Internal controls on compliance databases and reports

The 2007 ACC/Serengeti Managing Outside Counsel Survey asked a group of questions about law departments and compliance. As summarized in ACC Docket, Vol. 30, March 2008 at 12, “less than half of law departments have the following specific internal controls for validating the accuracy of the data in their compliance reports: audit trail of changes to reporting data (18%); verification that data has been correctly entered (23%); and verification of spreadsheet formulas (10%).”

Actually, I am surprised that one out of ten law departments in the survey verify the formulas in the spreadsheets that they use to prepare compliance reports. And, does “verification that data has been entered correctly” mean extra precautions like re-keying for accuracy checks or reading data entered against the original source?

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