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Strong policies and internal controls – safeguarding your resources, and your reputation

Strong policies and internal controls – safeguarding your resources, and your reputation. Maria Falvo Chief Operating Officer American Savings Foundation. Bradley P. Lusk, CPA Managing Partner Sisterson & Co. LLP. Deborah Shinbein, Esq. Certified Information Privacy Professional

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Strong policies and internal controls – safeguarding your resources, and your reputation

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  1. Strong policies and internal controls – safeguarding your resources, and your reputation Maria Falvo Chief Operating Officer American Savings Foundation Bradley P. Lusk, CPA Managing Partner Sisterson & Co. LLP Deborah Shinbein, Esq. Certified Information Privacy Professional Data Law Group, P.C.

  2. Scholars Say Promised Money Didn't Come December 08, 2013| By MATTHEW KAUFFMAN And VANESSA DE LA TORRE, Hartford Courant Background article on this story.

  3. Best Practices • Establish an independent audit committee. • Conduct an annual audit. Remember – auditor should report to audit committee, not to staff. • Respond to all audit findings and recommendations. • Conduct a formal annual review of top management. • Adopt and review policies and procedures. Decide which should receive annual board approval. • Regularly communicate policies and procedures to staff through an employee handbook, regular staff meetings. • Provide regular education to board related to governance, compliance, policies and procedures. • Perform a risk management review.

  4. New Challenges in a Digital Age Data in many formats and locations Laws vary from state to state Policies needed for protection from liability (and compliance) • Website terms of use – and other online concerns • Privacy / use of personal information policy • Data security policies (WISP, AUP, BYOD, more) • Data retention/destruction policy • Breach preparation/response policy

  5. New Challenges in a Digital Age (Cont.) Data security tips: • Oversee third party providers: • Screen carefully – 3rd party certifications, due diligence • Contracts - include security requirements, audits, warranties, indemnification, breach response, termination provisions, and more • Encrypt data in transit and at rest; SSL when appropriate • Implement access controls, strong passwords • Test your security measures (tech penetration, human errors) • Update antivirus, system patches, etc. regularly • Back-up frequently, specify approved use of cloud providers • Don’t collect more than needed or keep longer than necessary

  6. Our experience – what works • Work with your auditor to get the most out of your annual audit. Together, look for opportunities to strengthen controls. • Make sure annual review of policies is not simply pro forma. • Document, review, update and follow procedures for all key activities. • Consider additional challenges for a small staff. • Never be satisfied. Test your assumptions.

  7. Contact information Maria Falvo Chief Operating Officer American Savings Foundation 185 Main Street New Britain, CT 06051 mfalvo@asfdn.org 860.827.2556 phone 860.832.4582 fax Bradley P. Lusk, CPA Managing PartnerSisterson & Co. LLP310 Grant Street Suite 2100Pittsburgh, PA 15219 bplusk@sisterson.com Phone: 412.281.2025Fax: 412.338.4597 Deborah Shinbein, Esq. Data Law Group, P.C. 3700 Quebec Street Denver, CO 80207-1639 Deb@DataLawGroup.com Phone: 303.997.1325 Fax: 303.796.7203

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