Divide duties between staff
Separate duties by allocating tasks and associated privileges for a business process to multiple staff. This is very important in areas such as payroll, finance, procurement, contract management and human resources. Systems help to enforce the strong separation of duties. This is also known as segregation of duties.
Why this countermeasure matters
Allowing a single person to perform all or multiple tasks within some processes may lead to:
- fraudulent payments
- unauthorised access, manipulation or disclosure of information
- poor management of decision-making and risk
- fraudulent requests or claims being processed
- the creation of fake vendors and fraudulent payments
- fraudsters concealing their activities.
How to put this countermeasure in place
Some ways to implement this countermeasure include dividing duties between the person who:
- creates and maintains vendor records and the person who processes invoices
- uses the credit card and the person who acquits and reconciles credit card payments
- approves grants and the person who processes the grant payments
- orders assets from suppliers and the person who confirms the delivery of the assets in the accounting system
- records the payroll information in the system and the person who verifies the calculation.
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure by using the following methods:
- Consult staff or subject matter experts about separating duties and processes, and confirm they have a correct understanding of their purpose.
- Confirm the existence of separation of duties within the system.
- Obtain and review requirements for how duties should be separated.
- Review procedures or guidance to confirm it clearly specifies where separation of duties should apply.
- Review processes for requests for user permissions. Confirm the request processes identify conflicts in separation of duties. Actively test processes if required.
- Confirm request and approvals processes are consistently applied.
- Confirm that someone cannot override or bypass separation of duties even when pressure or coercion is applied.
- Review reports of user permissions to confirm if a single person can complete multiple functions that should be separated.
- Review a sample of completed requests/claims to confirm the separated of duties were applied.
- Undertake ‘pressure testing’ or a process walk-through to confirm that separation of duties are enforced.
- Confirm the existence of a review and reconciliation process and review the reports.
- Review any past access breaches to identify how they occurred.
Legislation and policy can help prevent, detect and respond to fraud, such as by outlining clear rules, regulations and criteria, allowing entities to collect, use and disclose information and allowing entities to enforce penalties and recover fraud losses.
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.
Clearly document decision-makers using delegations, authorisations and instructions. Clearly defined decision-making powers increase transparency and reduce the opportunity for fraud and corruption.
Use declarations or acknowledgments to both communicate and confirm that a person understands their obligations and the consequences for non-compliance. The declaration could be written or verbal, and should encourage compliance and deter fraud.
Make sure requests or claims use a specific form, process or system for consistency.
Authenticate client or third party identities during each interaction to confirm the person owns the record they are trying to access.
Have clear and specific eligibility requirements and only approve requests or claims that meet the criteria. This can include internal requests for staff access to systems or information.
Make sure forms or system controls require mandatory information to support claims or requests.
Escalate non-standard requests or claims for further review or scrutiny. Non-standard requests or claims might include those that are late, do not meet normal conditions, include evidence that is difficult to verify (such as from overseas) or are for amounts that are higher than normal.
Apply limits on requests, claims or processes, such as maximum claim amounts or time periods. Enforce these limits using IT system controls.
Set up system prompts and alerts to warn users when information is inconsistent or irregular, which either requires acceptance or denies further actions.
Limit access to systems, data, information, physical documents, offices and assets.
Limit and control functionality within systems with user permissions. Assign permissions to users based on specific business needs, such as making high-risk functions limited to specialised users. The Protective Security Policy Framework sets out the government protective security policies that support this countermeasure.
Put protections in place to prevent data from being manipulated or misused.
Only allow certain types of claims to be processed by staff with a specific type of user permission or skillset.
Verify any requests or claim information you receive with an independent and credible source.
Require clients, staff and third parties to have ongoing compliance, performance and contract reviews.
Have processes in place to prevent, identify and correct duplicate records, identities, requests or claims.
Use system workflows to make sure all requests, claims or activities are approved only by the appropriate decision-maker.
Limit and monitor privileged system accesses (those that allow staff, contractors and providers to perform special functions or override system and application controls). The Protective Security Policy Framework outlines the government protective security requirements to safeguard information from cyber threats, including to restrict administrative privileges.
Change management processes make sure that changes do not create risks or weaken existing countermeasures.
Conduct system testing to identify vulnerabilities prior to release. Untested systems can allow vulnerabilities to be released into production environments.
Have processes in place to properly archive or dispose of old or unnecessary systems, assets, staff positions and accesses, client accounts and records.
Conduct quality assurance activities to confirm that processes are being followed correctly and to a high standard.
Prepare summary reports on activities for clients, managers or responsible staff.
Establish exception reports to identify activities that are different from the standard, normal, or expected process and should be further investigated.
Internal or external audits or reviews 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.
Automatically notify clients or staff about high-risk events or transactions. This can alert them to potential fraud and avoid delays in investigating and responding to fraud.
Fraud detection software programs automatically analyse data to detect what is different from what is standard, normal or expected and may indicate fraud or corruption.