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Our SOX procedure for PTFs is:

-Request permission for installation of PTF (or PTF Cume)
-co-worker agreement
-manager approval

above 3 steps are run through a PC task routing system (on a portal); don't ask me which one!
The record of these are the documentation for the auditors that it was requested and approved.

-install on test machine
-wait a week
-install on live machine

The auditors have been convinced that the list of PTFs from IBM is sufficient documentation; we've explained that it's a package, and that we do not pick and choose which ones to install, and that if IBM says it's needed, it's needed, and we install it. Period.

Part of the SOX auditing is to make sure that we have internal procedures to handle things like changes. And that if we've written up something as part of the procedure, are we following our own rules. We got dinged because our procedures specified that changes to production data would be requested on the Official Change Live Data Request Form, and we had some changes that, although signed by the same people who sign the Official Form, were not on the Official Form. We re-wrote the procedure to say Official Form or other piece of paper. *sigh*

--Paul E Musselman
PaulMmn@xxxxxxxxxxxxxxxxxxxx




At 8:25 AM -0600 1/16/08, Jones, John (US) wrote:
Change management is much, much more than a log of the change. It
includes the request for the change, an approval of the change, the
implementation of the change, verification that the change was done and
that it works as advertised, and a back out plan in case the change has
to be un-done. Ideally it includes a testing phase where the change is
tested in a non-production environment.

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