Separation of Duties, also known as Segregation of duties (SoD) is the concept of having more than one person required to complete a task or certain set of tasks. Therefore, SoD is an internal control intended to prevent fraud and error. From a financial perspective, the SoD concept prohibits the assignment of responsibility to one person for the acquisition of assets, their custody, and the related record keeping.

In other words, having adequate SoD in a financial process means properly assigning the handling of financial process controls/procedures among two or more competent and qualified individuals in a way that provides reasonable assurance for preventing fraud and error. More specifically, no one person should be able to initiate, record, authorize and reconcile a transaction.

In information systems, SoD also seeks to prevent fraud and error, with access control being the main driver for ensuring only authorized personnel have access to specific information systems. Additionally, SoD in information systems requires the adoption of Role Based Access Control (RBAC), for which the concept of least privilege is used, which is the following: Providing a user and the associated user account only those necessary and minimum privileges that are essential for a user to perform his/her functions within a given information system.

Best practices for implementing information security segregation of duties for ISO/IEC 27001 when developing an ISMS include the following:

• Define Clear Roles and Responsibilities: Clearly define and document the roles and responsibilities of each individual involved in information security. This includes identifying specific tasks and access privileges associated with each role.
  
  
• Separate Administrative and User Functions: Avoid combining administrative functions (e.g., user provisioning, access management) with regular user functions. This reduces the risk of individuals abusing their privileges for malicious purposes.
  
  
• Implement Least Privilege: Follow the principle of least privilege, which means granting individuals only the minimum access rights necessary to perform their duties. This ensures that individuals have access to the information they need for their roles and nothing more.
  
  
• Rotation of Duties: Implement job rotation or periodic role changes for employees in critical positions. This practice helps prevent employees from becoming too comfortable with potential opportunities for misuse.
  
  
• Two-Person Control: For highly sensitive operations or critical tasks, consider requiring two or more authorized individuals to be present or involved in the process. This can help prevent unauthorized activities and provide oversight.
  
  
• Regular Audits: Conduct regular audits and reviews of access controls, permissions, and activities to identify any potential violations of segregation of duties.
  
  
• Monitor Privileged User Activities: Implement monitoring and logging mechanisms for privileged users' activities. This allows for the detection of suspicious or inappropriate behavior.
  
  
• Automate Access Control: Use automated identity and access management tools to streamline access provisioning, revocation, and permission changes. Automation reduces the likelihood of manual errors and unauthorized access.
  
  
• Role-Based Access Control (RBAC): Adopt Role-Based Access Control systems to assign permissions based on job roles. RBAC ensures that access rights are tied to specific job functions, simplifying the management of access privileges.
  
  
• Regular Training and Awareness: Educate employees about the importance of segregation of duties and the potential risks associated with its violation. Encourage a culture of security awareness within the organization.
  
  
• Incident Response and Reporting: Establish clear incident response procedures and reporting channels to handle any potential security breaches or violations promptly.
  
  
• Third-Party Access: If third-party vendors or contractors have access to sensitive systems or data, ensure proper controls are in place to monitor and limit their access based on their specific responsibilities.

What organizations need to have in place is a well-defined policy for ISO/IEC 27002:20222 | 5.3 - Segregation of Duties. With MorganHill, our ISMS 5.3 segregation of Duties Policy and Procedures templates includes the following sections:

• Information Security Roles and Responsibilities | SoD – Information Systems.
• Information Security Duties and User Departments & Users of Systems.
• Development, Testing and Production Environments.
• Development/Testing and Production Environment SoD Matrix.
• Development and I.T. Operations.
• Database Administrator and I.T. Administrative Duties.

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