I was the SOX lead for the Consumer group regarding EDI and interfaces when we 
were faced with our first SOX audit Back In The Day.

It'll be a little while before I can get anything together from my archives -- 
but the most important thing that you need to get your auditors to buy into is 
the fact that EDI IS A COMPENSATING CONTROL and not a primary control.  

Primary controls, like audit trails, control totals in the source and target 
systems, etc. are the object of most audits and scrutiny, but you should get 
them to agree that any EDI processing is a compensating control (that's the 
magic word.)

Until we decided to take that tack, we were faced with the prospect of 
revalidating all of our maps and trading partnerships for both internal and 
external audit groups.    Once we realized that we had no real control over the 
data that came in -- the primary control and business logic existed in the 
receiving systems -- we were able to simply point to these facts:

1) There are access controls on the production system preventing *unaudited* 
production dataset access.
2) There are access controls on the production mapping preventing *unaudited* 
production map changes.
3) There are SOPs in place to detect mapping failures as they are received from 
the VAN and the primary responsible group is trained to respond to these.

With this in place, EDI becomes an important - but still manageable -- 
component.   I have seen people have all access - including browse - removed 
from maps, datasets, etc.  all in the name of SOX.  That is ridiculous.  SOX 
404 is about accountability for changes and auditability of the process, not 
about people kept from doing their work.

Let me know if you need specific questions answered -- or examples -- and I'll 
be happy to help you out.  Nobody should face SOX alone.   LOL


Rich Hurd
EDI Lead-SAP Process Teams
Johnson & Johnson Consumer Companies 
North American Consumer IT
908-874-1523




-----Original Message-----
From: [email protected] [mailto:[EMAIL PROTECTED] Behalf Of
[EMAIL PROTECTED]
Sent: Thursday, July 12, 2007 10:29 AM
To: [email protected]
Subject: [EDI-L] gentran NT narrative for SOX compliance


Has anyone had to write up a narrative for Gentran for SOX?  Our company 
just went public in February.  We are doing the documentation of our 
various IT systems to become compliant.  I'm struggling, as I'm sure many 
of you have, with trying to explain EDI. 

Any help would be appreciated!

Cindy

[Non-text portions of this message have been removed]



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