We went through a number of years ago and had to change the way that we worked.
We had to "mandate" that all developers used our trouble ticket system to "input changes" that were being planned. This allowed us to show audit that the change was planned, coupled with the change mgmt reports showed that the changes were also approved.
We did this for all systems not just those under SOX testing (control).
Of course this assumes that you have a Trouble ticket system. At a minimum, you might be able to use the minutes from your change management meetings (again, hopefully you have these).
Anyone else?
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