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A.5.3 Segregation of Duties

Purpose​

The purpose of this procedure is to ensure that roles related to information security and information systems management are appropriately segregated to prevent conflicts of interest, reduce the risk of errors or fraud, and ensure effective distribution of responsibilities.

Scope​

This procedure applies to all work processes within the organization, including the development, maintenance, and operation of information systems, risk management, and handling of information security incidents.

Definitions​

  • Segregation of Duties: The division of tasks and responsibilities among multiple individuals or roles so that no single person is responsible for the entire process from start to finish.
  • Conflict of Interest: A situation where an individual with authority or responsibility may be influenced by personal or external interests, potentially compromising organizational decisions.

Responsibility​

  • Organization Management:
    • Responsible for establishing a segregation of duties policy and ensuring its implementation.
    • Provides the necessary resources to ensure effective segregation of duties.
  • Information Security Officer:
    • Responsible for developing, managing, and supervising the segregation of duties within the organization.
    • Ensures sufficient segregation between critical roles to mitigate risks.
  • Unit Managers:
    • Responsible for implementing the segregation of duties policy in their units.
    • Ensure that employees perform their roles according to segregation guidelines.
  • Organizational Employees:
    • Required to act in accordance with the segregation of duties guidelines and report any potential conflicts of interest.

Process​

1. Identifying Critical Roles and Processes​

  • The organization will identify critical roles and processes where segregation of duties is required, particularly in areas prone to conflicts of interest or dangerous concentrations of authority.

2. Task and Responsibility Allocation​

  • The Information Security Officer, along with organizational management, will ensure that tasks and responsibilities are divided among multiple roles or individuals, as needed, to prevent dangerous concentrations of authority.

3. Controls and Safeguards​

  • The organization will establish controls and monitoring mechanisms to ensure that segregation of duties is maintained, including systems to monitor and verify the implementation of these guidelines.

4. Training and Education​

  • The organization will provide training and education to employees regarding the segregation of duties policy, including the importance and benefits of maintaining this separation.

5. Monitoring and Review​

  • The Information Security Officer will conduct periodic audits to ensure that segregation of duties guidelines are being followed.

6. Reporting Exceptions​

  • Any employee or manager is required to report any suspicion of conflicts of interest or breaches of the segregation of duties policy to the Information Security Officer.

Notes​

  • The organization will conduct periodic assessments of segregation of duties processes and update the policy as necessary to accommodate changes in the work environment or technologies used by the organization.
  • The segregation of duties policy will be a part of the organization’s risk management program.