Create separation and termination processes
Summary
These are processes for ending an individual’s or entity’s engagement or involvement with an organisation.
Why this countermeasure matters
Unclear or inconsistent separation and termination processes may lead to:
- insider threats
- dysfunctional workplace cultures
- fraudsters being reemployed.
How to put this countermeasure in place
Some ways to implement this countermeasure include creating separation and termination processes like:
- separation checklists and reporting for all staff and contractors
- terminating staff or contractors for fraud or misconduct
- cancelling registrations if providers are found to be involved in fraud or misconduct
- expelling suppliers from a procurement panel due to fraud or misconduct.
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure using the following methods:
- Review processes/guidelines for termination/separation.
- Confirm that staff members, contractors or providers would be terminated or expelled for fraud/non-compliance.
- Confirm that data is captured and reported for all terminations involving fraud/misconduct.
- Identify cases where staff members, contractors or providers have been terminated for fraud/non-compliance.
- Confirm processes are adhered to and reported on by making sure:
- assets are returned
- system access is revoked
- building access is revoked (passes are returned)
- information, documentation and intellectual property is protected.
- Confirm that reasons for termination are recorded by keeping a permanent record for the customer, staff member, contractor, provider or supplier.
- Confirm that termination reasons are shared with other parties with a need-to-know such as informing other organisations or programs of:
- serious or organised fraud
- staff/contractor/vendor terminations for fraud/misconduct.
Related countermeasures
This type of countermeasure is supported by the below countermeasures:
Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.
Assess the integrity of new employees, contractors or third parties such as by having entry level checks, probationary periods, suitability assessments or security vetting.
Collaborate with strategic partners such as other government entities, committees, working groups and taskforces. This allows you to share capability, information and intelligence and to prevent and disrupt fraud.
Develop clear instructions and guidance for activities and processes, such as instructions for collecting the right information to verify eligibility or entitlements, procedures to help staff apply consistent and correct processes and guidance to help staff make correct and ethical decisions.
Provide staff with adequate training to increase likelihood that correct and consistent processes and decisions will be applied.
Make sure requests or claims use a specific form, process or system for consistency.
Have processes in place to properly archive or dispose of old or unnecessary systems, assets, staff positions and accesses, client accounts and records.
Create lists to quickly compare information to automate or require further actions.
Put protections in place to prevent data from being manipulated or misused.
Collect and analyse data to improve processes and controls, increase payment accuracy and find and prevent non-compliance, fraud and corruption.
Conduct quality assurance activities to confirm that processes are being followed correctly and to a high standard.
Report on incidents or breaches to help identify if further investigation is required. Clients, public officials or contractors can take advantage of a lack of reporting and transparency to commit fraud, act corruptly and avoid exposure.
Conduct internal or external audits or reviews to evaluate the process, purpose and outcome of activities. Clients, public officials or contractors can take advantage of weaknesses in government programs and systems to commit fraud, act corruptly, and avoid exposure.
Capture documents and other evidence for requests, claims and activities to detect, analyse, investigate and disrupt fraudulent activity.
Investigate fraud in line with the Australian Government Investigation Standards (AGIS).
Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs.
Related Fraudster Personas
This countermeasure helps prevent, detect or respond to the following Fraudster Personas:
