By Deanna Mollett, Partner & Director of ILM Services
In this first of our 3-topic series on compliance in 2016, we’re kicking things off with a review of Data Retention Tool, a.k.a. DART. The Data Retention Tool remains a vital component and “gold standard” in providing tax audit data. Support note 663007 offers an insightful explanation about DART’s position and utility in supporting response to tax audit inquiries. To gain further understanding about DART’s functionality extension in other countries, support note 1463497 is a highly valuable resource.
One important aspect to understand about DART and its value to your organization is that it updates periodically. Updates can be in alignment with requirements influenced by customer workgroups, such as the DSAG GDPdU Workgroup and the ASUG Tax Special Interest Group. While some updates are universal to solving performance or security problems, updates may be country-specific, such as France (FEC) enhancements. The latest upgrade to DART 2.8 delivers important customer workgroup updates and technical improvements.
To DART or not to DART is the question. In our 2-part blog post dedicated to DART, we’ll identify commonly asked questions and give you key information needed to help you answer those questions in a way that makes sense for your organization.
Question: Does DART really need to be implemented?
At Simply ILM, we base our observations on more than 16 years of DART and data archiving experience. On average, about 15% of those projects already had DART completed ahead of data archiving project inception. Previously implemented archiving that is in need of renovation indicates that the focus on DART was just enough to get by without a clear plan for keeping it current and compliant. For that reason alone, assessing the true value and risk to the organization for running DART (or not) is essential before working it into a project plan.
In our work with private and public U.S.-based companies, we have found the distinction of ownership to be a tipping point in the decision to implement DART before data archiving. It’s not that simple for other countries. Local tax agencies enforce guidelines covering “the right to data access,” which is applicable to both private and public companies. (We will expand on that concept and the differences between Z1, Z2, and Z3 access in Germany in the next blog post in this series.)
Key Considerations: DART is designed specifically for tax audit responses. Back in the old days of the Millennium, I attended course BC680 “Data Retention Tool”. There were two IRS agents in the classroom. If your company has ever received an IRS Information Document Request, or IDR, formatting reads like a technical specification with explicit instructions for the data pull. Agents in non-U.S. countries are savvy in the ways of DART and know they will be able to perform transactional forensics within the tool. With consideration to these points, and taking into account the fact that DART updates to current requirements, if SAP is the “system of record” from which tax filings are derived, it is a reasonable conclusion that DART prepares the company to handle tax inspection requests.
Question: Where does DART align on the organizational chart?
When considering role assignments, remember that DART is designed to support government tax audits. Accountability through people, process, and procedure is one box you want checked in an audit request. Customizable “off-the-shelf” DART authorization templates create segregation of duties between roles and promotes company code-specific visibility. This is a key factor with mitigating risk and fostering process control and consistency. These are the key roles and associated responsibilities we recommend as a starting point:
This role is for an exclusive and small group in order to minimize security concerns and ensure consistency in the DART model. Administrators have deep knowledge and actual experience across functional and technical areas, and, ideally, have received focused DART training. Admins are responsible for the overall processing and quality control of DART extracts, file management, and customizations.
DART Functional Support
We have seen more often than not that our customers align this support with the “FI/Tax” team and/or the business analyst talent pool. DART Functional Support team members are empowered to read and perform validity checks on pre-existing extract files to support audit information requests. People in this role can also create DART “Views,” such as reports to support audits.
DART View User, Including FI/CO and Tax Business Users
We see this role assigned the least; however, it often serves a valuable purpose within organizations. Specifically, it enables self-service when restrictions for company code data access is important at the local level and when end users are on the front lines of receiving the initial audit information request.
This title applies to external and internal auditors who log on and perform data inquiries in your SAP system. (Look for details on this role in our next blog post.)
Key Considerations: Sustainable practices are built on a consistent knowledge base and defined roles and responsibilities for stewardship and future maintenance. Changes in organizational and support models can leave DART floating in the “wild space” of support, and, therefore, puts DART at risk of not being maintained as current and compliant. If DART has fallen into this state, and you’re not sure where to start, do two things first: 1) Identify where the roles currently exist in the support model; and, 2) Check the current version of DART.
In conclusion–for now–here’s an important consideration every business should keep in mind: Getting ahead of your next audit cycle will save your company from the “dark side” of scrambling to pull data for audit deadlines. We hope you’ve found this blog post helpful and invite you to come back to read our follow-up post on the topic in a few weeks. And if you’re looking for DART support, know that Simply ILM has extensive experience in delivering DART training, administration and user manual development, and otherwise navigating the complexities of support for the system and its note-based upgrades. Be sure to contact us with inquiries or to learn more about how we can help your organization in 2016 and beyond.