What is Separation of Duties (SoD)

Separation of Duties (SoD) is a key concept of internal control and the basic principle of cybersecurity that mitigates fraud, error, and abuse of authority by splitting key duties among different individuals. Instead of a single person having complete autonomy, SoD ensures that one person doesn't have control over the process of which could result in serious damage to the organization if processed incorrectly (either on purpose or by accident).

An analogy for SoD is building a car: person A designs the engine, person B builds the parts, person C assembles the parts, and person D performs quality assurance. No one person can move the whole process along without oversight. In the digital space, SoD is when an individual performs work that involves significant risk to the organization and no one else reviews or the risk is separated among individuals. The SoD principle requires two or more individuals to "collude" in order for a fraudulent act to take place or for a major error to happen without detection.

Idea behind SoD

• Checks and Balances: Creates built-in checks and balances. The action of one person is reviewed, or called upon, with the action of another.

• Risk Reduced: By preventing one person from having "end-to-end" control of a sensitive process significantly reduces fraud, error or sabotage.

• Accountability: Duties clearly delineated allow for easy identification of where process broke down [Consider: "processes broke down"].

Common Examples of SoD

• Financial Processes:

  • The person who approves vendor invoices should not be the person who processes the payments.

  • The person responsible for recording cash receipts should not be responsible for depositing cash in the bank.

• IT and System Admin:

  • The person responsible for managing user accounts should not also be responsible for IT security audits of those accounts.

  • The developer who writes code should not also be responsible for deploying code directly to the production environment.

• Data Management:

  • The person responsible for entering data should not also be responsible for approving changes in sensitive databases.

The Importance of Separating Duties for Modern Security

In today's digital world, where information is king and threats are at every turn, SoD is not just a best practice - it's a tenet of security, regulatory compliance, and stakeholder trust. Without SoD, organizations are handing over significant risk on a silver platter.

Here's why implementing strong SoD is necessary:

• Reduces Fraud and Embezzlement: This is the historical main purpose of SoD. By requiring multiple people to complete a financial transaction, it effectively prevents one person from stealing cash or tampering with records for monetary gain.

• Reduces Error and Mistakes: When there are multiple sets of eyes on a process, or when multiple people periodically perform the steps in the process independently, the chance that one human error can turn into a large problem is significantly reduced. It builds quality into the workflow.

• Mitigating Insider Threat: Whether due to malicious intent or simply negligent behavior, SoD limits an insider's ability to create chaos. If one individual goes rogue, there will always need to be another collaborator before that individual can destroy data, elevate their level of access, or attack a key system.

• Supports Regulatory Compliance: Almost every significant regulatory environment – GDPR, HIPAA, SOX, and NIST (to name a few) – either clearly describes or implies Separation of Duties. Implementing SoD is easily recognizable for reviewers, and simply provides clear evidence that adequate controls are in place to alleviate crippling fines and legal repercussions.

• Supports Least Privileged Access (LPA): SoD is complementary to LPA. While LPA will limit what one individual can do, SoD will limit what any one individual can do in the larger, sensitive process. They work together, to ensure that no single person creates a single point of failure (in access control).

• Operational Transparency: SoD allows organizations to break complicated tasks down and assign clarity. Tasks become more measurable, and organizations are able to understand workflows, track progress and bottlenecks, and ultimately understand where sensitive processes are happening.

• Auditability: During an audit review, separation of duties creates clarity. Auditors can more easily understand who did what, when, and to what point the individual was responsible for completing tasks. Discrepancies or security incidents become much easier to trace.

• Compromised Identities: In the current world of identity-based attacks, even if an adversary compromises one users [Typo: "user's"] credentials, SoD mitigates how deep the adversary gets because they won't have all the pieces needed to complete a high-risk operation.

ReShield knows that strong Identity Governance and Administration (IGA) is key to effective Separation of Duties Control. Our platform enables organizations to define, manage, and monitor SoD policies for all human and non-human identities, across all software and business unit systems responsibilities. Our abilities provide clear visibility, clear relationships, and alerting on policy violations to better enable you to proactively eliminate conflicts of interest, mitigate risks, and create a true resilient security posture capable of withstanding the most advanced threats, and robust compliance requirements.