Annex A 5.3 - Segregation of Duties

Description

Title of Control: Segregation of Duties

Introduction (what is it?): This control addresses the necessity of segregating conflicting duties and areas of responsibility within an organization. It aims to prevent situations where a single individual can perform actions that could potentially lead to fraud, errors, or circumvention of information security controls.

What is the purpose of it? The purpose of this control is to minimize the risk of fraudulent activities, errors, and unauthorized bypassing of security controls. By separating conflicting duties among different individuals, the organization aims to maintain the integrity of processes and strengthen its overall security posture.

What are the benefits of meeting these requirements? Meeting these requirements offers several benefits:

  • Risk Reduction: Segregating duties minimizes the potential for individuals to exploit their positions for fraudulent or malicious purposes.

  • Error Prevention: Conflicting responsibilities being separated helps reduce the risk of mistakes.

  • Control Strengthening: Segregation enhances the effectiveness of information security controls.

  • Accountability: Clearly defined responsibilities make it easier to track activities and hold individuals accountable.

  • Compliance: Adhering to segregation of duties helps meet regulatory and compliance requirements.

How difficult is this control to meet? The difficulty of meeting this control depends on the complexity of an organization's processes and the availability of personnel to fulfill segregated duties. It may be more challenging for smaller organizations, but applying the principle as much as possible is essential. If segregation is challenging, alternative controls such as monitoring, audit trails, and supervision should be considered.

What are the sub-requirements?

  1. Determine which duties and areas of responsibility require segregation.

  2. Identify activities prone to conflicts such as initiating, approving and executing changes, access rights management, code design and implementation, software development, application administration, database management, and security control assurance.

  3. Design segregation controls considering the possibility of collusion among individuals.

  4. Apply the principle of segregation as much as possible and practicable, even in smaller organizations.

  5. When segregation is difficult, consider alternative controls like activity monitoring, audit trails, and management supervision.

  6. Ensure that role-based access control systems do not grant conflicting roles to individuals.

  7. Use automated tools to identify and remove conflicts when there are a large number of roles.

  8. Carefully define and provision roles to minimize access issues if a role is modified or removed.

Other information:

  • Segregation of duties can be challenging for small organizations, but efforts should be made to apply the principle to the extent feasible.

  • Automation tools can aid in identifying and managing conflicting roles in role-based access control systems.

In conclusion, this control emphasizes the importance of segregating conflicting duties and responsibilities to reduce the risk of fraud, errors, and circumvention of information security controls. Proper segregation enhances accountability, control effectiveness, and compliance with security requirements.

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