manage technical IT issues to ensure conformance where necessary and
compatibility with in-house technical standards
Ensure all relevant legal and regulatory requirements have been considered
Standardise and commoditise solutions wherever possible
Set realistic expectations regarding service delivery
Take time to understand product and service offerings
Understand how your own IT assets may be affected by supply of external products
or service
Ensure there is good control of the internal environment affected by the externa
l
supply
Project Approach
Take care to manage all staff related issues
Set up a co-ordination committee of senior customer representatives
Make sure there is a process for both parties to follow
Build into the requirements and contract plans for transition/transformation fro
m the
current state to an outsourced service
Approach contracts and relationships in a balanced way ensuring risks have been
considered in the context of the value expected from the supplier
Avoid the danger of mixed messages coming from different parts of the customer
organisation
Make sure there is top-down management commitment to support all key decisions
How to monitor and measure
1. Identify a limited range of meaningful and measurable key measures e.g.:
Performance
Financial
Risks
Compliance
Relationship
Value added
Delivery
2. Take ownership and define and obtain agreement for all measures
3. Supplier senior management should:
Supplier Governance7
IT Governance Developing a Successful Governance Strategy
40 Provide data for all measures he is responsible for
Monitor delivery performance
Agree remedial action with customer
Commit remedial actions
4. Customer IT service management should:
Be responsible for monitoring and reporting
Prioritise and recommend actions
5. Customer should:
Provide customer satisfaction measurement data
Consider benchmarking to other organisations and other services
What functions should be retained by the customer?
(Reference Forrester Research Functions to Retain when Outsourcing, July 2004)
Even when the bulk of IT is outsourced, several key functions should be retained
because they supply continuity for clients
of IT, provide for the oversight of the outsourcer, are highly specific to the w
As organisations have adopted the CobiT approach, it has driven the professional
Audit firms to follow similar approaches,
and to integrate CobiT into their internal proprietary methodologies. This has h
elped to break down communication barriers
and improve the mutual understanding of IT controls. There is also a trend among
service providers to use CobiT and other
best practices to improve their market image and quality of service. This is als
o helping to improve communication of control
issues and make it easier to manage and audit IT activities against a commonly a
ccepted basis. Because CobiT is open and
independent of any specific vendor all parties can use it freely. It is not a sta
ndard as such but a best practice framework
and set of guidance materials to be tailored for each specific situation.
There is currently a great deal of focus on the Sarbanes-Oxley Act in the US, an
d the reporting requirements that this
legislation requires for Company Directors. Many companies are using CobiT as th
e framework for reporting the status of IT
systems and controls, and consequently a massive CobiT-based controls documentat
ion effort is underway. While SarbanesOxley has been very useful for putting IT governance and control on the Board s ag
enda, there is a danger that the effort will
be limited to a documentation exercise to achieve compliance. The real value fro
m any control evaluation, especially when
based on CobiT, is the identification of control gaps and the implementation of
a sustainable improvement programme. There
45
is an analogy with the Y2K experience in that Sarbanes-Oxley should not be a one
off exercise but an ongoing programme for
improving management control and establishing governance.
8.3 What are the roles of IT and Audit for IT Governance?
Role of IT Audit
IT Governance is a management responsibility, and therefore not the sole
responsibility of an Audit function. The Audit function should remain independen
t,
but this can provide an excellent position to influence and recommend change.
Independence should not inhibit provision of advice, so long as management take
full responsibility and accountability for implementation and operation of contr
ols.
Taking responsibility for enabling an IT Governance initiative or for initiating
governance projects should not compromise Audit.
IT Governance requires management commitment and ownership within IT and the
business in order to make it happen. Audit can then determine if it is happening
, and
provide assurance to the board.
When reviewing Governance, Audit must do more than just identify problems. They
need to identify root causes and make constructive recommendations.
Audit can test controls especially where control is critical and assurance is
required. But increasingly there is a trend for IT to test themselves by performin
g
self-assessments.
Audit can play a part in setting standards, and providing control criteria and c
ontrol
benchmarks, particularly in respect of external regulation.
Given the speed of IT change and the high cost of development projects, it makes
sense to involve auditors in projects. To be effective auditors must:
- Be credible and confident to gain the respect of IT
- Not wait until the end of a phase to critique but give pro-active guidance on
what should be done
Role of IT
IT has to be responsible for changing the culture of the IT organisation, for
scorecards of IT performance.
Define HOW improvements can be made.
Create business case for changes.
Create implementation action plan.
Provide Project Control and QA.
Facilitate job rotation/secondees.
Improvement
Advise on WHAT should be improved.
Provide training in controls.
Provide workshops to improve understanding.
Organise shared events.
Facilitate job rotation/secondees.
Figure 8.5
47
The effectiveness of a self-assessment depends on the quality, objectivity, skil
l and experience of the people performing the
review. Using an alternative means of checking to supplement the questionnaire c
an help as can obtaining Internal audit input
in an educating/reviewing role.
There are a number of constraints and challenges relating to self-assessments:
Level of maturity
Number/volume of testing
Reliance on the results
- Objectivity
- Completeness and Rigour
Resources
IT is typically overloaded with day to day pressures
Political issues need to be addressed
how to get management buy-in, and there
may be a reticence to identify and quantify risks
Cultural aspects should be considered e.g. the need to balance positive messages
with weaknesses
Avoid routine ticking boxes exercises which are much less valuable
The following are some practical requirements for self-assessments:
Individuals performing assessments recognise accountability
There will be a need framework/objectives/policy to self assess against (e.g. ba
sed
on CobiT)
Well designed questionnaires keep them simple with no ambiguity, and examples
to aid interpretation
Coaching/training may be needed if using a web-based questionnaire
Require supporting evidence to be documented
Training may be needed on risk identification, definition, and quantification
IT & Audit Working Together & Using CobiT8
IT Governance Developing a Successful Governance Strategy
48 9 Information
Security
Governance
9.1 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . .48
9.2 What is information security? . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.49
9.3 Where to focus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . .50
9.4 Roles and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.50
9.5 Action planning and best practice . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .52
parties.
Information security specialists can play a key advisory role although governanc
e and final decision-making must remain
in-house. There is also an opportunity for cost reduction compared with permanen
t in-house staff. Examples of outsourced
security activities include:
Testing (e.g. following patches)
Vulnerability testing (note: Penetration testing must be performed with care as
it
may crash the system)
Incident management
Special care should be taken when dealing with outsourced suppliers:
Contractors need to be vetted for security purposes
Suppliers do have a responsibility to manage security within their own activitie
s
make sure this happens
Although the supplier has to be trusted to carry out checks, the client must ens
ure
that the necessary checks are in place
Regulations such as Sarbanes-Oxley requires that governance responsibility
remains in-house
Information Security Governance9
Who needs to be involved?
Investors Providers Controllers
The Board
IT Council/Management Team
Senior business unit managers e.g. key
customers of IT services
Business Partners
External investors/shareholders
as part
of corporate governance
Project and change managers (IT and
Business)
Programme managers
Business managers and users
Technical delivery and support teams
Key players e.g. Business sponsors,
Project champions
Relationship managers and internal
communications teams
Suppliers (especially outsourced service
providers)
Contract and procurement management
Peripheral players/influencers/Policy
owners e.g. HR, Facilities Management,
Legal
Internal audit and external audit (due
diligence)
External regulators
Corporate governance coordinator
Risk managers
Compliance
regulatory and internal
Finance/Project Managers/IT and
business managers
reviewers of
benefits/ROI
Post investment appraisal/Post project
review teams
Key Security Responsibilities
Risk sign-off
Own the business case
Set policy
Define expectations and requirements
Ensure legal and regulatory compliance
Review performance
Monitor delivery
Quantify impact of risk
Challenge the risk management plan
Approve proposals and metrics
Prioritise actions and investments
Supply necessary resources
Set culture and environment
Risk analysis
Design and implementation
Creation of business cases
cost and
solution
Security operations
Security administration
Monitoring security incidents
Education and training (both IT and HR)
Creation and maintenance of scorecards
for performance measurement
Understand impact of regulations
Monitor adequacy and performance of
controls (assessments and audits)
Test actual performance of controls
Monitor performance (execution of
improvements)
Provide independent assurance to
management
Figure 9.4
IT Governance Developing a Successful Governance Strategy
52 9.5 Action planning and best practice
IMPACT SIG members suggest the following action steps be considered:
1. Classify objectives and actions into technical and non-technical areas
2. Ensure that an effective security policy is in place
3. Establish a security baseline
4. Cover key vulnerabilities
5. Communicate management concerns for security to ensure staff awareness
6. Focus on changes
evaluate and test for security exposures
7. Ensure that Board presentations emphasise security as an enabler and not as a
disabler
53
10 Legal &
Regulatory
Aspects of IT
Governance
10.1 Legal and regulatory factors affecting IT Governance . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53
10.2 Roles and responsibilities . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
.54
10.3 Best approach to compliance . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .55
10.4 What IT has to do . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . .56
10.5 Dealing with third parties . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. .58
10.6 Critical success factors . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
. .59
In recent years there has been a general increase in the number of regulations a
ffecting the use of IT and also the number
of situations where legal measures need to be considered. This is due to the nee
d to guard against a wide range of new IT
related risks and from a general increase in corporate regulations.
The impact of not taking sufficient care over legal or regulatory requirements c
an be considerable including:
Loss of reputation
Inability to trade
Financial penalties and losses
Loss of competitive advantage
Loss of opportunity
On the other hand the benefit of complying with regulatory requirements and usin
g legal measures to protect commercial
interests can be considerable, including:
General improvement in overall control of IT related activities
Reduced losses and administrative costs
More efficient and effective negotiation of commercial transactions
A greater ability and confidence to take risks
because senior management feel
more in control
There are a wide range of laws and regulations, some specific to industry sector
s that can have an impact on IT. Every
organisation must identify the specific regulations affecting them and respond a
ccordingly, and ensure that the roles and
responsibilities for understanding legal and regulatory matters are properly def
ined for each group of stakeholder so that each
group can apply its specific expertise effectively. External advice must be soug
ht whenever the issues are sufficiently risky
or complex.
Every organisation relies on a growing number of third parties for support of IT
services. From a legal and regulatory
perspective this means that there is potentially a complex hierarchy of responsi
bilities that combine to meet the legal and
regulatory needs of the customer. Ultimately it is the customer s responsibility t
o ensure that all the right controls are in place
with any third party that is relied upon for legal and regulatory compliance.
10.1 Legal and regulatory factors affecting IT Governance
The recent increase in the number of regulations affecting the use of IT is due
to a number of factors, including:
Legal & Regulatory Aspects of IT Governance10
IT Governance Developing a Successful Governance Strategy
54 A greater interest by regulators in the operations of all
organisations caused by major corporate financial failures and
scandals, which is resulting in regulations like the US SarbanesOxley Act forcing Boards of Directors to express opinions about
their systems of control.
Concerns about security and privacy fueled by the overall
increase in use of computers and networks and the impact of the
Internet.
Laws to protect personal information and its potential misuse in
electronic form.
A growth in the use of computer systems and networks for
criminal activity and terrorism, including viruses, hacking,
money laundering and pornography etc.
A growth in complex contractual relationships for IT services
and products (outsourcing, managed services, product licenses
etc.).
The growth in all forms of electronic media and the potential
The Board
IT Council/Management Team
Senior business unit managers e.g. key
customers of IT services
Business Partners
External investors/shareholders
as part of
corporate governance
Project and change managers (IT and
Business)
Project and change managers (IT and
Business)
Programme managers
Business managers and users
Technical delivery and support teams
Key players e.g. Business sponsors, Project
champions
Relationship managers and internal
communications teams
Suppliers (especially outsourced service
providers)
Contract and procurement management
Peripheral players/influencers/Policy owners
e.g. HR, Facilities Management, Legal
Internal audit and external audit (due
diligence)
External regulators
Corporate governance coordinator
Risk managers
Compliance
regulatory and internal
Finance/Project Managers/IT and business
managers
reviewers of benefits/ROI
Post investment appraisal/Post project
review teams
Legal and Regulatory Responsibilities
Understand requirements (what regulations
are to be complied with)
Set the mandate
Set priorities and expectations
Establish and ensure the expected degree of
compliance
Based on advice concerning risk and cost:
Assess impact on business
Provide resource and funding to ensure
issues are addressed
Define who is accountable
Obtain internal or external assurance as
required that issues have been addressed
and controls established
Monitor and evaluate compliance
programmes and significant commercial
contracts
Sign off specific compliance programmes
Provide approvals when required for
significant legal or regulatory decisions
Advise on IT related technical and
commercial risks that could impact legal and
regulatory requirements
Provide proposals and business cases for
legal and regulatory programmes, projects or
action plans
affect which systems. Then it becomes possible to address all the relevant syste
ms when standards have to change:
Consider regulatory issues together
Do not set up separate projects which may conflict with the standard approach
Decision making must rest with the business in terms of the extent and nature of
compliance
10.4 What IT has to do
Historically, most IT people did not think about compliance- except in terms of
good practice, because regulations rarely
impacted the technical environment. Gradually this has changed, first with IT sp
ecific legislation like the Data Protection act,
and most recently by the realisation that corporate level regulations like Sarba
nes-Oxley must be inextricably linked to the IT
systems because corporate information and financial reporting has become so auto
mated.
Figure 10.3
57
In addition, due to the very significant cost of IT investments, and the complex
ity of customer and supplier relationships,
legal contracts for IT services are being given much more careful attention. The
se contracts in turn demand greater controls
be demonstrated by the parties to the contract, over many issues such as securit
y, intellectual property, service availability,
ownership of deliverables, support of products etc.
As a consequence, IT service providers, vendors, and internal IT functions are a
ll realising that they must be better organised
from a control and compliance perspective. It is only a relatively recent realis
ation that IT related controls should be
documented and monitored by IT functions, increasingly driven by regulatory pres
sure.
Business objectives and processes should drive the system of internal control an
d therefore the documentation process. The
flow should be:
For an efficient and effective compliance process, the documentation should be i
n a language that auditors would use, and
therefore it is best to work with the audit community and adopt a common languag
e and approach such as CobiT.
IT functions increasingly need to be more involved in legal and regulatory requi
rements and should:
Work with the business users and risk management groups to identify critical
systems and compliance priorities.
Document architectures so that the overall environment is understood on a
continuous basis.
Define processes in IT in a logical well ordered fashion, meaningful to auditors
and
management (e.g. based on CobiT).
Appoint process owners so there is accountability and responsibility.
Understand control concepts, the need for IT controls, and how they relate to
business level controls.
Document these processes and controls (especially for compliance critical system
s),
and maintain the documentation as changes occur.
Legal & Regulatory Aspects of IT Governance10
Figure 10.4
IT Governance Developing a Successful Governance Strategy
58 Standardise wherever possible to avoid duplication of effort.
Maintain evidence of controls being exercised to be better able to demonstrate
compliance.
Generate business benefits from the control and compliance projects by performin
g
The IMPACT SIG identified the following success factors to enable effective ongo
ing legal and regulatory compliance and
proper control of legal contracts:
Establish the right culture to encourage diligence and good controls
Communication throughout the organisation based on a Board level mandate is
essential to make sure everyone takes the issues seriously and uniformly
Involve the right people as advisors but do not abdicate responsibility
Retaining responsibility for control and compliance when using service providers
Standardisation and a common approach is the most effective and efficient way to
meet compliance requirements
Use frameworks and accepted compliance models especially those accepted by
auditors
Integrate compliance objectives into the IT strategy
Ensure management are actively involved
not just performing a sign-off at the
end
- Set the tone at the top
Institutionalise compliance behaviour
- Engage the governance and risk management groups (those who own the
framework) as soon as possible
- Provide a positive spin good controls can be very beneficial
- Make compliance normal business practice rather than a project
Make compliance meaningful and relevant
- Translate into normal language
- Explain business context
- Carry out awareness training
Establish mechanisms for evidence and documentation
Establish metrics for monitoring performance
Create incentives and/or penalties as part of personal objectives
Do regular compliance checking and tests
Do regular review of risks (include 3rd parties)
Have good incident management procedures to learn from legal and regulatory
incidents
Legal & Regulatory Aspects of IT Governance10
IT Governance Developing a Successful Governance Strategy
60 11 Architecture
Governance
11.1 Why is Architecture Governance important? . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .60
11.2 What are the objectives of Architecture Governance? . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .61
Given the complexity and fast-changing nature of IT, architectures are important
for defining technical direction, captured
in a formal design that will support evolution and change, based on generally ac
cepted standards as well as specific
design standards. Architecture governance is therefore to do with ensuring that
the principles of architectures are properly
applied to the design and maintenance of information systems, meeting technical
design standards as well as the business
purpose and strategic objectives for IT.
There are generally three overall end goals with respect to architecture governa
nce:
Business and IT Alignment (fit for purpose)
Risk Management (reduced likelihood of design failures)
Resource Management (cost effectiveness and value for money)
The process of determining technological direction via an IT Architecture satisf
ies the business requirement to take advantage
of available and emerging technology to drive and make possible the business str
ategy. This is enabled by creation and
maintenance of a technological infrastructure plan that sets and manages clear a
nd realistic expectations and standards, of
what technology can offer in terms of products, services and delivery mechanisms
. Given the significant amount of outsourcing
of IT services, the effective governance of architectures in these situations is
a key consideration. The business strategy may
depend on an effective IT architecture, but who defines the architecture in the
outsourced situation? The customer should
always take control of his own requirements including architectural decisions ev
en if the provider offers existing solutions
and approaches. Senior management may assume that providers will develop technol
ogy to improve productivity
this is
not always the case. A capability for setting the direction for technology impro
vement should be retained in house and often
contracts will call for customers to control their own technical direction. Cost
will usually be the driving factor in contractual
arrangements who will pay for architectural upgrades?
The group identified the following critical success factors for achieving archit
ectural governance:
Ensure that the Architecture process and its governance is adequately funded
Ensure good communications among all the groups concerned
Align the architecture with the business strategy and the culture of the
organisation
Recognise that persuasion is always needed for compliance and that this can be
enhanced by active project involvement, technical consultancy, provision of read
ilyavailable,
cost-effective tool-kits and components
Share all artefacts with outsource providers
11.1 Why is Architecture Governance important?
Architecture (in Greek a??? = first and t???? = craftsmanship) is the art and sc
ience of designing structures. In the context
of computers, the term architecture is used to describe the technical design and
interoperability of components that together
make up the information system i.e. hardware, software and network components.
Given the complexity and fast-changing nature of IT, architectures are important
for defining technical direction, captured in
a formal design that will support evolution and change, based on generally accep
ted standards as well as specific design
standards. There is an analogy with the original use of architectures for defini
providing the
ng the design of buildings
blueprint that demonstrates what the end product should look like, that it is fo
rmed on a solid foundation, that it is built
according to defined design standards, and that it meets the purpose for which i
t was intended.
Architecture governance is therefore to do with ensuring that the principles of
architectures are properly applied to the
design and maintenance of information systems, meeting technical design standard
s as well as the business purpose and
strategic objectives for IT. The IT Governance and Technical Architecture SIG me
mbers believe that in many organisations the
61
challenge is to commit to a properly funded and business driven architectural ap
proach. Often it is treated as too technical an
activity, with inadequate or insufficiently skilled resources, and with limited
business and top management direction.
The group assessed the maturity of Architectural activities based on the CobiT ma
turity model (see Appendix). This
assesses maturity on a scale from 0 to 5. An analysis of the maturity level of t
he organisations represented showed the
following:
Current maturity ranged from 1+ to 4
- In larger organisations there was a spread (e.g. from 2 to 4) across the diffe
rent
parts of the organisation
- The lowest maturity was in a business where IT had recently been outsourced
The maturity level aspired to was between 3+ and 4
- No organisation saw level 5 as necessary
11.2 What are the objectives of Architecture Governance?
The definitions CobiT provides for setting technical direction were used to help
define the purpose of Architecture
Governance:
The process of determining technological direction via an IT Architecture satisf
ies the business requirement to take advantage
of available and emerging technology to drive and make possible the business str
ategy. This is enabled by creation and
maintenance of a technological infrastructure plan that sets and manages clear a
nd realistic expectations and standards of
what technology can offer in terms of products, services and delivery mechanisms
.
It considers:
Capability of current infrastructure
Monitoring technology developments via reliable sources
Conducting proof-of-concepts
Risk, constraints and opportunities
Acquisition plans
Migration strategy and roadmaps
Vendor relationships
Independent technology reassessment
Hardware and software price/performance changes
Covering the following activities:
Technological infrastructure planning
Monitoring future trends and regulations
Assessing technological contingency
Planning hardware and software acquisitions
Defining technology standards
The group believe that measurement of these activities is difficult and may ofte
n rely on perception of trends.
CobiT suggests focusing on these key measurable outcomes:
Number of technology solutions that are not aligned with the business strategy
Percent of non-compliant technology projects planned
Number of non-compatible technologies and platforms
Decreased number of technology platforms to maintain
Reduced applications deployment effort and time-to-market
Increased interoperability between systems and applications
And these performance measures:
Percent of IT budget assigned to technology infrastructure and research
Number of months since the last technology infrastructure review
Business functions satisfaction with the timely identification and analysis of
technological opportunities
Percent of technological domains within the technology infrastructure plan that
have
sub-plans specifying current state, vision state and implementation roadmaps
Average length of time between the identification of potentially relevant new
technology and the decision as to what to do with that technology
The Open Group (www.opengroup.org) defines an Architecture Governance Framework
which covers:
Architecture Governance11
IT Governance Developing a Successful Governance Strategy
62 Governance processes
Policy management
Compliance assessments
Dispensation procedures
enable accountability.
Given the volatility of a portfolio of IT-related business projects, it is essen
tial to embed active portfolio management into the
organisation to maximise value creation and minimise the risk of value destructi
on. As with any aspect of IT governance, the
process needs visibility, leadership and commitment from the top.
12.1 Why is managing the IT investment important?
The basic principles of IT value are the on-time and within-budget delivery of ap
propriate quality, which achieves the benefits
that were promised. In business terms, this is often translated into: competitiv
e advantage, elapsed time for order/service
fulfilment, customer satisfaction, customer wait time, employee productivity and
profitability. Several of these elements are
either subjective or difficult to measure, something all stakeholders need to un
derstand. Often, top management and boards
fear to start major IT investments because of the size of investment and the unc
ertainty of the outcome. For effective IT value
delivery to be achieved, both the actual costs and the return on investment need
to be managed (ITGI Board Briefing V2
2004).
20% of all expenditure on IT is wasted7, representing, on a global basis, annual
value destruction of US$500bn according
to a 2002 Gartner paper (Gartner, The Elusive Business Value of IT , August 2002).
It is then no surprise that there is an
increasing demand from boards and executive management for generally accepted gu
idelines for investment decision-making
and benefit realisation. While particularly applicable to IT-enabled business in
vestments, where IT is a means to an end, the
need is equally applicable to all investment decisions. In the case of IT, the
end
is to contribute to the process of value
creation in the enterprise.
IT-enabled business investments, when managed well within an effective governanc
e framework, provide organisations
with significant opportunities to create value. Without effective governance and
good management, they provide an equally
significant opportunity to destroy value. Horror stories abound around the value
destruction suffered by major organisations
through the failed implementation of IT enabled business investments. Nike repor
tedly lost more than US$200m through
difficulties experienced in implementing its supply chain software, failures in
IT enabled logistics systems at MFI and
Sainsbury in the UK led to multi-million pound write-offs, profit warnings and e
rosion of share price. Other organisations have
suffered in a similar fashion.
On the other hand, many successful organisations have created value through sele
ction of the right investments, and
successfully managing them through implementation to realising the expected valu
e. Examples include IBM who reportedly
was able to save more than US$12bn over two years by linking disparate pieces of
its supply chain and thereby reducing
inventory levels, and Southwest Airlines who were able to reduce procurement cos
ts and increase service levels through their
supply chain transformation project.
Managing the IT Investment12
7. IT Governance Institute research on IT Value.
IT Governance Developing a Successful Governance Strategy
64 The message is clear. IT-enabled business investments can bring huge rewards
with the right governance and management
processes and full commitment from all management levels. The process for managi
ng IT investments can be summarised
ation
governs the use of IT properly. With corporate governance on every boardroom age
nda and increasing scrutiny of IT s performance - IT governance has become a hot topic
around
the world. For some many businesses, IT governance initiatives are already trans
forming the
way their organisations take responsibility for IT. For others, it is a challeng
e just knowing
where to start.
Recognising the challenges faced by CIOs in establishing effective IT governance
, the NCCs
IMPACT Programme launched an IT Governance Special Interest Group (SIG). Its aim
was
to identify not just the issues that need to be addressed, but also practical ap
proaches for
organisations to follow. Over the past two years, heads of IT governance from Ab
bey, Aon,
Avis, Barclays, BOC, DfES, Eli Lilly, Learning & Skills Council, Legal & General
, Marsh, NOMS,
Royal Mail, and TUI Group examined the key challenges. They shared successful ap
proaches
and defined best practice.
This IT Governance Best Practice Guide is a comprehensive insight of the princip
les and
practices that the group put together. It is presented in a form that should hel
p you to
understand better how to guide successful IT governance initiatives and make eff
ective
management and control of IT resources business as usual .
This Guide forms part of the NCC Best Practice Guides series and is intended to be
of
practical use for decision makers in IT. This guidance is achieved through indus
try consensus,
managed by NCC, across the broadest range of professionals and experts.