Managing Segregation of Duties (SOD) in R3 Session Code: 808 Donnie Looper, Eastman Chemical Company Jasvir Gill, Virsa Systems

Goals of this session: Managing Segregation of Duties What is SOD? SOD Challenges SOD Solutions SOD Best Practices Questions/Discussion

What is SOD? Managing Segregation of Duties SOD - “Segregation of Duties” –Most definitions include something along the lines of: “Internal controls intended to prevent or reduce the risk of errors/fraud, identify problems, and ensure corrective action is taken.”

What is SOD (continued) ? Managing Segregation of Duties SOD objectives: –Avoid conflicting access and reducing risk of fraud –Ensuring system stability/integrity is not at risk. Examples of SOD’s: –Create a Vendor & pay a Vendor –Process Sales Orders & Rebates Mitigating Controls (Compensating Controls): –Accept risk for situations (i.e. limited staff) by running specialized reports or developing additional controls.

Goals of this session: Managing Segregation of Duties What is SOD? SOD Challenges SOD Solutions SOD Best Practices Questions/Discussion

SOD Challenges: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Challenges: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) –How do you build a good set of data relevant to your needs? –How do you upgrade SOD rules in the future?

SOD Challenges: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Challenges: Managing Segregation of Duties Automating SOD Analysis –How can you automate SOD analysis at all levels (User, Role, Profile, Composites)?

SOD Challenges: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Challenges: Managing Segregation of Duties Proactive/Ongoing SOD Compliance –How do you ensure that once your system is clean it remains clean (free of SOD issues)?

SOD Challenges: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Challenges: Managing Segregation of Duties Documenting Mitigating Controls –How do you automate Risk Mitigation Controls and use them in SOD analysis/resolution?

Goals of this session: Managing Segregation of Duties What is SOD? SOD Challenges SOD Solutions SOD Best Practices Questions/Discussion

SOD Solutions: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Solutions (Building SOD Rules): Managing Segregation of Duties Identify user community Management Support (Proactive) Rule Database starting point: –Vendor Supplied Rules –Internal Control Standards For Your Company –Information from Other Contacts (ASUG, etc…) Customizing rules to meet your needs Automate the development of rules

SOD Solutions: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Solutions (Automating SOD Analysis): Managing Segregation of Duties A tool is needed ( Ad hoc solutions don’t work) Tool must fully automate SOD analysis: – At the role level, user level, transaction code level and authorization object level. Tool must automate SOD rule definition, validation and customization. Tool should provide corrective analysis.

SOD Solutions: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Solutions (Ongoing SOD Compliance): Managing Segregation of Duties Ensure compliance when either roles are changed or assigned to users All additions and modifications should have “What-If” scenarios performed The tool should fully automate simulation and be based on live data (Users & Roles)

SOD Solutions: Managing Segregation of Duties Building/Upgrading SOD Data (Rules) Automating SOD Analysis Proactive/Ongoing SOD Compliance Documenting Mitigating Controls

SOD Solutions (Documenting Mitigating Controls): Managing Segregation of Duties Tool must provide: –Online definition and documentation of the mitigating controls –Capability to define: Controls at the User, Role or Rule Level Mitigation approvers and monitors Validity date for mitigation controls –Analysis with/without mitigation controls

Goals of this session: Managing Segregation of Duties What is SOD? SOD Challenges SOD Solutions SOD Best Practices Questions/Discussion

SOD Best Practices: Managing Segregation of Duties Identify and resolve issues at the earliest phase possible. –Once SODs creep into PRD they are more expensive and time consuming to resolve. Incorporate the use of the tool into your corporate processes and procedures –Changes should be simulated prior to submission. Rule definition process should be optimized –All objects aren’t needed all the time.

Goals of this session: Managing Segregation of Duties What is SOD? SOD Challenges SOD Solutions SOD Best Practices Questions/Discussion

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