SoD Documentation Responsibility for Contents: SoD Coreteam (C. Twehues) Classification: Internal Version: Version 1.93 Subject and Purposes This document describes the operational concept of the implementation of Segregation of Duties (SoD) at Henkel. Distributed by: 20130923 SoD Documentation v1.93.doc Project SIGMA Pages : 111 Enclosures : 5 SoD Documentation Content 1 Management Summary ........................................................................................... 6 1.1 Scope and Target Group of Current Document ............................................... 6 1.2 Definition Segregation of Duties (SoD) ............................................................ 6 1.3 Scope of SoD .................................................................................................. 6 1.4 Definition Identity & Access Management (IAM) ............................................. 6 1.5 Scope of IAM ................................................................................................... 6 1.6 Definition Authorization Concept ..................................................................... 7 2 General Terms ......................................................................................................... 8 2.1 User ................................................................................................................. 8 2.2 User-ID ............................................................................................................ 8 2.3 Access Rights .................................................................................................. 8 2.4 Authorizations .................................................................................................. 8 2.5 Enterprise Roles .............................................................................................. 8 2.6 Business Roles ................................................................................................ 8 2.7 Transaction ...................................................................................................... 8 2.8 Technical Authorization Objects ...................................................................... 9 2.9 SoD Risk ......................................................................................................... 9 2.10 SoD Risk Levels (Colour Coding) .................................................................. 10 2.11 SoD Conflict .................................................................................................. 10 2.12 Dangerous Combinations of Roles ................................................................ 10 2.13 Critical Transactions ...................................................................................... 11 2.14 Critical Roles ................................................................................................. 11 2.15 Need-to-Know Principle ................................................................................. 11 2.16 Preventive Controls ....................................................................................... 11 2.16.1 Segregation of Duties Controls ........................................................................................ 11 2.16.2 Built-In Controls ............................................................................................................... 11 2.17 Detective Controls ......................................................................................... 12 2.17.1 Compensating Controls ................................................................................................... 12 2.18 Privileged Authorizations ............................................................................... 12 2.19 Explanation of Process Flows (Swim Lane Charts) ....................................... 12 3 Roles & Responsibilities ...................................................................................... 14 3.1 HR ................................................................................................................. 14 3.2 Employee ...................................................................................................... 14 3.3 Supervisor of Employee ................................................................................ 14 3.4 Contractor...................................................................................................... 14 3.5 External Company ......................................................................................... 14 3.6 Person In Charge .......................................................................................... 14 3.7 Supervisor of Person In Charge .................................................................... 14 3.8 IT Coordinator................................................................................................ 15 Page 2 of 111 Version 1.93 Classification: internal SoD Documentation 3.9 3.10 3.11 3.12 3.13 3.14 User Administrator ......................................................................................... 15 Help Desk ...................................................................................................... 15 SoD Council .................................................................................................. 15 SoD Compliance Manager ............................................................................ 15 Business Process Owner .............................................................................. 15 Role Owner ................................................................................................... 16 3.14.1 Tasks of the Global Role Owner ...................................................................................... 16 3.14.2 Tasks of the Local Role Owner ........................................................................................ 16 3.15 Role Administrator (Role Admin) ................................................................... 16 3.15.1 Tasks of the Role Admin (SPOC) .................................................................................... 16 3.15.2 Tasks of the Role Admin (Assignment Approver) ............................................................ 16 4 Identity & Access Management Processes ......................................................... 17 4.1 User ID Administration ................................................................................... 17 4.1.1 4.1.2 4.1.3 4.2 User Authorization Administration ................................................................. 26 4.2.1 4.2.2 4.2.3 4.2.4 4.3 Define Role Owner (IAM-400) ......................................................................................... 38 Define Role Administrator (IAM-401) ............................................................................... 39 Review Role Ownership (IAM-410) ................................................................................. 39 Review Role Administrators (IAM-411)............................................................................ 40 Compliance Controls User Authorization Ownership ...................................................... 40 SoD Compliance Control ............................................................................... 41 4.5.1 4.5.2 4.5.3 4.5.4 4.6 Create Role (IAM-300) ..................................................................................................... 32 Change Role (IAM-301) ................................................................................................... 33 Delete Role (IAM-302) ..................................................................................................... 33 Pre-Authorized Role Change (IAM-303) .......................................................................... 34 Review Obsolete Roles (IAM-310) .................................................................................. 35 Compliance Controls User Authorization Configuration .................................................. 35 User Authorization Ownership ....................................................................... 38 4.4.1 4.4.2 4.4.3 4.4.4 4.4.5 4.5 Assign Roles (IAM-200) ................................................................................................... 26 Remove Roles (IAM-201): Overview ............................................................................... 28 Reapply Role Assignment (IAM-210) .............................................................................. 29 Compliance Controls User Authorization Administration ................................................. 30 User Authorization Configuration ................................................................... 32 4.3.1 4.3.2 4.3.3 4.3.4 4.3.5 4.3.6 4.4 HR Processes Joiner - Mover – Leaver .......................................................................... 17 User ID processes ........................................................................................................... 20 Compliance Controls........................................................................................................ 24 Check Compensating Control (IAM-500) ......................................................................... 41 Approve SoD Exception (IAM-501) .................................................................................. 42 Review SoD Exceptions (IAM-510) ................................................................................. 42 Compliance Controls........................................................................................................ 42 SoD Framework Governance ........................................................................ 43 4.6.1 4.6.2 4.6.3 4.6.4 4.6.5 Review Corporate Standard SoD (IAM-600) ................................................................... 43 Review SoD-relevant Transaction Directory (IAM-601)................................................... 44 Review SoD Permission Directory (IAM-602) .................................................................. 44 Reconciliation of SAP GRC Rule Sets (IAM-603) ........................................................... 45 Define Compensating Controls (IAM-604) ....................................................................... 45 Classification: internal Version 1.93 Page 3 of 111 SoD Documentation 4.6.6 5 SoD Governance ................................................................................................... 47 5.1 Elements and Structure of the SoD Framework at Henkel ............................ 47 5.1.1 5.1.2 5.1.3 5.2 5.3 SoD Framework ............................................................................................................... 47 SoD Tools ........................................................................................................................ 48 SoD KPI and Reporting.................................................................................................... 48 Naming Conventions of the SoD Framework at Henkel ................................ 48 5.2.1 5.2.2 5.2.3 5.2.4 Rule Sets ......................................................................................................................... 48 Access Risks .................................................................................................................... 49 Functions ......................................................................................................................... 49 Risk Descriptions ............................................................................................................. 50 Governance of the SoD Framework .............................................................. 51 5.3.1 5.3.2 5.3.3 5.3.4 5.3.5 6 Compliance Controls SoD Framework Governance ........................................................ 46 Governance Bodies ......................................................................................................... 51 Corporate Standard Segregation of Duties (CS SoD) ..................................................... 51 SoD Relevant Transaction Directory ............................................................................... 52 SoD Permission Directory ................................................................................................ 52 SAP GRC AC Rule sets ................................................................................................... 53 Authorization Concept (TO BE REVIEWED) ....................................................... 57 6.1 Requirements of Authorization Concept ........................................................ 57 6.1.1 6.1.2 6.2 6.3 General Requirements ..................................................................................................... 57 Technical Requirements .................................................................................................. 58 Dependencies to other Processes ................................................................. 58 Technical Authorization Concept ................................................................... 58 6.3.1 Definition of Terms ........................................................................................................... 58 6.3.2 Background Information ................................................................................................... 59 6.3.3 General Structure of Authorization Concept .................................................................... 60 6.3.4 Domains and their usage ................................................................................................. 63 6.3.5 Naming Convention ......................................................................................................... 68 6.3.6 Future mode of operation and maintenance .................................................................... 71 6.3.7 SU24 ................................................................................................................................ 76 6.3.8 Customer specific authorization objects .......................................................................... 77 6.3.9 Authorization Groups ....................................................................................................... 77 6.3.10 Further Restrictions .......................................................................................................... 78 6.3.11 Current Business Roles ................................................................................................... 78 6.3.12 Emergency procedure : Quickfixes .................................................................................. 80 7 Software (TO BE UPDATED) ................................................................................ 83 7.1 Overview of SoD Tool Landscape ................................................................. 83 7.2 Tools.............................................................................................................. 84 7.2.1 7.2.2 7.2.3 7.2.4 7.3 SAP GR AC – Access Control ......................................................................................... 84 COCOS – Compensating Control System ....................................................................... 85 BIC – SAP ERP Built-in Controls ..................................................................................... 87 RAP – Reapply Roles ...................................................................................................... 87 Operational Model ......................................................................................... 89 7.3.1 Page 4 of 111 Tool Ownership ................................................................................................................ 89 Version 1.93 Classification: internal SoD Documentation 7.3.2 7.3.3 8 Reporting & KPI ..................................................................................................... 90 8.1 Global SoD Anaylsis (GSODA) ..................................................................... 90 8.1.1 8.1.2 8.2 KPI definition .................................................................................................................... 90 Scope ............................................................................................................................... 90 System SoD Analysis (SSODA) .................................................................... 91 8.2.1 8.2.2 9 Incident Management Regulations .................................................................................. 89 Change Management Regulations .................................................................................. 89 KPI definition .................................................................................................................... 91 Scope ............................................................................................................................... 91 Training & e-Learning ........................................................................................... 93 9.1 SoD Portal Page ............................................................................................ 93 9.2 SoD Forum .................................................................................................... 93 9.3 Training ......................................................................................................... 94 9.3.1 9.3.2 9.3.3 CUP tool ........................................................................................................................... 94 RAR tool ........................................................................................................................... 94 COCOS tool ..................................................................................................................... 95 10 Appendix ................................................................................................................ 96 10.1 FAQ ............................................................................................................... 96 10.2 Glossary ........................................................................................................ 96 10.3 Acronyms .................................................................................................... 101 10.4 Enclosures ................................................................................................... 105 10.4.1 SoD Governance ........................................................................................................... 105 10.4.2 Authorization Management ............................................................................................ 107 10.5 Revision History and Document Reviews .................................................... 108 Classification: internal Version 1.93 Page 5 of 111 SoD Documentation 1 Management Summary 1.1 Scope and Target Group of Current Document This document describes the operational model of the processes, tools, and the governance of the Segregation of Duties concept at Henkel. Target Group of this document is - The maintenance and enhancement team in IT - Future projects like Horizon and others that implement changes in the SoD relevant business processes 1.2 Definition Segregation of Duties (SoD) Segregation of duties (SoD) is the concept of having more than one person required to complete a task. Besides organizational measures this includes the segregation of access rights to and authorizations within the corresponding IT systems. The SoD Framework is a set of rules that defines which combinations of functions have to be segregated in a business process in order to mitigate the risk of fraud and erroneous transactions. 1.3 Scope of SoD The present SoD framework focuses on the business processes Order-to-Cash (OTC) and Purchase-toPay (PTP). The SoD framework was defined independent of the underlying IT systems and has a global scope. 1.4 Definition Identity & Access Management (IAM) IAM is an administrative area that deals with identifying individuals in a system (such as a country, a network or an organization) and controlling the access to resources in that system by placing restrictions on the established identities. 1.5 Scope of IAM IAM in the context of this document is limited to controlling the access to and authorization within IT Systems. The Scope of IAM is global. IAM at Henkel consists of three main areas: Identity Management (IdM): Definition: Process and tool landscape for managing the lifecycle of user-IDs and their relationship to persons. Services: User administration, IAM Request Mgmt, IAM-Reports Authorization Management: Definition: Management of compliant authorizations of users within IT systems, e.g. SAP. Services: SAP Authorizations, Emergency Procedures, IT-based non-SAP Authorizations Page 6 of 111 Version 1.93 Classification: internal SoD Documentation Compliance Control: Definition: Monitoring of compliance to external and internal regulations in the use of IT systems Services: Compliance Checks & Reports, Support of VIA and external Audit, Compliance awareness, Compensating Control Setup 1.6 Definition Authorization Concept The Authorization Concept describes the structure and design of authorizations to users. An authorization concept is defined in Enterprise Roles and Business Roles in business terms, as well as a translation into technical terms, i.e. transactions and authorization objects within an IT system (Technical Authorization Concept). Classification: internal Version 1.93 Page 7 of 111 SoD Documentation 2 General Terms 2.1 User A user is a person in a company that uses an IT system. 2.2 User-ID A user-ID (also called user account) identifies a user (employee or Contractor) within the company by the username. It allows one to authenticate to IT systems. It also generally provides one with the opportunity to be authorized to access them. 2.3 Access Rights A user needs a user-ID and a password, and access rights assigned to the user-ID to be able to enter IT systems or applications. This authentication does not automatically imply authorization within the IT system. It’s like the “key to the main entrance of a building”. 2.4 Authorizations Authorizations (also privileges, entitlements, permissions) determine what a user can do on the system, once authenticated with user-ID and password. Authorizations enable users to use certain functionality or to display information of the IT system. Authorizations are like “keys to doors within a building”. 2.5 Enterprise Roles Enterprise Roles define access rights and authorizations within the entire enterprise, i.e. across IT systems and applications. 2.6 Business Roles Business Roles (or Roles in this context) define groups of authorizations within an IT system in business terms. Roles contain the authorizations that a user needs to work. Role Administrators grant authorizations to employees or external staff (users) by assigning specific Roles to their user-IDs. 2.7 Transaction A transaction in SAP is like a program in normal computer languages, and is identified by a four-character transaction code. A transaction can be initiated directly from the command field on the presentation interface or from the corresponding menu option. There are two kinds of transactions: report and dialog transactions. - Report transactions are SAP programs that collect selection parameters from the selection screen followed by the output called the lists. - Dialog programs consist of more than one interactive screen called a dynpro. These transactions sometimes also need pre-selected information for triggering them, not unlike the explicit selection screens in report programs; these are called parameter transactions. Page 8 of 111 Version 1.93 Classification: internal SoD Documentation 2.8 Technical Authorization Objects Technical Authorization Objects define authorizations to technical objects within an IT system. These objects can be e.g. SAP tables, plants, sales organization, etc. With the help of Technical Authorizations Objects user access can be restricted to a limited organizational area of responsibility. The functional area of responsibility described in four layers: Role BuildingisPrinciple Σ Business Roles Profile e.g. Customer Service Business Roles e.g. Order Management Function e.g. Display Master Data, Sales Doc Processing, Delivery Processing Transactions e.g. BU01, BU05, BU06, etc. Henkel / Project SIGMA 15-Apr-2010 2 The four layers are: 1. Transactions: SAP standard and Z-transactions 2. Function: Transactions grouped together with restrictions (org. limitations…) 3. Business Roles: Functions grouped together 4. Profile: Business roles grouped together SAP Profile: not shown in the above picture, i.e. the technical implementation of a Function. 2.9 SoD Risk The SoD Framework (see chapter 10.4: “Enclosures”) defines combinations of duties as “High” or “Very High” risk. These potential combinations are called SoD Risks. The combinations are marked in the SoD matrix as “High” or “Very High” and are described in the SoD Risk Register with examples. Classification: internal Version 1.93 Page 9 of 111 SoD Documentation 2.10 SoD Risk Levels (Colour Coding) The SoD Framework classifies the risks due to missing SoD in four categories: Red, Orange, Yellow, and Green.: Color Code Risk rating Green No risk in the defined sense of SoD, i.e. no damage/loss possible Control requirements for mitigation of SoD risks Control requirement for mitigation of risks due to Critical Functions No controls required No controls required Yellow Low risk, i.e. damage/loss is unlikely to happen and would only be immaterial No controls required No controls required Orange High risk, i.e. damage/loss is reasonably possible to happen and would result in a material impact Either SoD or Compensating Controls required Compensating Control mandatory Red Very High risk, i.e. damage/loss would be probable to happen and could result in a material or even severe impact SoD mandatory The Critical Function must only be executed by dedicated and named personnel; Compensating Control mandatory 2.11 SoD Conflict A SoD conflict occurs, when a user actually has the authorization to conduct a combination of duties in a business process that is defined as a high or very high SoD Risk in the SoD Framework. Depending on the risk rating, SoD Conflicts can be neglected (low risk), or require approval (high risk, controlled with a Compensating Control). In case of very high risk, SoD conflicts are not allowed; the duties have to be segregated. 2.12 Dangerous Combinations of Roles The Authorization Concept uses Roles which group authorizations a user needs to execute business functions in an IT system. Objective is to ease the assignment of authorizations to users, but also to ensure that every user has exactly the authorizations he/she needs to perform business functions in a compliant way. Roles are designed not to have a SoD conflict within the role itself. I.e. every user with one role assigned shall be free of SoD conflicts. Only with the assignment of two or more roles to a user, a SoD conflict might occur. There exist pairs of Roles that contain duties that are marked as a SoD risk in the SoD framework. With the assignment of both Roles to a user, a SoD conflict occurs. The combination of these Roles is called a Dangerous Combination. Page 10 of 111 Version 1.93 Classification: internal SoD Documentation Example: Role “Procurement” and Role “Warehouse” are in itself free of SoD risks. The role “Procurement” contains among others the function “create purchase order” and the role “Warehouse” contains among others the function “book goods receipt”. The combination of these functions (“create purchase order” and “book goods receipt”) is a SoD risk identified in the SoD matrix. Thus assigning the two roles “Procurement” and “Warehouse” to a single user within the same organizational unit would lead to a SoD conflict. I.e. “Procurement” and “Warehouse” are a Dangerous Combination of Roles. 2.13 Critical Transactions Some single transactions have an inherent risk and are defined as critical transactions. Examples: - Technical transaction: Debugging with replace (prohibited by IT Security Policy in all cases) - Business transaction: Release of vendor payment block (only assigned to a limited number of well instructed users) 2.14 Critical Roles Some Roles might be critical in itself. Reasons might be: - Role that bear a SoD conflict in itself (defined exceptions) - Privileged authorizations for e.g. process owner, key user, etc - Collection of critical transactions in a critical role to control their assignment to users 2.15 Need-to-Know Principle The Need-to-Know Principle (also known as least user access, least-privilege, or least authority) describes a security concept, in which all users at all times should run with as few authorizations as possible, and also launch applications with as few access rights as possible. The principle is widely recognized as an important design consideration in enhancing the protection of data and functionality from faults (fault tolerance) and malicious behavior (computer security). 2.16 Preventive Controls 2.16.1 Segregation of Duties Controls The segregation of areas of responsibility in business processes and of corresponding authorizations, access rights, and built-in system behavior within the IT systems is called SoD Control. This is a preventive control against SoD-risks. 2.16.2 Built-In Controls A Built-in Control is a system behavior that prevents a user to conduct two functions that are defined as a SoD risk. This control is a Segregation of Duties, when certified as “proven security”. Example: A user has the authorization to create a purchase order and to book a goods receipt against purchase orders. A built-in control could be a user exit in SAP that blocks a user from booking a goods receipt against purchase orders, the user created him/herself. If it is proven that no user can by-pass the Built-In Control, this control is a valid Segregation of Duties. Classification: internal Version 1.93 Page 11 of 111 SoD Documentation 2.17 Detective Controls 2.17.1 Compensating Controls Compensating Controls are controls which compensate for missing segregations of duties (i.e. for approved SoD conflicts). These can be: - Ex-ante controls that prevent fraud e.g. “2-pairs-of-eyes”-principle at credit note processing. - Ex-post controls that allow detecting if unwanted events of SoD risks have occurred. Where automated systems provide basis information for detective controls, manual monitoring processes are required for review of this information. Example: An exception report is regularly provided by IT-application and lists the actual bookings by users with SoD-conflicts; the manager in charge is required to review this report timely and to sign-off the listed transactions retrospectively. 2.18 Privileged Authorizations Some users need access rights and authorizations beyond the usual scope or beyond the profile of the employee, in order to support others or other topics. Examples can be a Key User, a Business Process Owner, a temporary project member, etc. The Privileged Authorizations assigned in these cases require a special handling and controls beyond the usual control. 3 Remark: out of scope of project SIGMA. That means, until exceptional processes and/or controls are listed, privileged users are treated like regular users. Select Role (IAM-201) Information Technology 2.19 Explanation of Process Flows (Swim Lane Charts) Requester has to be supported to find the right Role. Example: Process “Select Roles” (IAM-201) Supervisor of Employee / Internal Responsible Person START Select Role Administrator from Directory Request Form plus free text Info Employee / External Person (User) Yes, from same Role Administrator Role Administrator selects Role Role Administrator Further Role necessary ? No ROLE SELECTED Yes, from different Role Administrator Select Role (IAM-201) Henkel / Project SIGMA / IAM Process Design Page 12 of 111 Version 1.93 16-Aug-2010 17 Classification: internal SoD Documentation Legend Process starter and terminator START Process flow Select Role Administrator from Directory Further Role necessary ? Process step Decision Info Document (e.g. mail) Select Role (2.1.3) Pre-defined process OUT IN Except ion Handli OR ng Connector for process flows across more than one document page Manual process Logical OR Split into parallel processes Join of parallel processes Role Administrator Responsible person for the process step (swim lane) Classification: internal Version 1.93 Page 13 of 111 SoD Documentation 3 Roles & Responsibilities 3.1 HR The HR department is responsible for all processes concerning the joining, moving or leaving of an employee within the Henkel organization. All employee master data is stored in the central GHR system. However, not in all cases HR is the starting point of IAM processes. In a lot of cases request for changes in access rights and authorizations are triggered from within the business organization. The lifecycle of Contractors at Henkel is out of scope of HR and covered by special IAM processes. 3.2 Employee A person who is hired to provide services to a company on a regular basis in exchange for compensation (contract of service employer/employee) and who does not provide these services as part of an independent business (contract for services employer/independent External Company). 3.3 Supervisor of Employee A Supervisor is the line manager of an employee (solid line) and responsible for the delegation of tasks to an employee. In this context the Supervisor is responsible to grant compliant access rights and authorizations to an employee (user). The Supervisor usually delegates this task to a Role Administrator. The Supervisor approves exceptions in case of SoD conflicts. If a Compensating Control is defined (e.g. an exceptions report that lists the actual transactions of a user with SoD-conflicts) the Supervisor has the responsibility to review and to sign off the listed transactions retrospectively. He/she might delegate this task. 3.4 Contractor A Contractor is a person who provides services to Henkel as part of an independent business (independent External Company). 3.5 External Company The company, the Contractor is working for. 3.6 Person In Charge By definition a Contractor does not have a line manager within Henkel. This role is taken over by a so called Person In Charge. Main tasks are the request of a user-ID and according authorizations for the Contractor. 3.7 Supervisor of Person In Charge The line manager of the Henkel-internal person who is responsible for a Contractor. Usually the Person In Charge approves assignments of access rights and authorizations to the Contractor, but in some cases Page 14 of 111 Version 1.93 Classification: internal SoD Documentation his/her Supervisor is required for a second approval. 3.8 IT Coordinator The IT Coordinator is a member of the business organization who supports employees in coordinating service requests (hardware, software procurement and installation). Often the request for user-IDs and access to systems goes along with these service requests and is managed by the IT Coordinator as well. 3.9 User Administrator The User Administrator is a member of the IT service unit User Admin. The User Administrator is responsible for managing the lifecycle of user-IDs. The User Administrator configures the Identity Management tools, processes requests for user-ID and role assignments, and runs periodic reviews of User ID validities. 3.10 Help Desk A help desk is an information and assistance resource that troubleshoots problems with computers or similar products. In the context of IAM the Help Desk is enabled to reset passwords within the password handling process. 3.11 SoD Council The SoD Council is the owner of the SoD Framework. Members are the global Business Process Owner. Chairman is the SoD Compliance Manager. The SoD Council approves changes to the SoD Framework, steers the implementation of SoD within the business processes, and serves as the escalation body when it comes to conflicts between business process efficiency and compliance objectives. The SoD Council meets on a quarterly basis. Periodic releases of the Corporate Standard SoD require approval of the Compliance & Risk Committee. 3.12 SoD Compliance Manager The SoD Compliance Manager is a member of the IT Governance organization. He/she is responsible for managing the SoD Lifecycle (driving the design and governance of the SoD Framework as chairman of the SoD Council, monitoring SoD compliance in the business processes at Henkel and coordinating follow-up activities). The SoD Compliance Manager is the process owner of IAM processes and tool landscape. 3.13 Business Process Owner The Business Process Owner (BPO) is responsible for the design of a specific business process. BPO are defined by Business Unit and Function at Henkel. Changes in end-to-end processes are coordinated between different process owners. The set-up of the Business Process Owner organization varies between the businesses/functions and processes. In some cases a global BPO but usually regional BPO are installed. The BPO define standard processes, steer the implementation of standard processes in IT systems in the regions, and steer the changes within processes and systems. The BPO usually work with local Key Users in the countries to design local process variants. In the context of IAM the Business Process Owner defines Role Owners, and triggers changes to Roles Classification: internal Version 1.93 Page 15 of 111 SoD Documentation with changing of the process design. The Business Process Owner defines, designs, and reviews Compensating Controls for Dangerous Combinations of Roles as well as for Critical Roles. The BPO might delegate this task to Role Owner(s). 3.14 Role Owner (to be moved to the ACC or ACC to link to this chapter?) The Role Owner is defined by the Business Process Owner. He/she defines the content of Business Roles, defines, designs, and reviews Compensating Controls for Critical Roles, clarifies SoD conflicts detected by automatic reviews on role design, and triggers the change management process for Roles. The Role Owner coordinates the nomination of Role Administrators and defines which roles a Role Administrator is enabled to assign to users. The Role Owner is typically a member of the Business Process Owner organization. 3.14.1 Tasks of the Global Role Owner - - definition and change management of global template authorization roles (master roles) - - nomination of Local Role Owners - - approval & delegation of local roles for specialties 3.14.2 Tasks of the Local Role Owner - derivation of global template roles to local domains - definition of local and derived roles - nomination of local Role Admins (key user concept) 3.15 Role Administrator (Role Admin) ACC to link to this chapter?) (to be moved to the ACC or The Role Administrator is defined by local Line Management. He/she assigns Roles to and removes Roles from users. The Role Administrator selects Compensating Controls for approved exceptions. The Role Administrator initiates changes to roles by requesting missing objects from the Role Owner. 3.15.1 Tasks of the Role Admin (SPOC) - contact for end user requests for authorizations - select roles according to the request - SoD cleaning of users - request changes to roles from Local Role Owners 3.15.2 Tasks of the Role Admin (Assignment Approver) - approval of role assignments Page 16 of 111 Version 1.93 Classification: internal SoD Documentation 4 Identity & Access Management Processes 4.1 User ID Administration (to be moved to the IDM document) This chapter describes the processes and compliance controls that support the life cycle of user IDs at Henkel, including the access to IT systems. This chapter is currently under review. The documented process flows reflect current practice. Prerequisite for User ID Administration is - HR Master Data entry in case of employees - Master data entry in the identity repository (HMD) for contractors - Tools to support the Identity Management processes (see chapter 7: “Software”). Some IAM processes start in HR, when a new employee joins the company, or an employee leaves the company. In other cases the IAM processes are triggered by supervisors or administrators within the organization. The Global HR system (GHR) stores all relevant master data of employees. The process of joining or leaving a company usually starts in HR, subsequent Identity and Access Management processes are triggered by HR. Contractors working at Henkel are not stored in the GHR system. Master Data for Contractors and External Companies are stored directly in the Henkel Meta Directory (HMD). 4.1.1 HR Processes Joiner - Mover – Leaver 4.1.1.1 Joiner (IAM-001) Supervisor of Employee / Person in charge START Employee/ Contractor (User) START Create User (IAM-100) Assign Roles (IAM-200) JOINED HR START Classification: internal Version 1.93 Page 17 of 111 SoD Documentation 4.1.1.2 Mover (IAM-002) A typical challenge for a company is the situation of employees frequently changing their duties. A higher risk exists, when these employees gather access rights and authorizations during their life cycle without removal of obsolete rights. It is especially the case for assignments in apprenticeship or internships or job rotations in different business functions. The trigger for removing authorizations shall come from the former and/or new Supervisor Supervisor of Employee Org A START Indicate “Employee Leaving” Supervisor of Employee Org B START Indicate “Employee Joining” RoleAdministrator Org A RoleAdministrator Org B Employee/ Contractor (User) Remove Roles (IAM-201) Set validity period for remaining “old” roles (overlap period) END Assign Roles (IAM-200) Info The Mover process is controlled by the following controls: 1. SoD risks of level very high (red) The CUP workflow ensures that no Mover has a red SoD conflict at any time. 2. SoD risks of level high (orange) Compensating controls approved by Supervisors ensure a second pair of eyes for all SoD risks (risk level red and orange). 3. Remaining risks (need-to-have principle, non-SoD relevant) Validity periods for authorizations: 24 month expiration of authorizations ensure a review on average within 1 year, latest after 2 years. The control of the remaining risk is to be ensured by Supervisors organisationally. No automatic trigger is required Page 18 of 111 Version 1.93 Classification: internal SoD Documentation 4.1.1.3 Leaver (IAM-003) HR System START Exit-Action within GHR Remove Roles (IAM-201) Supervisor of Employee Classification: internal Delete User (IAM-101) END Info Version 1.93 Page 19 of 111 SoD Documentation 4.1.2 User ID processes 4.1.2.1 Create User (IAM-100) Create User – After Entry Action (IAM-100A) HR START Entry-Action within GHR Only for countries where Master Data registration can be done before first working day ! 1. PERSON 2. USER User ID & Password Generation System Supervisor Supervisor can directly request additional authorizations for the Employee Info IT Coordinator Activate User Employee User/PasswordForm ENTRY END Create User – Before Entry Action (IAM-100B) User Administrator Employee START User ID & Password Generation 1. USER 2. PERSON ENTRY User/PasswordForm END Activate User IT Coordinator Use User for the Entry-Action ! No Dummies left in the system ! HR Page 20 of 111 For some countries it’s a legal restriction: HR Master Data registration not before first working day ! Entry-Action within GHR END Version 1.93 Classification: internal SoD Documentation Create User – External (IAM-100C) Requestor (anybody) Attach identifying attributes to a User + External Company START No Person in charge END Supervisor of Person in charge Approve ? Yes No END Approve ? External Company has to be informed because he signed the “Data Security Agreement” and is therefore responsible for his employee. External Company Info Create User System 4.1.2.2 Yes Approval ? END Delete User (IAM-101) Delete User – Internal (IAM-101A) HR START Exit-Action within GHR System (GHR) Leave-Date stored System (HAD/HMD) User-Blocking User Administrator Manual User-Blocking Supervisor START Classification: internal Delimit User User-Erasing DELIMITED DELETED In some cases the Exit-Action in HR is at the end of the contract (e.g. inactive period), but the user-ID needs to be blocked before-hand. Version 1.93 Page 21 of 111 SoD Documentation Delete User – External (IAM-101B) Requestor (anybody) START REJECTED Request for Deletion Person in charge No Approve ? START Yes Supervisor of Person in Charge External Company Info Delete User System 4.1.2.3 DELETED Block Inactive User (IAM-102) START System Employee/ Contractor (User) Supervisor of Employee / Person in charge Page 22 of 111 Periodical Check of User User Block Delete Never used 1 year 1 ½ years Used once 1 ½ year 2 years Delete Action ? Delete User USER REVIEWED Block Block User Info Info Version 1.93 Classification: internal SoD Documentation 4.1.2.4 Password Reset (IAM-103) Password Reset (IAM-103A) 2 Security Questions Help Desk Employee identified ? PasswordReset & Handover Yes No Password forgotten or entered wrong password Employee START Employee contacts Help Desk IT Coordinator Instructed to contact IT Coordinator personally Receives Initial Password Identifies Employee via Badge PasswordReset & Handover Creates personal Password END Password Reset – Self Service (IAM-103B) LOGIN ApplicationSelection LOGIN HELP START Login via - Corp. UID - Corp. Password HelpDocumentation CHANGE PASSWORD Employee LOST PASSWORD Change via - Corp. UID - Old Corp. Password - New Corp. Password - Confirm Password CHANGE PASSWORD Lost Password - Corp. UID RESET PASSWORD Yes Classification: internal Version 1.93 eMail successfully sent ? No Please inform Heldpdesk ! Page 23 of 111 SoD Documentation 4.1.2.5 External Company Handling (IAM-104) Person in charge Create/ Modify/Delete External Company START Supervisor of Person in charge No REJECTED Approve ? External Company 4.1.2.6 Yes CREATED Info User Access Review (IAM-110) START Daily System (HAD) Update of user access rights table in UAR System (UAR) END START Daily Select users with last review > 12 months + send mail Logging of review in HAD END Remove Access Rights END Yes Info Supervisor Review of User Access Rights Approve ? IT Coordinator No 4.1.3 Compliance Controls This list is not complete. Further and more specific controls are implemented in the processes. 4.1.3.1 Approval of User Requests (C14) Control C14: User administrators and Help Desk only act on valid and approved requests. Page 24 of 111 Version 1.93 Classification: internal SoD Documentation 4.1.3.2 Logging of User Requests (C13) Control C13a: Every user access request must be logged electronically. 4.1.3.3 User Access Review (C20) “Review of Obsolete User-IDs“ Control C20: Supervisors are to periodically review an overview of the users under their responsibility and identify obsolete users (leavers, retired staff etc.) Classification: internal Version 1.93 Page 25 of 111 SoD Documentation 4.2 User Authorization Administration (to be moved to the chapter 4.2. of ACC document) This chapter describes the processes and compliance controls that support the life cycle of user authorizations within the SAP systems that are in scope of SoD Compliance. Prerequisite is - User ID existing (see chapter 4.1: “User ID Administration”) - Business Roles configured in the process and tool landscape (see chapter 4.3: “User Authorization Configuration”). - Role Administrators defined (see chapter 4.4.2: “Define Role Administrator (IAM-401)”). 4.2.1 Assign Roles (IAM-200) The Role Assignment workflow requires a 1-step approval by the Role Administrator. The workflow blocks the assignment of SoD risks of level very high (red). All other SoD risks of level “orange” or lower are passed. Prerequisite: These conflicts are covered by Compensating Controls activated system-wide. Supervisor / Person in charge End User Info START On demand Role Admin (SPOC) Authorization Request IAM 200-1 Role Selection IAM 200-2 Info Reject/ Submit ? Request rejected Request submitted Role Admin (Assignment Approver) Role approval process per selected role (line items) Role Approval IAM 200-3 Role approval is finished when all roles are approved or rejected System (CUP) Page 26 of 111 Reject/ Approve ? Request rejected Request approved Provisioning In SAP Version 1.93 Yes Success? No Exception Handling Classification: internal END SoD Documentation 4.2.1.1 Assign Roles (IAM-200-1): Authorization Request Supervisor / Person in charge End User Input by End User: - Free text: required authorizations - Free text: reason - Select system - Select Role Admin (SPOC) = addressee Create Authorization Request START On demand Info Role Admin (SPOC) Role Admin (Assignment Approver) Next Workflow Stage (0 1) System (CUP) 4.2.1.2 END Assign Roles (IAM-200-2): Role Selection Supervisor / Person in charge End User Remediate Conflict Approve SoD Exception IAM-510 Exception Reject Request OR No Role Admin (SPOC) Check Request Info Request OK? Yes Select Roles Optional actions: - select/add different roles - assign/retain/remove role - set validity periods of role SoD Compliance Check Yes Red SoD Risk? Reject Request No Submit Request Role Admin (Assignment Approver) System (CUP) START Classification: internal Event: Authorization request created by End User Version 1.93 New Workflow Stage (1 2) END Page 27 of 111 SoD Documentation 4.2.1.3 Assign Roles (IAM-200-3): Role Approval Supervisor / Person in charge End User Role Admin (SPOC) Remediate Conflict Approve SoD Exception IAM-510 Exception Reject Request OR No Role Admin (Approver) Check Role Optional: OR Change Role Yes Assignment Optional changes: - assign/retain/remove role - set validity period of role Role OK? Info System (CUP) START Yes Red SoD Risk? SoD Compliance Check Reject Role No Approve Role Event: Authorization request submitted by Role Admin (SPOC) after role selection END 4.2.2 Remove Roles (IAM-201): Overview The main difference between a request for removal and a request for assignment of roles is the approval step. “Removal without approval”. Request for removal don’t require a SoD check and don’t require a approval by Role Admins (Assignment Approvers). Supervisor / Person in charge End User Info START On demand Role Admin (SPOC) Authorization Request IAM 200-1 Role Removal IAM 201-2 Info Reject/ Submit ? Request rejected Request submitted Role Admin (Assignment Approver) Yes System (CUP) Page 28 of 111 Provisioning In SAP Version 1.93 Success? No Exception Handling END Classification: internal SoD Documentation 4.2.2.1 Remove Roles (IAM-201-2): Role Removal Supervisor / Person in charge End User No Role Admin (SPOC) Check Request Request OK? Yes Select Existing Assignments Select roles to be removed Submit Request Reject Request Info Role Admin (Assignment Approver) System (CUP) START Event: Request for removal of authorizations created by end user END 4.2.3 Reapply Role Assignment (IAM-210) Each role assigned to SAP users is limited to a certain validity period. A mail daemon recognizes role assignments that are going to expire in some weeks and ask the user to request a prolongation. This request for prolongation process is identical to the regular process for assignment of roles. Supervisor / Person in charge Info End User Info Assign Role IAM 200 Role Admin (SPOC) Role Admin (Assignment Approver) System (CUP) START Classification: internal Event: expiration of existing role assignments Version 1.93 END Page 29 of 111 SoD Documentation 4.2.4 Compliance Controls User Authorization Administration 4.2.4.1 Segregation of Request and Approval of Role Assignments (C15) Control C15: Every user authorization request must be formally approved by the Role Administrator, i.e. “2-pairs-of-eyes”-principle (1-step approval). The Role Administrator cannot request and assign roles to himself. One of both activities requires a second person. 4.2.4.2 Segregation of Role Assignment from Role Design (C35) Control C35: Role Administrators cannot change roles or approve changes on roles. Role Owners can assign roles and approve role assignments. Remark: In general it should be avoided that the one responsible for assigning roles is enabled to change roles. But exceptions, especially in smaller countries, must be possible, i.e. the Role Owner also assigning Roles to users. Sufficient control is provided if: - “2-pairs-of-eyes”-principle is implemented in the change of roles, i.e. segregation of change request and development/implementation of change (Role Owner vs. IT Development) - Role is checked on SoD compliance before implementation 4.2.4.3 Segregation of Role Assignment from Role Implementation (C37) Control C37: The responsibility to execute changes in user assignments (Role Administrator & User Administrator) cannot be combined with any execution responsibility in the role development (IT Service Delivery). 4.2.4.4 Limitation of Role Administrators (C43) Control C43: Every Role Administrator can only assign a defined and limited set of Roles to users. 4.2.4.5 Approval of SoD Conflicts (C09 and C22) Control C09: Segregation of Duties conflicts may only be approved if policies on this matter justify or approve a compensating activity other than segregation. Control C22: When Role Assignment activities introduce additional SoD conflicts of level "High" (Orange), the Supervisor needs to be informed. Compensating Controls must be active to mitigate these SoD risks. 4.2.4.6 Logging of User Requests (C13) Control C13b: Every user authorization request must be logged electronically. 4.2.4.7 Need-To-Know Principle (C17) Control C17: The Role Administrator is required to inspect appropriateness of assignment and whether the chosen alternative is considered as the best. 4.2.4.8 Documentation of Roles (C18) Control C18: Documentation on the available Roles must be available for every requestor and approver such to identify the appropriate authorizations for a Role Assignment request. 4.2.4.9 Consulting (C19) Control C19: The adequacy of selected authorizations or Roles can be verified by consulting a subjectmatter expert or GSD. Page 30 of 111 Version 1.93 Classification: internal SoD Documentation 4.2.4.10 Validity Period for Role Assignments (C40) Control C40: When a user is moving from one organizational unit to another unit, the Role Administrator of the new organizational unit has to set a validity period to the “old” authorizations. These Roles have to be removed automatically after a validity period (3 months), upon prior information. 4.2.4.11 Review of Role Assignments on Compliance to Need-To-Know (C21) Control C21: Supervisors are to periodically review an overview of User - Role assignments under their responsibility and identify obsolete and/or incorrect assignments. Remark: This task is delegated at Henkel to Role Admins. See process 4.2.3: “Reapply Role Assignment (IAM-210)”. 4.2.4.12 Review of Role Assignments on Compliance to SoD (C25) Control C25: All Users must be reviewed periodically to identify any present SoD conflicts to ensure timely detection of undesired combinations due to recent Role assignments (i.e. detective SoD Control). Remark: See process 4.2.3: “Reapply Role Assignment (IAM-210) 4.2.4.13 Further Optional Controls from COBIT & ISO27002 These controls are defined in the COBIT and/or ISO 27002 standards, but were decided not to be implemented within the SIGMA concept. Reason: Controls are redundant to controls above or controls are defined on low risk areas. Check Validity of Request Control C16: The Supervisor is to assess the validity of the request and business case as well as the business need (place storage) (Verify) Remark: Control is skipped. The Role Assignment process foresees a 1-step approval for assignment of roles. Only assignment of an exception requires a 2nd-level approval. Reason: Effective control is achieved with first approval. The Role Assignment request is documented. Requestor and Approver are segregated duties. The Role Administrator has only a limited set of Roles he/she is enabled to assign to users. SoD conflicts are detected preventively by a system before actual assignment. Detective controls check SoD conflicts ex-post. Approval for Assignment of SoD Conflicts Control C23: Segregation of Duties conflicts may only be approved if policies on this matter justify or approve a mitigation activity other than segregation Remark: redundant. Segregation of Role Assignment from Review of Role Assignments Control C36: The responsibility to assign Roles to users cannot be combined with the responsibility to periodically review and approve Role Assignments to users (Execution) Remark: This control was skipped. Reason: The Role Administrator who is responsible for assigning Roles to Users is at the same time the most knowledgeable person to review the User assignments. Classification: internal Version 1.93 Page 31 of 111 SoD Documentation 4.3 User Authorization Configuration (to be moved to the chapter 6 of ACC document) This chapter describes the processes and compliance controls that support the configuration of Business Roles. This is prerequisite for the administrative processes described in chapter 4.2: “User Authorization Administration”. Prerequisite for the Authorization Configuration is - Role Owner defined (see section 4.4.1: “Define Role Owner (IAM-400)”). - Role Administrator defined (see section 4.4.2: “Define Role Administrator (IAM-401)”). 4.3.1 Create Role (IAM-300) Business Process Owner Define Role Owner (IAM-400) START Process change triggers the need for Role creation No Role Owner START Role Owner defined? Yes Change Role (IAM-301) CREATED Periodic review triggers the need for a new Role Role Administrator START Missing transactions in Role triggers the need for Role creation Page 32 of 111 Version 1.93 Classification: internal SoD Documentation 4.3.2 Change Role (IAM-301) Business Process Owner START Demand to change Role Process change triggers the need for a Role change Info REJECTED if triggered by Business Process Owner Info if triggered by Business Process Owner No Role Owner START Check Demand to change Role Periodic review triggers the need for a Role change Approval ? Yes Pre-authorized Role Change (IAM-303) CHANGED No if triggered by Role Administrator if triggered by Role Administrator Info Role Administrator START Demand to change Role REJECTED Info Missing transactions in existing Roles triggers the need for a Role change 4.3.3 Delete Role (IAM-302) Business Process Owner START Process change triggers the need for Role deletion Role Owner Change Role (IAM-301) START DELETED Periodic review triggers the need for Role deletion Role Administrator Classification: internal Version 1.93 Page 33 of 111 SoD Documentation 4.3.4 Pre-Authorized Role Change (IAM-303) The process described here is embedded in the regular CHARM process (Change Management process) Build IT (Service Delivery) Maintain Master Data (Role Owner/Role Admin Tables) Unit & Functional Test Transport change to production Yes Compliant solution possible? No No Is Role compliant? System (GRC) Yes Define type of change and create CR No Info Role Owner Check content of role START Acceptance Test Acceptance? Yes REJECTED Info IMPLEMENTED The check “Is Role compliant?” needs to check on the following: - SoD compliance of role itself, i.e. did the change create a SoD conflict within the objects of the role? Further checks can be considered: - Impact of the role change on possible Dangerous Combination, i.e. did the change of the role create a new dangerous combination of this role with any other existing role, although the role itself is still free of SoD conflicts? - Impact of the role change on the existing user authorizations on potential new SoD conflicts, i,.e. on which users did the change of the role create new SoD conflicts? These impact analyses are very difficult to conduct. The effort might be higher than a roll-back and/or clean-up afterwards. Therefore the following steps should be processes after a role change: - Regular SoD Analysis (monthly) identifying the users with SoD conflicts - Check on solution options: Roll-back roll change, repair role, or clean-up users A differentiation in simple and complex changes is required. (A) simple, pre-authorized changes e.g. for adding a transaction to a role This change can run at any time. (B) complex change with potential impact on user base, e.g. deleting functions out of roles This change rather runs within the next release upgrade and is tested with the next integration test. The Role Owner decides which type of change he triggers. Page 34 of 111 Version 1.93 Classification: internal SoD Documentation 4.3.5 Review Obsolete Roles (IAM-310) IT Service Delivery Periodic analysis of obsolete roles START Is the Role still valid? Role Owner Document Review-Result REVIEWED Yes No Delete Role (IAM-302) 4.3.6 Compliance Controls User Authorization Configuration 4.3.6.1 SoD Conflict-Free Role design (C24) Control C24: Segregation of Duties conflicts in Role design have to be avoided wherever possible. Exceptions must be formally documented along with the approvals and reference to the documented opted compensating controls. 4.3.6.2 Approval of Role design changes (C03) Control C03: Changes to Roles must be approved by the Role Owner. 4.3.6.3 Logging (C05) Control C05: The process to change Roles must ensure logging. 4.3.6.4 Segregation of Role Design from Role Assignment (C35) Control C35: Role Administrators cannot change roles or approve changes on roles. Role Owners can assign roles and approve role assignments. Remark: In general it should be avoided that the one responsible for assigning roles is enabled to change roles. But exceptions, especially in smaller countries, must be possible, i.e. the Role Owner also assigning Roles to users. Sufficient control is provided if: - “2-pairs-of-eyes”-principle is implemented in the change of roles, i.e. segregation of change request and development/implementation of change (Role Owner vs. IT Development) - Role is checked on SoD compliance before implementation 4.3.6.5 Segregation of Role Implementation from Role Assignment (C37) Control C37: The responsibility to execute changes in user assignments (Role Administrator & User Classification: internal Version 1.93 Page 35 of 111 SoD Documentation Administrator) cannot be combined with any execution responsibility in the role development (IT Service Delivery). 4.3.6.6 Segregation of Role Owner from Role Implementation (C42) Control C42: The responsibility to approve changes of roles (Role Owner) cannot be combined with any execution responsibility in the role development (IT Service Delivery). 4.3.6.7 Approval of Business Process Owner on Cross-Business Roles (C04) Control C04: A Role Owner can only add transactions and technical authorization objects out of his/her area of responsibility to Roles. To add transactions or technical authorization objects out of other areas requires the approval of the respective Business Process Owner. Remark: A Role Owner in the Supply Chain wants to add a Finance Transaction in his Role design. This requires prior permission by the Business Process Owner of Finance. 4.3.6.8 Review of Change Management process for Roles (C06) Control C06: A periodic review must be performed on the effectuated role changes to ensure adequate execution of the role change management process Remark: Covered by the CHARM process, no additional controls for SIGMA defined. 4.3.6.9 Review of Role design (C07) Control C07: Role content must be reviewed periodically by the appropriate Role Owners to ensure that the content is still SoD-compliant and required. Remark: This control is achieved by a periodic review and subsequent deletion of obsolete roles, and by the content and compliance check with every change of a role. An additional periodic review of role content is not required. See process 4.3.2: “Change Role (IAM-301)” and process 4.3.5: “Review Obsolete Roles (IAM-310)”. 4.3.6.10 Approval of Role design creating new Dangerous Combinations (C08) Control C08: When role changes introduce additional SoD conflicts of level "High" (Beta), additional approvals must follow by the Business Process Owner. SoD conflicts of level “Very High” (Alpha) must not be introduced by role changes. Remark: Tbc if this control can be supported by a GRC tool. Fall-back is a detective SoD Compliance monitoring that latest detects new SoD conflicts. 4.3.6.11 Further Optional Controls from COBIT & ISO27002 These controls are defined in the COBIT and/or ISO 27002 standards, but were decided not to be implemented within the SIGMA concept. Reason: Controls are redundant to controls above or controls are defined on low risk areas. Review of Roles design on SoD compliance Control C10: Single roles or tasks used in roles and user provisioning, must be periodically reviewed on the presence of SoD conflicts and approved by appropriate owners. Remark: Covered by controls above Approval of SoD conflicts in Roles design Control C11: Segregation of Duties conflicts in roles must be formally documented along with the approvals and reference to the documented opted mitigating controls. Remark: Covered by controls above Page 36 of 111 Version 1.93 Classification: internal SoD Documentation Handling of Privileged Authorizations Remark: The handling of Privileged Authorizations is out of scope of SIGMA. Control C26: A process must be defined controlling the request, use and timely decommissioning of privileged authorizations. This process must ensure approvals, documentation and periodic review. Control C27: A list of pre-approved users of privileged authorizations must be defined and maintained to ensure only authorized staff has access Control C28: The list of pre-approved users is reviewed at least quarterly for accuracy and updated to ensure validity and timely adjustments following organizational changes Control C29: The list of pre-approved users is formally approved after periodic review to ensure management accountability and awareness. Control C30: Changes to the pre-approval list are formally approved by the accountable manager Control C31: The process defined to control the use of privileged authorizations requires a logged incident / ticket before privileged authorizations may be obtained. This ticket must be used to justify the use and must include documentation on the proposed/intended solution (using privileged authorizations) as well as a closing comment on what was done using these authorizations to solve/close the ticket. This documentation will be matched with audit trails from the super-user authorizations Control 32: Every privilege use-case is reviewed by a different individual to inspect its use, match with the documentation and formally signs off that the use was legitimate and that only activities for the incident/ticket were performed. Control 33: Documentary evidence of each ticket, review/approval and sign-off as well as logging remains available for at least 12 months to allow for inspection and auditability Control 34: An independent staff member must review (after privileged authorizations were granted) that privileged authorizations are effective only for the required period and in any case not used for longer than 24 hours Control 38: The responsibility to use privileged authorizations cannot be combined with the responsibility to review and approve its legitimate use Control 39: The responsibility to maintain the "pre-approved" list cannot be combined with the authority to use the privileged authorizations Classification: internal Version 1.93 Page 37 of 111 SoD Documentation 4.4 User Authorization Ownership Decide if stay here or moved to ACC document This chapter describes the processes and compliance controls that support the definition and the review of role ownership. This is prerequisite for the administrative processes described in chapter 4.2: “User Authorization Administration”. 4.4.1 Define Role Owner (IAM-400) Business Process Owner START Nominate Role Owner per process Role Owner Info IT (Service Delivery) Maintain Master File (Global Role Owner.xls) System Maintain GRC role master data DEFINED This process is covered organizationally. Page 38 of 111 Version 1.93 Classification: internal SoD Documentation 4.4.2 Define Role Administrator (IAM-401) Role Owner Define Role Admin (Assignment Approver per role) Define Role Admin (SPOC) START Role Administrator Info IT (Service Delivery) Maintain Master Data (SPOC table / GRC role master data) System DEFINED This process is covered organizationally. 4.4.3 Review Role Ownership (IAM-410) Business Process Owner IT (Service Delivery Define Role Owner (IAM-400) No Confirmation of Role Owner? Periodically check list of Role Owners START Yes Document review result in Global Role Owner master file REVIEWED System This process is covered organizationally. Classification: internal Version 1.93 Page 39 of 111 SoD Documentation 4.4.4 Review Role Administrators (IAM-411) Define Role Administrator (IAM-401) Role Owner IT (Service Delivery No START Confirmation of Role Admin? Yes Periodically check list of Role Administrators Document review result REVIEWED System This process is covered organizationally. 4.4.5 Compliance Controls User Authorization Ownership 4.4.5.1 Definition of Role Owner (C01) Control C01: Role Owner must be defined. 4.4.5.2 Review of Role Owner definition (C02) Control C02: Role Owner assignments must be periodically reviewed. Remark: see process 4.4.3: „Review Role Ownership (IAM-410)“. 4.4.5.3 Review of Role Administrator definition (C41) Control C41: Role Administrator assignments must be periodically reviewed. Remark: see process 4.4.4: „Review Role Administrators (IAM-411)“. Page 40 of 111 Version 1.93 Classification: internal SoD Documentation 4.5 SoD Compliance Control To stay here. This chapter describes the compliance controls and review processes that ensure SoD Compliance. 4.5.1 Check Compensating Control (IAM-500) The supervisor of an employee is responsible for the risks associated to the authorization given to his/her employees. The Supervisor is also the one checking Compensating Controls. System (COCOS) START Event: Periodic trigger Periodic collection of potential SoD violations in SAP (COCOS Reports) Periodic notification mails to Supervisors Logging of approval status CHECKED Info Yes Check Compensating Control in COCOS (WEB tool) Supervisor Chief Compliance Officer Classification: internal Approve ? No Violation Handling Version 1.93 Page 41 of 111 SoD Documentation 4.5.2 Approve SoD Exception (IAM-501) Business Management START Event: Red SoD conflict cannot be solved. Request for exception raised by Role Admin President / MC0 Document request for exception to Corporate Standard SoD Check request for exception No Approve ? Yes Compliance & Risk Committee Check request for exception Approve ? No Yes Create a mitigation control for the approved exception limited to N months IT Service Delivery END 4.5.3 Review SoD Exceptions (IAM-510) SAP GRC START Reaffirm Role Assignment IAM-210 END 4.5.4 Compliance Controls Not defined Page 42 of 111 Version 1.93 Classification: internal SoD Documentation 4.6 SoD Framework Governance To stay here. This chapter describes the processes and compliance controls that support the Governance of the SoD Framework itself. This is important to achieve a consistency between the rules defined in the Corporate Standard SoD and the rules applied in the organization, processes, and tool landscape. 4.6.1 Review Corporate Standard SoD (IAM-600) No Compliance & Risk Committee Approve changes ? Yes Event: Annual Review START SoD Coreteam Publish new version of CS SoD in HIMDOC Define new CS SoD release Collect change requests to CS SoD Approve changes ? Yes Major change ? END Reconciliation SAP GRC rule sets IAM-603 No Define Compensat. Controls IAM-604 Configure SAP GRC rule set IT Service Delivery Classification: internal Review SoD Permission Directory IAM-602 Yes No Review SoD Rel. Transact. Directory IAM-601 Version 1.93 Page 43 of 111 SoD Documentation 4.6.2 Review SoD-relevant Transaction Directory (IAM-601) Compliance & Risk Committee on demand END START SoD Coreteam No Collect change requests IT Service Delivery Approve changes ? Yes Run SoD impact analysis Reconciliation SAP GRC rule sets IAM-603 Review SoD Permission Directory IAM-602 Configure SAP GRC rule set 4.6.3 Review SoD Permission Directory (IAM-602) Compliance & Risk Committee No SoD Coreteam Approve ? Yes on demand START IT Service Delivery END Yes Collect change requests Page 44 of 111 New transaction with permission ? No Document SoD Permission Directory Configure SAP GRC rule set Version 1.93 Reconciliation SAP GRC rule sets IAM-603 Classification: internal SoD Documentation 4.6.4 Reconciliation of SAP GRC Rule Sets (IAM-603) END Document reconciliation results SoD Coreteam Yes Reconcile access risks vs CS SoD Reconcile functions vs SoD-relevant T-code Directory Reconcile permissions vs SoD-relevant T-code Directory Reconcile permissions vs SoD Perm. Directory Recon Successful ? No IT Service Delivery START Download SAP GRC rule sets Correct SAP GRC rule set Event: Change of SAP GRC rule set 4.6.5 Define Compensating Controls (IAM-604) This process describes how Compensating Controls are defined and designed. The actual control itself is conducted by the Supervisor, see 4.5.1: “Check Compensating Control (IAM-500)”. The Business Process Owner might delegate the definition of Compensating Controls for single Critical Roles to the Role Owner. Compensating Controls on Dangerous Combinations of Roles usually require the definition by the Business Process Owner. START Check changes of new version of Corporate Standard SoD Event: Change of Corporate Standard SoD New Risks? No Update configuration of controls Review configuration of COCOS tool Yes New control required? SoD Coreteam No Update Compensating Control Direct. Yes Define change request Build, test, and deploy new control IT Service Delivery Classification: internal END Version 1.93 Page 45 of 111 SoD Documentation 4.6.6 Compliance Controls SoD Framework Governance 4.6.6.1 Review of Compensating Control measures (C12) Control C12: Business Process Owner must periodically test, demonstrate and sign-off on the on-going effectiveness of the employed Compensating Control measures. Remark: Business Process Owners have to check measures like Compensating Control reports or builtin controls periodically. The Compensating Control itself is conducted by the Supervisor of the User. This control is achieved by - Periodic review of the SoD matrix and subsequent check and change of Compensating Controls - Detection of missing Compensating Controls within the assignment process and subsequent creation (no SoD conflict approval without compensating control) Page 46 of 111 Version 1.93 Classification: internal SoD Documentation 5 SoD Governance To stay here. This document describes the elements of the SoD Framework at Henkel, ownership and regulations for change management, and the master files per element. 5.1 Elements and Structure of the SoD Framework at Henkel 5.1.1 SoD Framework Corporate Standard SoD CS SoD The Corporate Standard defines - the processes (e.g. PTP) - functions per process - SoD risks as combination of two functions (e.g. function 1 combined with function 2) - the classification of SoD risks (risk level, e.g. red = very high) SoD Relevant Transaction Directory The SoD Relevant Transaction Directory lists all relevant SAP transactions per process function to enable the SoD tools to check on combinations of transactions assigned to users. The directory defines - the SoD relevant transactions per process - the classification of each transaction to a process function - the criticality of the transaction (e.g. display transactions not critical) - whether the SoD risks is defined more precisely on permission level or if the whole transaction is classified as SoD-critical SoD Permission Directory The SoD Permission Directory defines - the authorization objects, fields per SAP transaction Classification: internal Version 1.93 Page 47 of 111 SoD Documentation - the critical values (e.g. activity type 01/02 = create/change are critical, but activity type 03 = display is not critical) 5.1.2 SoD Tools SAP GRC AC SAP GRC AC (Access Control) is implemented at Henkel for the following purposes - Analysis of the SoD compliance of authorization roles (RAR) - Analysis of the SoD compliance of SAP users (RAR) - Compliant provisioning of authorizations to SAP users, preventing from assigning red SoD conflicts (CUP) Compensating Control System (COCOS) COCOS is a web-based tool that allows Supervisors to check and approve transactions posted by employees of their team. COCOS displays all cases, where one and the same user ran two steps of a process in SAP which should have been segregated following the Corporate Standard SoD. COCOS collects data from Compensating Control Reports running per SoD risk in each SAP System. Some Compensating Control Reports even check on cross-system SoD Conflicts (e.g. creation of master data in P03 (central master data system) and posting of credit notes in Pxx (Finance or Logistics System)). Built-in Controls Built-in control prevent users from posting in one document flow two steps of a process that should be segregated following the Corporate Standard SoD. The user might be authorized to run both process steps, but is blocked from posting both process steps in one and the same document flow. 5.1.3 SoD KPI and Reporting Global SoD Cockpit The Global SoD Cockpit analyzes the SoD compliance of all SAP users worldwide. The cockpit reports the SoD Compliance by location of the users (regions, countries, and organizational units) independent of the SAP system the users are working with. This KPI is considering cross-system risks. The cockpit is updated on a monthly level. Owner of the Global SoD Cockpit is the SoD Compliance Manager. System SoD Cockpit The System SoD Cockpit analyzes the SoD compliance of all SAP users worldwide. The cockpit reports the SoD Compliance per system, independent where the users are located. This KPI is not considering cross-system risks. The cockpit is updated on a monthly level. Owner of the Global SoD Cockpit is the SoD Compliance Manager. 5.2 Naming Conventions of the SoD Framework at Henkel 5.2.1 Rule Sets The Rule Set ID has no naming convention. Page 48 of 111 Version 1.93 Classification: internal SoD Documentation The Rule Set description names the version (i.e. version of the SoD relevant transaction directory and the release date of the SoD relevant transactions directory 5.2.2 Access Risks General naming conventions (framework) Access Risks have the following naming convention XXXX_Y XXXX is the 4-digit Risk ID as stated in the Corporate Standard (SoD Risk Register, high level) _Y stands for the type of risk (_S = single system risk / _C = cross system risk) Within this general frame, the processes define the risks as follows. Order-to-Cash (OTC) OTC SoD risks are codified as follows: XXZZ_Y XX is the acronym of the first function (e.g. B5 for function BU05 – Sales Order Processing) ZZ is the acronym of the second function (e.g. F3 for function FO03 – Credit Management) Purchase-to-Pay (PTP) PTP SoD risks are codified as follows: PXNN_Y P is fix for PTP X identifies the sub process type (I=Risk only for Intercomany, E=risk only for external procurement; G = general risk for all types of sub-processes NN 2-digit number Human Resources (HR) HR SoD risks are codified as follows: HNNN_Y H is fix for HR NNN 3-digit number _Y stands for the type of risk (_S = single system risk / _C = cross system risk) For HR only single system risks apply 5.2.3 Functions General naming conventions (framework) Functions have the following naming convention XXNN(Z)_Y XX is the 2-digit header of the process (e.g. PR = procurement) Classification: internal Version 1.93 Page 49 of 111 SoD Documentation NN Z 2-digit number is an optional letter, identifying a variant of the function. This is technically required in some cases, where the the same risk and function is defined differently per connector. _Y stands for the type of risk (_S = single system risk / _C = cross system risk) Order-to-Cash (OTC) OTC functions are codified as follows: XX PR = Procurement; AP = Accounts Payable; MM = Materials Management Purchase-to-Pay (PTP) XX BU = Business Unit OTC FO = Finance OTC; Human Resources (HR) HR functions are codified as follows: HNNN_Y H is fix for HR NNN 3-digit number _Y stands for the type of risk (_S = single system risk / _C = cross system risk) For HR only single system risks apply 5.2.4 Risk Descriptions The risk descriptions are listed in the SoD Risk Register of the SoD Matrix of the Corporate Standard SoD. Short Description The short description of the Access Risk is naming the two sub processes combined in this SoD Risk. E.g. “Processing of Purchase Order and Processing of Vendor Invoice” SoD Risk Register: “SoD Short Description” Long Description The long description describes the risk. SoD Risk Register: “SoD Long Description” Control Objective The Control Objective provides examples. SoD Risk Register: “Example” Page 50 of 111 Version 1.93 Classification: internal SoD Documentation 5.3 Governance of the SoD Framework 5.3.1 Governance Bodies Corporate Compliance & Risk Committee (CRC) The CRC is chaired by the Chief Compliance Officer at Henkel. The CRC approves - major changes of the CS SoD - exceptions to the CS SoD as regulated in the CS SoD SoD Coreteam The SoD Coreteam is chaired by the SoD Compliance Manager. It takes place on a monthly basis. The SoD Coreteam members are representatives of the Process Ownership per business unit and function for the SoD relevant processes at Henkel, plus Internal Audit (VIA). The SoD Coreteam approves - minor changes to the CS SoD - all changes to the SoD Relevant Transaction Directory - all changes to the SoD concept implemented at Henkel (i.e. Provisioning Process (CUP workflow), Compensating Control System (COCOS), Compensating Control reports, Built-in Controls, SAP GRC rule sets incl. Permission Level) - all changes to the KPIs and SoD Reporting 5.3.2 Corporate Standard Segregation of Duties (CS SoD) Owner Owner of the Corporate Standard is the Corporate Compliance & Risk Committee (CRC) Master Files The documentation consists of the following documents: - Main document: CS SoD vX.X (.pdf) - Enclosure #1: SoD Matrix for Purchase-to-Pay (PTP) (.xls) - Enclosure #2: SoD Matrix for Order-to-Cash (OTC) (.xls) - Enclosure #3: SoD Matrix for Order-to-Cash (HR) (.xls) The Corporate Standard is documented in the HIMDOC database (Henkel’s Corporate Governance documentation). Location: http://sf-apps-i201.de.henkelgroup.net/corporate/sustainability/himdochg.nsf Responsible for master file SoD Compliance Manager. Review Cycle The Corporate Standard is reviewed annually (end of year). Classification: internal Version 1.93 Page 51 of 111 SoD Documentation Change Management Regulations All change requests to the Corporate Standard have to be presented to the SoD Coreteam. The SoD Coreteam decides on all changes to the Corporate Standard, minutes of the decisions are documented in the Lotus Notes database “SoD Compliance Managements”. Major changes require additionally the approval of the Corporate Compliance & Risk Committee before implementation of the change. Some complex changes might require the trigger of implementation projects, especially when the change impacts many users (e.g. additional processes). 5.3.3 SoD Relevant Transaction Directory Owner Owner of the SoD Relevant Transaction Directory is the SoD Coreteam. Master File The SoD Relevant Transaction Directory is an Excel file, stored in the SoD Compliance Management database in Lotus Notes. This documentation is leading. The configuration of functions and transactions in the SAP GRC rule sets have to follow this master documentation. Responsible for master file SoD Compliance Manager. Review Cycle The SoD Relevant Transaction Directory is reviewed on a monthly basis with each change request. Change Management Regulations Changes to the SoD Relevant Transaction Directory have to be presented to the SoD Coreteam for approval. An impact analysis on different levels might be required before taking a decision on the actual implementation of the change. 5.3.4 SoD Permission Directory Owner Owner of the SoD Permission Directory is the SoD Coreteam. Master File The Permission configuration is defined in the PRC system (master). The SoD Permission Directory is an up-to-date copy of this configuration. This copy is stored in the SoD Compliance Management database. Responsible for master file Responsible for the configuration in SAP GRC AC and responsible for the correct and up-to date documentation of permissions in the SoD Permission Directory documentation is VT-GSD-SO Authorization Management. Page 52 of 111 Version 1.93 Classification: internal SoD Documentation Review Cycle The SoD Permission Directory is reviewed on a permanently basis with each change request. Change Management Regulations Changes of the documentation follow changes of the permission configuration in PRC (see SAP GRC rule sets / Change Management / Permission Level). 5.3.5 SAP GRC AC Rule sets SAP GRC AC architecture SAP GRC AC is configured with a 3-tier architecture. Development system is DRC, consolidation system is CRC, and productive system is PRC. SAP GRC AC is implemented as one instance for Henkel worldwide and connected to the distributed SAP landscape of Henkel. CRC is connected to SAP ERP development systems (Dxx/Nxx) and to SAP ERP consolidation systems (Qxx/Kxx/Cxx). CRC is used to run productive SoD analyses on roles changes against consolidation SAP systems before deployment of these roles to productive SAP systems. Therefore CRC is part of the SoD framework. Changes of the CRC rule sets have to follow the SoD Governance rules in the same way as changes on the productive PRC rule set. PRC is connected to the productive SAP ERP systems at Henkel (Pxx, LA1). PRC is used to run SoD analyses on user level and to run the provisioning workflow to end users in productive SAP ERP systems. SAP GRC AC rule sets The SoD rule sets in DRC which are also active in PRC must have an identical configuration in DRC as in PRC. Reason: DRC is used productively in the change management process of authorization role changes. There are presently 2 SAP GRC AC rule sets defined at Henkel: CUP rule set The CUP rule set is a subset of the Corporate Standard SoD. It only defines the SoD risks of level red / very high, where segregation is mandatory, and Compensating Controls are not allowed. This rule set is used in the CUP workflow to prohibit the assignment of authorizations to end users that create such a red SoD conflict. All other conflicts, where a Compensating Control is allowed by the Corporate Standard SoD (SoD risks of level orange / high) or where general exceptions are approved by the SoD Coreteam (i.e. red SoD risks in OTC that are already controlled by a 2-pairs of eyes principle in the SAP system itself, so called built-in control) are not checked by the CUP workflow. These SoD risks are controlled by the Compensating Control System. The CUP rule set presently covers the SoD matrices of the business processes OTC and PTP. The CUP rule set is used for the Global SoD Cockpit as well as for the System SoD Cockpit. RAR rule set The RAR rule set defines all risks of the SoD matrices for OTC and PTP of risk level red / very high, and orange / high. The RAR rule set is not used in the CUP workflow, but used to analyze SoD risks of roles and users. Owner The content of the SAP GRC rule sets is owned by the SoD Coreteam. The configuration of the rule sets is owned by the VT-GSD-SO -Authorization Management team. Classification: internal Version 1.93 Page 53 of 111 SoD Documentation Master File Even if rule sets do not share common objects like SoD risks or SoD functions, the upload functionality and the transportation functionality of GRC do share common tables. This requires a joint change management approach with one master file for all changes to the SoD rule sets in GRC. SoD Coreteam IT Service Delivery CR on Risks Approval Compliance & Risk Com CR on Functions Approval SoD Coreteam CR on Permissions Pre-approved; check by GSD CS SoD SoD Rel Trans Dir MASTER FILE RULE SETS Upload of Master File SoD Perm Dir Test and Reconciliation of Rule Sets Transport of Rule Sets to CRC Recon Log File Reconciliation of Rule Set DRC PRC Transport of Rule Sets to PRC Test and Reconciliation of Rule Sets CRC PRIMARY SOD DOCUMENTATION SoD risks and rule sets The leading master file for SoD risks, soD functions and SoD risk descriptions is the Corporate Standard SoD. The risk and rule set definitions in SAP GRC have to follow the currently released version of the Corporate Standard SoD. SoD transactions The leading master file for SoD transactions per SoD function is the SoD Relevant Transaction Directory. The function and transaction configuration in the SAP GRC rule sets have to follow the currently released version of the SoD Relevant Transaction Directory. SoD permissions The leading master file for the permission level of the GRC rule sets is the SoD Permission Directory. The permissions’ configuration in the SAP GRC rule sets have to follow the currently released version of the SoD Permission Directory. MASTER FILE RULE SETS Any change to the rule set starts with a change of the underlying primary documentation. All documents are joined in one master file for upload. This master file is common for all processes of the Corporate Standard SoD. Page 54 of 111 Version 1.93 Classification: internal SoD Documentation Owner of the Master File Rule Sets SoD Compliance Manager is owning the master file. Change Management Regulations The rule sets in CRC and PRC are locked for changes. Only Fire Fighters are allowed in emergency cases to directly change the rule sets in CRC and PRC. Any change of the rule set has to follow the following procedure: 1. Definition of change request by businesses, functions, or projects 2. Approval of change request by SoD Coreteam 3. Update of primary documentation by SoD Compliance Manager 4. Update of the Master File Rule Sets by SoD Compliance Manager 5. Upload of rule sets to DRC by VT-GSD-SO -Authorization Management 6. Reconciliation of DRC rule set by SoD Compliance Manager 7. Transportation of rule set from DRC to CRC by VT-GSD-SO -Authorization Management 8. Reconciliation of CRC rule set by SoD Compliance Manager 9. Transportation of rule set to PRC by VT-GSD-SO -Authorization Management 10. Reconciliation of PRC rule set by SoD Compliance Manager Pre-approved changes for SoD permission level The decision which transactions are defined on permission level is taken by the SoD Coreteam and documented in the SoD Relevant Transaction Directory. Any request on adding permission level to further transactions or removing the permission level from approved transactions requires prior approval of the SoD Coreteam. As the configuration of the permission level per transaction requires detailed technical know-how, the SoD Coreteam decided to delegate the configuration to the VT-GSD-SO -Authorization Management team. That means: all changes to the permission level in the SAP GRC rule sets are pre-approved by the SoD Coreteam, as long as - the permission level is only changed for transactions where the SoD Coreteam apoproved the definition of a permission level - the definition of the permission level follows general risk considerations, e.g. display activity type 03 = no critical, create/change activity type 01/02 = crtitical. Each change of the permissions in the SAP GRC rule set has to be documented in the SoD Permission Directory. Reconciliation of SAP GRC rule sets After each change of the SAP GRC rule set a reconciliation to the SoD documentation is required. This reconciliation needs to be documented in the SoD Compliance Management database for later audit purposes. Purpose of the reconciliation is - consistency between configured version of the rule sets in SAP GRC and the currently approved and released version of the SoD Framework - consistency between the configuration of the SAP GRC rule set and the documentation of the rule set - consistency between DRC and PRC rule sets Classification: internal Version 1.93 Page 55 of 111 SoD Documentation SoD risks and rule sets Each change of the SAP GRC risks or rule sets in DRC, CRC, and PRC requires reconciliation against the Corporate Standard SoD. SoD functions Each change of the SAP GRC functions and assigned transactions in DRC, CRC, and PRC requires a reconciliation against the Corporate Standard SoD and the SoD Relevant Transaction Directory. SoD permissions Each change of the permissions defined in DRC, CRC, and PRC requires reconciliation against the SoD Transaction Directory (which transaction do have a permission level defined) and a reconciliation against the SoD Permission Directory (to ensure a up-to-date documentation). Page 56 of 111 Version 1.93 Classification: internal SoD Documentation 6 Authorization Concept (TO BE REVIEWED) To move to chapter 3 of ACC This chapter describes the structure of the authorization concept in SAP (GSP Western Europe). The Authorization Concept describes the realization of Business Roles in technical SAP settings together with - a concept for coexistence of old and new concept - a migration plan for cleaning up user authorization - a future mode of operation incl. detailed Change Management process and controls 6.1 Requirements of Authorization Concept This chapter describes the requirements in the scope of SIGMA project. The requirements have been categorized in general, technical and business requirements. In addition, the business requirements are analyzed separately by business. For further details on the requirements please refer to the Requirements Matrix. 6.1.1 General Requirements The following general requirements have been identified: GR-001 All atomic functions must be SoD conflict-free The atomic components of the to-be business roles must be free of SoD conflicts. GR-002 No shared ownership of functions between BUs In the current model, the equivalents to functions are shared between businesses. It is required that the functions have a unique owner. GR-003 No shared ownership of Business Roles between BUs Also business roles won’t be shared between businesses in order to simplify and centralize their maintenance. GR-004 Reduce maintenance costs The authorization concept should help to reduce the maintenance costs of authorizations. GR-005 Naming for Functions and business roles: easy to identify on the provisioning tool A new naming convention has to be defined in order to help to identify the functions and business roles and their description must be in business langauge since they’ll be shown in the provisioning tool. GR-006 Prevent 312 SAP Profiles limitation The actual function and business roles structure leads to problems in the assignment of business roles to users because of the limit of 312 SAP profiles per user. GR-007 Apply need-to-know principle Any user has to be granted the access they strictly need. GR-008 Naming for Functions and business roles: differentiate between concepts (current and new) The new naming convention should be descriptive and it has to be possible to differentiate Classification: internal Version 1.93 Page 57 of 111 SoD Documentation between the current and new concept. GR-009 All business roles must be SoD conflict-free Each and every business role must be free of SoD conflicts. Their combination can cause conflicts which will be detected by and their compesating controls documented in the Compliance control tool. 6.1.2 Technical Requirements The following technical requirements have been identified: TR-001 SAP Profiles name should be unique and not system-related A new naming convention for SAP profiles has to be defined to avoid colliding names when merging systems (HORIZON Project). 6.2 Dependencies to other Processes The definitions for the WEU authorizations will have a direct impact on the following R/3 systems: Region System Comments WEU P01 WEU P03 WEU P08 WEU P11 WEU P12 NA P60 Contains roles from P08 and P01 NA P62 P12 Mirror NA P68 P08 Mirror MEA P50 Contains roles from P08 and P01 6.3 Technical Authorization Concept The technical authorization concept focuses on the detailed technical explanation of the new authorization concept taking into account the different technical requirements and steps to be accomplished for the successful implementation. 6.3.1 Definition of Terms In this section we include the terms we use for the description of the technical authorization concept and its processes. Page 58 of 111 Version 1.93 Classification: internal SoD Documentation Term Acronym Description Henkel Security Policy HSP The Henkel Security Policy is a document which contains the established security policies within the world-wide Henkel network. z-Transactions Custom Transactions 6.3.2 Background Information This chapter details background information regarding the current authorization model and the standard SAP master-derived mechanism. 6.3.2.1 Current model The current model is based on master functions. Transaction codes are grouped together into master functions taking into account functional requirements and similar authorization objects. Afterwards those master functions are derived as required for the diverse businesses with the defined organizational levels (codification document) and common restrictions. Once derived those (derived) functions are grouped into business roles (e.g. A/R accounting clerk) to be finally assigned to the users. 6.3.2.2 Master-Derived Mechanism and Organizational Levels SAP authorization provides the functionality of derived functions. The idea is to create master functions with authorization data which is shared (transactions, organizational levels, non-organizational levels) by a certain criteria (e.g. country...). Authorization data which isn’t shared within the defined criteria won’t be taken into account in the master functions. Classification: internal Version 1.93 Page 59 of 111 SoD Documentation Afterwards derived functions are generated which are linked to the master functions. The derived functions are generated as copies of the master functions. These derived functions can be adapted with authorization data which isn’t shared within the defined criteria but it is only allowed for organizational levels: Finally the functions can be maintained as following: Master functions: Mass maintenance for shared authorization data Modifications of shared authorization data (transactions, organizational levels, nonorganizational levels) needs only to be done in the master function and can be automatically adapted for the derived functions. Manually maintenance for authorization data which isn’t shared Modifications of authorization data (organizational level) which isn’t shared (e.g. company code, plant…) has to be done manually for the corresponding derived function. 6.3.3 General Structure of Authorization Concept The new authorization concept is based on composite and single roles. Composite roles correspond to business roles and single roles correspond to functions. Composite roles (business roles) are assigned directly to the end users: Page 60 of 111 Version 1.93 Classification: internal SoD Documentation E.g. such a composite role (business role) could be: Business UA-OtC UK-OtC UW-OtC UA-PtP UK-PtP UW-PtP Composite Role (Business Role) OtC Local Administration Foreign Trade MD Customer Order Management Production PtP 01 SC Planner CMM 01 Process GR for components Composite roles (business roles) don’t contain directly acess rights like transactions and authorization objects but they are composed of single roles (functions): E.g. such a single role (function) could be: Business UA-OtC UK-OtC UW-OtC UA-PtP UK-PtP UW-PtP Classification: internal Single Role (Function) OtC Invoice Creation Order Entry Maintain Sales Order Display Purchase Order Cancel Goods Receipt Display Invoices Version 1.93 Page 61 of 111 SoD Documentation Finally single roles (functions) contain all authorizations like transactions and technical authorization objects with values: The transactions assigned to a single role (function) can be standard and custom transactions. The only restriction is that the custom transactions have to be available in the development system where the authorizations are being developed in order to be able to create the corresponding access rights. 6.3.3.1 Single Roles (Functions) Single roles contain groups of transactions which can be shared with other countries/regions or be local. Transactions shared by other countries/regions correspond to common processes and local transactions correspond to local processes: A. Common processes (global and regional) B. Local processes (local) Common processes For common processes single roles (functions) are used and the standard SAP mechanism of master and derived functions will be applied. The corresponding functions are called master functions and derived functions. Master functions are collections of transaction codes and access rights of a particular business process which correspond to a common process in order to be shared. As master functions are template versions they shouldn’t be assigned to business roles because they don’t contain organizational levels values (company code, plant …). Derived functions will be created for all master functions of the security concept in order to implement organizational splits. Derived functions are based on master functions and contain the same access rights as the master functions. In addition derived functions contain access rights which can be exclusively controlled by organizational levels (company code, plants, sales organizations…) defined for the domains. The master and derived functions will be divided into global and regional depending on the business requirements. Global business roles must be composed by global functions and regional business roles Page 62 of 111 Version 1.93 Classification: internal SoD Documentation must be composed by regional functions: Local processes For local processes also single roles (functions) are used but without the mechanism of master and derived functions. They are called local functions. Local functions are collections of transaction codes and access rights of a local business process. Local functions are never master functions and can’t be derived. 6.3.4 Domains and their usage The following statements define a domain and its usage: 1. Domain is a way of identifying a given set of authorizations objects, fields, org. levels, and their values usually related to a company or country 2. Domains are documented in the codification document 3. Domains are used as an input for derivation. The domain code usually contains the country and further specifications (splittings) such as company code, plant, shipping point, etc. However, some business roles and functions do have special codifications. Classification: internal Version 1.93 Page 63 of 111 SoD Documentation A domain consists always of 5 characters and is structured as follows: DDDDD (5) o DDddd (2) the first 2 characters determines the country or region code, e.g. BE, DE, etc. (see appendix) o ddDDD (3) determines further splits (company, plant, shipping point), e.g. HKA (BX - Cosmetics ACC), CDB (DE – Centr. Log UA/UT). Exceptions: - Template functions must have all organizational values set as blank. They are coded by 5 Ts TTTTT. - Functions with organizational values set to * are coded by using an X, e.g. XXXXX (no org.level restrictions), DEXXX (restricted by country = germany only) , etc. - Functions which don’t contain any organizational values are coded using Z. e.g ZZZZZ (typically used for custom transactions) Domains usually follow a tree structure for each country, in the picture below the domain tree for UK is shown: 6.3.4.1 Codification document The codification document is an Excel spreadsheet which is used to document the domains, their values and their owners. Changes of existing or creation of new domains must be updated manually. The codification document is used to determine domain owners and domain values, to find new available domains and to analyze domain structures. In order to reduce complexity it has been defined one codification document by region (AP, CEE, LA, MENA, NA, WEU). Page 64 of 111 Version 1.93 Classification: internal SoD Documentation The Excel Spreadsheet is structured as follows (e.g. WEU): The tabs are structured in three sections: First tab: Domains In the first tab all domains are listed by country (exceptions are regions NORDEN, BENELUX and X for corporate…) and additional description (e.g. DE, DE-UA, BX, BE-Purchasing). The domains must be unique and are linked to the corresponding tab and field which contains the domains’ details. The grouping by additional description can be used as applies. If it isn’t desired to use an additional description the domain should be always listed by region or country (or exceptions). Classification: internal Version 1.93 Page 65 of 111 SoD Documentation Second and third tab: Domain hierarchy queries and data If a new organizational values needs to be updated in a certain domain it has to be also done in the corresponding parent domains. The second tab called ‘Data Entry’ provides a tool to determine automatically the parent domains: The yellow field, right to ‘Input Domain’ is used to enter the domain in order to determine the corresponding parent domains. Once entered the tab displays automatically the parent domains, e.g. DECAX: In our example the domain DECAX has 4 parent domains. Page 66 of 111 Version 1.93 Classification: internal SoD Documentation The third tab called ‘Domain table’ contains the relation between domain and parent domain in order to be determined in the previous tab: Domains details The rest of the tabs contain the domain detail: Modules, fields, descriptions, objects, owners…and the domain values. The domain detail is linked directly to the domains listed in the first tab. Classification: internal Version 1.93 Page 67 of 111 SoD Documentation Maintenance of the codification document Depending on the type of change to be done one or more steps have to be followed in order to update the codification document: A. New value added/removed to/from an existing domain The domain detail tab has to be accessed and the corresponding values has to be added/removed to/from the corresponding value. B. New domain is created First the new domain has to be added to the corresponding list in the first tab. Here it has to be analyzed if a new column has to be created or the domain can be added to an existing one. A new column will require a new tab. Then the column detail has to be added to the corresponding detail tab (or a new tab has to be added) and the inserted domain in the first tab has to be linked with the detail tab (and the domain position). Finally the relation of the domain and their parent domains have to be updated in the third tab. 6.3.5 Naming Convention In order to provide a simple concept for an easy maintenance and understanding, a shared naming convention has been defined for the business roles, functions and SAP profiles. In addition, the naming convention helps to identify the role/function owners. 6.3.5.1 Business Roles The naming convention for business roles is: ABC_DDDDD_EEEEEEEEEEEEEEEEEEEE (30) Where A (1) defines the role scope (region): A (AP), C (CEE), G (Global), L (LA), M (MENA), N (NA), P (Local), W (WEU) B (1) defines the business (A, K…) C (1) defines the process (OtC, PtP…) D (5) is the domain code (see previous chapter “Domains and their Usage”) E (20) is the description (or part of it) Example: GWO_DEDXX_ORDER_MANAGEMENT - Global composite role for Germany and company Dorus Bopfingen for UW and OtC process with description “Order Management”. Page 68 of 111 Version 1.93 Classification: internal SoD Documentation 6.3.5.2 Functions There are three different types of functions which have to be considered for the naming convention. Master (template) Derived Local Master functions Master functions are used as templates for derivation. They contain the complete transaction set but all organizational values are set to ‘ ‘ (blank). The naming convention for master functions is as follows: ABCDDDDDNNF_EEEEEEEEEEEEEEEEEE (30) Where A (1) defines the function scope (region): A (AP), C (CEE), G (Global), L (LA), M (MENA), N (NA), W (WEU) B (1) defines the business (A, K…) C (1) defines the process (OtC, PtP…) D (5) is the domain, for master functions must be always “TTTTT” NN (2) is a consecutive alphanumeric numbering used to get unique names within the first 10 characters of the role name. F (1) is the type of activity: A (Administration = edit), D (Display), X (mixed) E (18) contains the description (or part of it) Example: WKPTTTTT01D_DISPLAY_PO – Western Europe master function #1 for UK and PtP process with activity display and description “Display Purchase Order”. Derived functions Derived functions are obtained by deriving the master functions. They contain the same transactions contents as the master with the addition of values to the organizational levels. The naming convention for derived functions is as follows: ABCDDDDDNNF_EEEEEEEEEEEEEEEEEE (30) Where A (1) same as master function B (1) same as master function C (1) same as master function Classification: internal Version 1.93 Page 69 of 111 SoD Documentation D (5) is the domain for derived functions (see previous chapter “Domains and their Usage”) NN (2) same as master function F (1) same as master function E (18) same as master function Example: WKPDED1X01D_DISPLAY_PO – Western Europe derived function #1 for Germany and company Dorus Bopfingen with split between plants for UK and PtP process with description “Display Purchase Order”. Local functions Local functions should contain only transactions that are being used within the scope of a country or department. As no further splits or instances of this kind of functions is expected, they are not intended to be derived. Local functions will be used only for local business roles. In the case of the need of using a local function between different departments or countries, a regional (hence template/derived) function must be considered. The naming convention for local functions is as follows: ABCDDDDDNNF_EEEEEEEEEEEEEEEEEE (30) Where A (1) defines the function range (region): P (Local) B (1) defines the business (A, K…) C (1) defines the process (OtC, PtP…) D (5) is the domain, for local functions the domain code XXXXX should not be used (see previous chapter “Domains and their Usage”) NN (2) is a consecutive alphanumeric numbering F (1) is the type of activity: A (Administration = edit), D (Display), X (mixed) E (18) contains the description (or part of it) Important: Attention with the consecutive numbering. All local functions must be unique within the first 10 characters. Otherwise duplicated profiles can be generated. Example: PFOBELXX23X_TAX_REPORT_BELGIUM – Local function #23 for Belgium and company Henkel Loctite for Finance and process OtC with description “Tax report Belgium”. Page 70 of 111 Version 1.93 Classification: internal SoD Documentation 6.3.5.3 SAP Profiles A technical requirement of SAP is to define a naming convention for the SAP profiles in order to prevent the overwriting and/or errors due to duplicated profiles. The naming convention for SAP profiles can be directly derived of the function name, it corresponds to the first ten characters: ABCDDDDDNN (10) A (1) same as function B (1) same as function C (1) same as function D (5) same as function NN (2) same as function E.g. the profiles of the examples above should be as following: WKPTTTTT01D_DISPLAY_PO -> WKPTTTTT01 WKPDED1X01D_DISPLAY_PO -> WKPDED1X01 PFOBELXX23X_TAX_REPORT_BELGIUM -> PFOBELXX23 Important: The consecutive numbering must be reviewed before assigning the profile name in order to prevent duplicate profile names. 6.3.6 Future mode of operation and maintenance 6.3.6.1 Prerequisites - All relevant Process Owners and Role Owners are named and take charge - All new Business Roles have to be developed for the new authorization concept following the policies and procedures described in chapter 4.3: “User Authorization Configuration” involving Process Owners and Role Owners - All new Business Roles to be developed for the new authorization concept pass SoD check to ensure SoD conflict-free Roles. 6.3.6.2 Ownership Ownership is a key concept for the authorizations model described in this document. All components of the authorizations concept must be owned by a Role Owner (as described in section “3.14 Role Owner” above). For this reason, the first three characters of the business role or function name define their ownership. ABC_DDDDD_EEEEEEEEEEEEEEEEEEEE (30) A (1) defines the role scope (region): A (AP), C (CEE), G (Global), L (LA), M (MENA), N (NA), P (Local), W (WEU) B (1) defines the business (A, K…) Classification: internal Version 1.93 Page 71 of 111 SoD Documentation C (1) defines the process (OtC, PtP…) Hence the ABC part of the name describes the owneship of the role as described in the following table: Global Regional Local G (Global) A (AP), C (CEE), L (LA), M (MENA), N (NA), W (WEU) P (Local) Global business roles, global derived functions, global master (template functions), global domains Regional business roles, regional derived functions, regional master (template functions), regional domains Local business roles, local functions, local domains In addition depending on the type of change the corresponding owner has to be determined: Transactions When a transaction is requested the ticket should be deal by SPOC of ACN. He will check if both area of the requester and of the transaction are the same. In case that both are equal, transaction will be added. In case that both are not equal, Authorizations team will request the approval of the Process Owner of requested transaction area. Look the matrix for the approval: When Authorizations team will have doubts about a transaction, they will first contact with their counter part in Henkel, second with the boss of their counter part, third their IT Global business consultant in order to get the accurate information of the transaction and be able than to identify the correct process owner for the approval. The Accenture team will save in the share point an excel sheet with all ticket information and approvals attached in the tickets, as is described in the Matrix_approval_history spreadsheet. Page 72 of 111 Version 1.93 Classification: internal SoD Documentation Authorization Objects When a change of a value of an authorization object is requested it has to be checked if the requester and the owner are the same person (see codification document). In case to be the same person the change will be processed. In case they aren’t a approval of the domain owner will be requested. In addition there are for some authorization objects specific authorization object owners (see codification document). In case that a change affects an authorization object of an authorization object owner then the approval has to be requested to authorization object owner instead of the domain owner. 6.3.6.3 Business Role Creation Business roles will be always created in the development system N08. Once tested the business roles are transported to the corresponding production system. Business roles must be classified into common process business roles and local process business roles. Common process business roles correspond to global or regional (AP, CEE, LA, MENA, NA, WEU) shared processes and local business roles to local processes which aren’t shared. Once determined if a business role is common or local the corresponding functions have to be assigned. For global business roles it must be assigned only global derived functions: For regional business roles it must be assigned only regional derived functions: Classification: internal Version 1.93 Page 73 of 111 SoD Documentation For local process business roles it must be assigned only local functions: 6.3.6.4 Function Creation There are three types of functions which have to be considered. For common processes master functions and the corresponding derived functions must be used. For specific processes local functions must be used. Master functions Master functions contain directly all transactions and access rights of a certain business process but the organizational values (company code, plant, sales organization…) are blank. Derived functions Technically it is first needed to create the derived function, link it to the corresponding master function and then derive the master function. Then the authorizations of the master function will be mapped to the derived function so that the derived function contains the same transactions and access rights as the master function. Finally the organizational values are adapted. Transactions and access rights must never be changed, deleted or extended in the derived function. This will be always done through the master function. Local functions Local functions contain directly all transaction and access rights including organizational values of a local business process. 6.3.6.5 Business Roles Update Business roles will be always updated in the development system N08. Once tested the business roles are transported to the corresponding production system. There can be different reasons for a business role update: A. Update of transactions Transactions can’t be added or deleted directly from business roles. It has to be analyzed which functions are affected and depending on the type of function the following has to be considered: Master function First it has to be taken into account that a master function will be derived and therefore the update will affect all derived functions assigned to a master function. Page 74 of 111 Version 1.93 Classification: internal SoD Documentation Then the transactions have to be added and/or removed and the corresponding authorization objects have to adapted. Finally the master function has to be saved, generated and derived. Derived function Transactions must never be updated in derived functions. Local function Transactions have to be directly added and/or removed and the corresponding authorization objects have to be adapted. Finally the local function has to be saved and generated. B. Update of non-organizational authorization data Non-organizational authorization data (e.g. document type…) can’t be added, changed or deleted directly from business roles. It has to be analyzed which functions are and depending on the type of function the following has to be considered: Master function First it has to be taken into account that a master function will be derived and therefore the update will affect all derived functions assigned to this master function. Then the non-organizational data has to be updated. Finally the master function has to be saved, generated and derived. Derived function Non-organizational authorization data must never be updated in derived functions. Local function Non-organizational authorization data has to be directly updated. Finally the local function has to be saved and generated. C. Update of organizational authorization data Organizational authorization data (e.g. company code…) can’t be added, changed or deleted directly from business roles. It has to be analyzed which functions are affected and depending on the type of function the following has to be considered: Master function Non-organizational authorization data must never be updated in master functions. This is done in the corresponding derived functions. Derived function Organizational data has to be directly updated in derived functions. Finally the derived function has to be saved and generated. Local function Organizational authorization data has to be directly updated. Finally the local function has to be saved and generated. Classification: internal Version 1.93 Page 75 of 111 SoD Documentation 6.3.7 SU24 The standard SAP transaction SU24 is used to control different properties of transactions and their authorization objects. Once executed for a certain transaction code SU24 contains the relationship between transaction code, authorization object, check indicator and proposal, e.g. for FBL5N: The possible configurations are per transaction code and authorization object are: 1. CHECK INDICATOR a. C = Check (if checked in the ABAP code) b. N = Do not check (even if checked in the ABAP code) 2. PROPOSAL a. YES (CM) = Pulls all maintained objects, their fields and values into the role when the transaction, function module or service is added to the menu tab in transaction PFCG b. NO (N) = Objects are not proposed in PFCG but will generally be checked even if not required for the transaction c. `` (U) = Unmaintained or unknown The configuration of SU24 is directly linked to the profile generator (PFCG). The different configurations of SU24 do have the following impacts: Authorization objects which never need to be checked can be disabled so that they don’t appear automatically in PFCG and won’t be checked in SAP Authorization objects which should be always checked but shouldn’t be proposed in PFCG can be defined so that they don’t appear automatically in PFCG Authorization objects which should be always checked and proposed in PFCG but without a proposed value can be defined so that they appear automatically in PFCG but the values have to be entered (yellow light) Page 76 of 111 Version 1.93 Classification: internal SoD Documentation Authorization objects which should be always checked, proposed in PFCG with their values can be defined so that they appear automatically in PFCG and don’t need further processing (green light) Changes of settings in SU24 can be updated directly to roles (read old, merge new" option in PFCG) The following restrictions have to be taken into account during the maintenance of SU24: SAP best practices recommend avoiding manually entered authorization objects and changes of proposed authorization values in PFCG. Some authorization objects proposed by SAP in the SU24 aren’t coded in the corresponding programs and therefore aren’t checked. Parameter transactions are linked to core transactions (see SE93, e.g. F-04 -> FB05) and therefore core authorization objects can be pulled from core transactions Custom transactions and authorization objects have to be added manually to SU24. Release upgrades require additional control of SU24 in order to avoid inconsistencies 6.3.7.1 SU24 - Future mode of operation and maintenance The following processes have been defined for the maintenance of the SU24: A. Elimination of proposed Security Policy Conflicts The actual SU24 entries have been analyzed and it has been determined that actually in the development system N08 there are approx. 4000 entries of SU24 proposing authorization objects with values generating SoD conflicts. These entries will be adapted in order to propose values which don’t cause conflicts. B. CustomTransactions Authorization Objects All custom transactions must be maintained in SU24. Additionally all authorization objects of transactions called by the transaction have to be also maintained. Important: The future mode of operation depends directly on the requirements of the new compliance control tool and will be reviewed once the selection of the compliance control tool is made. 6.3.8 Customer specific authorization objects It will be always recommended to use SAP standard authorization objects in order to fulfill all requirements. However, if there aren’t alternative standard authorization objects available it has to be analyzed at transaction level if customer specific authorization objects can be implemented. In case of implementation it has to be taken into account that customer specific authorization objects require ABAP development. Customer specific authorization objects have always to start with Y or Z. 6.3.9 Authorization Groups Authorization groups aren’t used. Classification: internal Version 1.93 Page 77 of 111 SoD Documentation 6.3.10 Further Restrictions The direct access to SAP applications, programs and tables won’t be permitted to end users. Examples for restricted transactions are: o Tables: SE16, SM30/SM31 o Programs: SE38 o Queries: SQ00 The process to follow is to create a Z-transaction with the corresponding technical authorization objects. 6.3.11 Current Business Roles In this section we describe the managament of special functions and Business Roles that are out of the scope of SIGMA but need to be considered as a part of the concept because they deal with special or critical access. 6.3.11.1 IT Business Roles IT Business Roles aren’t in the scope of project SIGMA therefore they will be managed according to the current authorization concept. IT Business Roles are based on CC with the following levels: Level 1: Level 2: Level 3: Level 4: Display Maintenance tasks on daily basis. Approval from the business is required Basic critical tasks Maintenance tasks for a project. It has a validity date. Currently there are IT Business Roles defined for the following divisions: Page 78 of 111 ALE BI CAS EDI FI: o COPA o COPC ITG LOG o INV o MP o QM o SCP o WM o PTP PM/PS ARCHIVING BASIS CRM MD HELPDESK Application Responsible SD Version 1.93 Classification: internal SoD Documentation o GTS User Admin XAS- Authorizations Rule for the development of IT Business Roles: The following rules are used since July 2009. Level 1: DAAXXXXXBITXD AA = system where the role is developed/maintained XXXXX = is fixed, to denote it’s a master Function B = is the module following the standard SAP R/3 abbreviation for modules. ITX = is fixed, to denote it’s IT function D = Display Level 2: DAAXXXXXBITXA_CCC AA = system where the role is developed/maintained XXXXX = is fixed, to denote it’s a master function B = is the module following the standard SAP R/3 abbreviation for modules. ITX = is fixed, to denote it’s IT function A = Maintain CCC = Competence Center Level 3 and Level 4: The functions are the same as used in the normal business roles These Business Roles are maintained in template. This means that only a CC manager can raise a CR to modify the authorizations on the function. It is no valid to create a remedy ticket. 6.3.11.2 Intercompany Business Roles Users with intercompany Busines roles have to manage processes not only in one country/company but all companies within an area (WE, NA…). To ensure the access rights to the desired processes and countries a local business role will be created. 6.3.11.3 Corporate Business Roles Users with corporate Business Roles have to access processes within different countries in order to give support to local users. To warranty the access rights to the desired processes and countries a local business role will be created. 6.3.11.4 SSC Shared Service Center Business Roles Users with shared service center Business Roles have to access particular processes within certain countries. To ensure the access rights to the desired processes and countries a local business role will be created. Classification: internal Version 1.93 Page 79 of 111 SoD Documentation 6.3.11.5 RFC/CPIC and Batch Userid Business Roles Roles for RFC and batch users aren’t in scope and will be managed according to the actual authorization model: RFC and Batch userids might have the need for special authorizations to perform their tasks. These type of userids can’t be called in dialog mode; so if an authorization error is presumed, it will be necessary to set up a security trace in order to find out the correct authorizations needed. Be aware that not all checked objects are required for this userid, because SAP is checking all statements in the program and the values found in the trace need to be interpreted. The naming convention of the business roles for these userids doesn’t differ from the standard naming convention. However since most of these userids will be used for several countries, companies or any other type of organizational element no restriction indicator will be required (unless if the need is specifically defined). Example: D01XXX_RFC_OTCRFC Function for RFC userid OTCRFC. This Business Role can contain any normal type of function, but sometimes, it is necessary to define a special Function for one of these userids, due to the results obtained in the tracing. In this case a specific function should be created which contains the specific objects for the RFC activity. The function usually doesn’t contain transactions in the menu, in contradiction to normal functions. Regarding the naming of these special functions, the current naming convention should be respected which is valid for all functions. It should be unique within the Henkel server landscape with respect to the specific naming conventions corresponding to the respective development system where it is developed. As a module indicator the letter ‘R’ must be used. Example: D08XXXXXRZ01A Henkel Custom: OTCRFC authorizations. In this case the task is valid for the P08/P68 only. General functions must include a Y after the module indicator. The same rules are applicable for batch userids, but here the naming convention of the batch userids will contain BTC instead of RFC. Example: D12XXX_BTC_ARCHIVING Batch userids will contain normally more regular functions for reasons of background processing of batch inputs etc. 6.3.12 Emergency procedure : Quickfixes The Quickfix procedure allows for fast authorization error support without business interruption while preserving the regular change management procedures. The regular change management procedure on security changes is that if a role / function needs to be adjusted due to an identified authorization error, the change is to take place in the development environment. Subsequent transports will make the change available in the Test- or Production environment. This is still the most recommended approach towards security problems, however, depending on the project phase or situation, timeliness may be more important and a faster way of dealing with authorization errors is desirable. That approach may have to overcome the transport latency, but should not undo or neglect proper change management practices. The Quick Fix Procedure is simple, provides with the ability to quickly fix security problems and to keep track of an “error history”. In brief, the Quick Fix Procedure works as follows: Page 80 of 111 Version 1.93 Classification: internal SoD Documentation 1. Authorization Error. An authorization error is reported by a user. This error is to be addressed in a timely manner; 2. Recording of the Issue. The security administrator requests the authorization error information electronically. The user should provide with transaction code, SU53 information and his/her own user-ID and contact information; 3. Quick Fix. If an authorization object or field value is missing in the existing role(s), a manual profile is created using transaction SU02. This manual profile has naming convention ZFIX#### where each the “####” is a sequential number. Also note that if the user needs a particular transaction code or access that was not allocated according to the FU-TA, the solution is NOT quickfixing, but informing the user that he/she was not authorized by the responsible manager to have that functionality! Note that each ZFIX#### profile must have a decent description indicating the problem or a reference to the issue recording (step 2). The sequential number starts from 0001 and for each problem the number is incremented with 1; 4. Allocation to user. The quick fix manual profile is allocated to the end user that had the problem and depending on the situation to other users that share the problem or responsibility of that particular user. Note that this is a direct user assignment of a manual profile; 5. Informing the User. Steps 2,3 and 4 have a walk-through time of maximum 5 minutes. Once the authorizations of the user were changed, inform the user (preferrably by phone) that the problem was fixed and he/she needs to logoff/logon to test whether it now works. 6. Fixing the backlog. On a daily basis and preferrably as soon as time is available, the actual master tasks and derived tasks are to be updated with the information contained in the quickfix. This means that analysis has to take place to see what value/object was missing from which role and whether it was the proper solution to give these access rights to the user. The failing authorization role(s) are updated with the appropriate objects and values in the Development Environment and are set ready for transport to the appropriate environments. In this step, the validity and completeness of the information in the issue recording (step 2) is critical. If no proper list is maintained and the SU53 information etc. is not kept, it is impossible to effectively clean-up and update the authorization concept; 7. Cleaning Up. After the corrected roles were transported correctly, the Quickfix profiles and authorizations are to be removed from the users and deleted. Note that in the end, ALL quickfixes are to be deleted. Fixes should be fixed at a daily basis and no fix should survive for more than 5 working days. 8. Documentation. Even if the quickfix is deleted in the next working day, the quickfix has to be documented in the AS database. In the documentation database you can find the template file and the instructions to document quickfixes. 9. Role instead of profile. If needed, or if the analyst considers it is a better way of solving the incidence, the quickfix can be created as a role instead of a profile. The naming convention should remain the same. The role can be created when the fix should remain for some time ( because a permanent solution cannot be applied for any reason or the exception has been approved). The advantages of the QuickFix procedure are: The change management procedure on roles is still in place. No deviation from this procedure is made; Classification: internal Version 1.93 Page 81 of 111 SoD Documentation User problems can be addressed in the fastest possible way. No transport latencies are stopping the business processes; A clear trail of manual profiles with a uniform naming convention is made available that shows the errors that occurred and what work has to be done subsequently; If proper change management and discipline is within the security department, all authorization errors are ressolved using the change management procedure and fixes are only temporary. The risks in this procedure are: Exposure. Administrators may allocate quickfixes to users without considering the functiontask matrix where responsibilities are shown. This means that users may receive unauthorized access. The positive thing within this procedure is that the exposure to this risk is limited as quickfixes should be solved on the same day; Deviation. The risk exists that administrators are not following the steps as described in this procedure to the very end – that is – fixes are created and allocated, but not really solved in the security roles. Alternatively, the administrators could “forget” to remove the fixprofiles after they have transported the corrected roles. This would eventually result in a unclear concept and it would become unclear whether or not problems were already solved; Page 82 of 111 Version 1.93 Classification: internal SoD Documentation 7 Software (TO BE UPDATED) This chapter describes the tool landscape for the processes listed in chapter 4: “Identity & Access Management Processes”. 7.1 Overview of SoD Tool Landscape Can stay here. SCT SoD Framework Gov. IAM 600-604 SoD Framework SCT RO SAP GRC AC SAP ERP RAR BIC SoD Compliance Ctrl IAM 501-510 RA RA CUP SV User Authorizations User Auth. Admin IAM 200-210 User RO PTP OTC process User Auth. Config. IAM 300-310 COCOS SoD Compliance Ctrl IAM 500 Compensating Control Reports RAP IdM HAD User Auth. Admin IAM 210 User ID Administration IAM 001-003 / IAM 100-110 User Auth. Ownership IAM 400-411 Roles: - SCT – SoD Coreteam (in persona: SoD Compliance Manager) - RO – Role Owner - RA – Role Admin - User – End user of SAP ERP system - SV – Supervisor of end user Tools: - RAR - CUP - COCOS - RAP - BIC Classification: internal Version 1.93 Page 83 of 111 SoD Documentation - HAD 7.2 Tools 7.2.1 SAP GR AC – Access Control Can stay here as focus is only on SoD. 7.2.1.1 Overview 7.2.1.2 CUP - Compliant User Provisioning Overview CUP workflow Supervisor: - notified via mail on authorization change Role Admin (SPOC): - Check request - Select auth. roles - SoD Risk Analysis - Remediation in case of SoD conflicts - Reject or approve Stage 0 Stage 1 Request Role Selection End User: - Free Text: “I need …” - Reasoning - Selection of system - Selection of Role Admin Stage 2 Stage 2 Role Stage 2 Approval Role approval Role Approval SAP System: Automatic provisioning/ removal of roles in SAP system Role Admin (Approver): - Risk Analysis - Reject or approve A Compliant User Provisioning workflow needs to be activated at the very end of the SoD implementation in order to ensure that users are kept SoD-compliant. The CUP tool prevents from assigning new red SoD-conflicts in the future w/o mitigation control. 7.2.1.3 RAR – Risk Assessment & Remediation Overview RAR is a component of the SAP GRC AC tool suite. RAR analyzes user authorizations and role design on potential SoD conflicts. RAR uses a rule set defined in the master data of the RAR tool. RAR SoD Role Analysis RAR offers functionality to analyze SoD conflicts within authorization roles. Please refer to the training documentation provided in the Portal (http://CUP/). The Role analysis is conducted in each role change (see process 4.3.2: “Change Role (IAM-301)”). Typically the SoD analysis is done on Consolidation system before the roles are transported to productive SAP. In this case RAR is running in CRC, which is connected to all SAP ERP consolidation systems. Page 84 of 111 Version 1.93 Classification: internal SoD Documentation The output of the RAR analysis can be downloaded into a SoD Template Excel for role analysis which helps to identify the root causes of SoD conflicts. RAR SoD User Analysis RAR offers functionality to analyze SoD conflicts on user level. Please refer to the training documentation provided in the Portal (http://CUP/). The SoD user analysis is mandatory in each CUP request (i.e. risk violation analysis), but can also be run manually for one user or a user group via the RAR tool. The SoD user analysis is done on Productive system PRC which is connected to all productive SAP ERP systems. The output of the RAR analysis can be downloaded into a SoD Template Excel for user analysis which helps to identify the root causes of SoD conflicts. 7.2.2 COCOS – Compensating Control System Stay here as focus is only on SoD. 7.2.2.1 Overview The Compensating Control System at Henkel is not looking at the authorization level (i.e. what a user is allowed to do), but on the actual transactions in the system (i.e. what a user actually posted). In each SAP ERP system various Compensating Control reports are activated which screen all postings made during a past period, and detect if one and the same user posted two steps in a document which should be posted by two different persons following the Corporate Standard SoD. These “potential SoD violations” are stored in a central table per SAP system and transferred to a globally centralized SAP table in the SAP GRC database. Supervisor information is added from the central user administration tool HAD, which is synchronized with the Global HR system. Classification: internal Version 1.93 Page 85 of 111 SoD Documentation Compensating Control System (COCOS) Technical Overview Compensating Control Reports HR Supervisor Information Weekly trigger mail to Supervisors to check Compensating Control with link to Web application P01 … SAP GRC P93 “Watch Dogs” for SoD violations 16 Compensating Control reports per SAP system detect actual SoD violations on document level (e.g. same user created purchase order and posted the goods receipt) Web application for supervisors to check and approve Compensating Control reports Central Data Storage of all SoD violations and logging of approval / disapproval by Supervisors in SAP GRC Approve Logging of approvals in Central Data Storage on SAP GRC GRC – SAP tool “Governance, Risk & Compliance“ Page 5 28-Nov-2012 SoD @ Henkel / COCOS If one or more employees of a supervisor’s team are listed in the central table, the Supervisor is informed via mail to check these cases and to approve. In SAP the transactions are executed and are not waiting for this approval. So the Compensating Control approval is an ex-post approval. The approval of the Supervisor is logged in the central table in the SAP GRC for later audit purposes. Please visit the SoD Forum to learn more about the COCOS tool and to find a eLearning document for training purposes (http://sodforum/) 7.2.2.2 COCOS Web Tool 7.2.2.3 COCOS Data Collection + Mail Notifying 7.2.2.4 Compensating Control Reports OTC Page 86 of 111 Version 1.93 Classification: internal SoD Documentation 7.2.2.5 Compensating Control Reports PTP 7.2.3 BIC – SAP ERP Built-in Controls Stay here as focus is only on SoD. 7.2.3.1 Overview 7.2.3.2 Built-in Controls OTC 7.2.3.3 Built-in Controls PTP 7.2.4 RAP – Reapply Roles To be moved to ACC chapter 5. 7.2.4.1 Overview Program 1 : RAP Mass change of end validity date Program 2 : RAP Data collector Program 3 : RAP Email sending HR User IDs Supervisor Information P01 … PRC P93 Report that collects auth/user and checks if roles will not expire 8 wks prior to first role would be expired with info on what to do to user First reminder : 4 wks prior to first role would be expired with info on what to do to user + cc supervisor Second reminder : 3 days prior to first role would be expired with info on what to do to user + cc supervisor The RAP tool is actually a collection of individual programs rather than a tool suite. Basic idea of the review process is not to do a review of user authorizations. Instead all user authorizations of dialogue users are limited to 4 months and users have to request a prolongation (i.e. “re-apply”). For this purpose the same CUP tool is used: Classification: internal Version 1.93 Page 87 of 111 SoD Documentation CUP request workflow 1) User creates a CUP request to prolong his authorisations and assigns this to his Role Admin (SPOC) 2) Role admin (SPOC) selects "Existing Assignments" + Action "Retain“ where needed + runs optional SoD Check Role admin can overwrite the validity period The validity period should be automatically set to today+XX month Role owner 3) Role assignment approver(s) will receive the request and will judge on the retention of the roles or not and runs an SOD check. 4) Enduser + supervisor receives a notification User SPOC Profile updated 7.2.4.2 RAP Program “Mass Change Validity Periods” 7.2.4.3 RAP Program “RAP Data collector” 7.2.4.4 RAP Program “RAP e-mail sending” Page 88 of 111 Version 1.93 Classification: internal SoD Documentation 7.3 Operational Model ???? 7.3.1 Tool Ownership 7.3.2 Incident Management Regulations -link to Incident Management document??? 7.3.3 Change Management Regulations Link to Change Management document??? Classification: internal Version 1.93 Page 89 of 111 SoD Documentation 8 Reporting & KPI Stay here. 8.1 Global SoD Anaylsis (GSODA) On a monthly basis all SAP users worldwide are analyzed on red SoD conflicts. The users are reported per country / business unit where the users are located, independent of the country and SAP system the users are working for. E.g. a user in the SSC Philippines working for NA is reported in APAC / Philippines. GSODA is analyzing SoD conflicts within a system (e.g. Purchase order and payment in P01) as well as cross-system SoD risks (e.g. Master data on corporate SAP master data system P03 (IDH) X payment on Finance SAP system P08). 8.1.1 KPI definition The KPI “SoD Compliance (GSODA)” is defined as #users having no red SoD conflict (single system or cross-system SoD conflicts) ----------------------------------------------------------------------------------------------------------- x 100 #users having access to SAP ERP systems in scope [in %] 8.1.2 Scope All SAP ERP users w/w of the systems in scope are analyzed. SAP systems in scope are WEU: P01, P03, P08, P11, P12 NA: P03, P60, P62, P68 MEA: P03, P50, P92 APAC: P03, P93 LA: P03, LA1 CEE: none SAP ERP system not in scope: APAC: HK2 being substituted by P93 by program Horizon (included in scope above) CEE: being substituted by P92 by program Horizon (included in scope above) HP1 and all non-ERP SAP systems covering APO, HR, CRM etc. Page 90 of 111 Version 1.93 Classification: internal SoD Documentation as of Jan 9, 2013 Global SoD Analysis Henkel Total number of users: 17.319 SoD compliant: 11.901 (69%) Henkel by Regions Henkel by Regions 9.000 100% 8.000 90% 7.000 80% 70% #Users #Users 6.000 5.000 4.000 3.000 60% 50% 40% 30% 2.000 20% 1.000 10% 0 0% AP LA MEA NA WEU AE (P72) Others AP LA MEA Henkel by BU/Function WEU AE (P72) Others Total Henkel by BU/Function 9.000 100% 8.000 90% 7.000 80% 70% #Users 6.000 #Users NA 5.000 4.000 3.000 60% 50% 40% 30% 2.000 20% 1.000 10% 0 0% W K A FO FP FC FS Red SoD conflicts SoD compliant Page 4 9-Jan-2013 HR VS VT Others W K A FO FP FC FS HR VS VT Others Total AP: P93 (Horizon) only; CEE: not included, will be connected via Horizon Region “Others”: Users working for different region only Segregation of Duties @ Henkel - KPIs 8.2 System SoD Analysis (SSODA) On a monthly basis all SAP users worldwide are analyzed on red SoD conflicts. The users are reported per system they have access to. E.g. a user in the SSC Philippines working for NA (P68) is reported on P68 (NA). SSODA is analyzing SoD conflicts within a system only. Cross-system SoD risks are neglected. 8.2.1 KPI definition KPI “SoD Compliance (SSODA)” is defined as #users having no red SoD conflict (single system SoD risks only) -------------------------------------------------------------------------------------#users having access to SAP ERP systems in scope x 100 [in %] 8.2.2 Scope All SAP ERP users w/w of the systems in scope are analyzed. SAP systems in scope are WEU: P01, P03, P08, P11, P12 NA: P03, P60, P62, P68 MEA: P03, P50, P92 Classification: internal Version 1.93 Page 91 of 111 SoD Documentation APAC: P03, P93 LA: P03, LA1 CEE: none SAP ERP system not in scope: APAC: HK2 being substituted by P93 by program Horizon (included in scope above) CEE: being substituted by P92 by program Horizon (included in scope above) HP1 and all non-ERP SAP systems covering APO, HR, CRM etc. as of Jan 14, 2013 System SoD Analysis Henkel1) Total No of SAP accounts2): 30.103 SoD compliant: 21.463 (71%) Henkel by SAP Systems Henkel by SAP Systems 6.000 100% 90% 5.000 80% 70% #Users #Users 4.000 3.000 2.000 60% 50% 40% 30% 20% 1.000 10% 0 0% P01 P03 P08 P11 P12 P50 P60 P62 P68 LA1 P72 P92 P93 P01 P03 P08 P11 Henkel by SAP Platforms P50 P60 P62 P68 LA1 P72 P92 P93 Total Henkel by SAP Platforms 16.000 100% 14.000 90% 80% 12.000 70% #Users 10.000 #Users P12 8.000 6.000 60% 50% 40% 30% 4.000 20% 2.000 10% 0 0% CORP GSP WEU GSP NA Red SoD conflicts SoD compliant Page 2 Page 92 of 111 9-Jan-2013 GSP MEA LA1 HORIZON 1) 2) Global AE CORP GSP WEU GSP NA GSP MEA LA1 HORIZON Global AE Total HK2 (APAC) and HP1 (CEE) not included, will be connected via Horizon Total No. of SAP users: 17.319 Segregation of Duties @ Henkel - KPIs Version 1.93 Classification: internal SoD Documentation 9 Training & e-Learning Stay here??? 9.1 SoD Portal Page A Henkel portal page serves as first contact for end users and Role Admins. The portal page explains to the end user how to request authorizations with the CUP tool. A special section for Role Admins explains how to run RAR analyses and how to proceed CUP requests. The Portal page is available in some country versions, translated in local language. The Portal page is open for every user at Henkel. Link: http://portal.de.henkelgroup.net/irj/portal/global/8VQKMQ898JREN Portal Short Cuts: CUP, RAR, SOD, SIGMA, PRC, GRC 9.2 SoD Forum The SoD Forum is a discussion forum including a Q&A section for all topics around SoD. The SoD Forum is available in English only. The SoD Forum is open for every user at Henkel. Link: http://connections.henkelgroup.net/communities/community/sod Portal Shortcut: sodforum Classification: internal Version 1.93 Page 93 of 111 SoD Documentation 9.3 Training Can stay here. 9.3.1 CUP tool 9.3.1.1 CUP tool training for end users Target group: End users working with SAP ERP systems Available training types: end user manual (PPT) e-Learning Video no classroom training available Access to training: via SoD Portal Page Contact: Britta Winkelmeyer@henkel.com 9.3.1.2 CUP tool training for Role Admins Target group: Role Admins (SPOC) Role Admins (Assignment Approvers) Available training types: Classroom + Remote Training Sessions Training document (PPT) e-Learning Video Access to training: via SoD Portal Page Contact: Britta Winkelmeyer@henkel.com 9.3.2 RAR tool Target group: Page 94 of 111 Role Admins (SPOC) Version 1.93 Classification: internal SoD Documentation Role Admins (Assignment Approvers) Role Owners Available training types: Classroom + Remote Training Sessions Training documents on RAR analyses (PPT) e-Learning Video Access to training: via SoD Portal Page / Instructions for Role Administrators Contact: Britta Winkelmeyer@henkel.com 9.3.3 COCOS tool Target group: Supervisors Available training types: Help function in COCOS tool COCOS manual for Supervisors no classroom training available Access to training: via SoD Forum: “Compensating Control System COCOS: How does this work?” Link: SOD FORUM_COCOS Contact: Frank.Junglas@henkel.com Classification: internal Version 1.93 Page 95 of 111 SoD Documentation 10 Appendix 10.1 FAQ 10.2 Glossary Stay here. Term Acronym Description Access Rights A user needs a user-ID and a password, and access rights assigned to the user-ID to be able to enter IT systems or applications. This authentication does not automatically imply authorization within the IT system. It’s like the “key to the main entrance of a building”. Authorization Concept The Authorization Concept describes the structure and design of authorizations to users. An authorization concept is defined in Enterprise Roles and Business Roles in business terms, as well as a translation into technical authorization objects within an IT system (Technical Authorization Concept). Authorization Configuration processes and compliance controls configuration of Business Roles Authorizations Authorizations (also privileges, entitlements, permissions) determine what a user can do on the system, once authenticated with user-ID and password. Authorizations enable users to use certain functionality or to display information of the IT system. Authorizations are like “keys to doors within a building”. Built-in Controls Built-in system behavior that prevents a user to conduct two functions that are defined as a SoD risk. This control is a Segregation of Duties, when certified as “proven security”. that support the Example: A user has the authorization to create a purchase order and to book a goods receipt against purchase orders. A built-in control could be a user exit in SAP that blocks a user from booking a goods receipt against purchase orders, the user created him/herself. If it is proven that no user can by-pass the Built-In Control, this control is a valid Segregation of Duties. Business Roles Compliance Control Tool Page 96 of 111 Business Roles (or Roles in this context) define groups of authorizations within an IT system in business terms. Roles contain the authorizations that a user needs to work. Role Administrators grant authorizations to employees or external staff (users) by assigning specific Roles to their user-IDs. CCT The Compliance Control Tool is used in the provisioning process of user authorizations. It contains the SoD rule set as master Version 1.93 Classification: internal SoD Documentation data. Main tasks are - Detective reports on SoD conflicts - Preventive SoD authorizations - SoD checks of authorization role changes - Exception handling checks on requests for new COBIT The Control Objectives for Information and related Technology (COBIT) is a set of best practices (framework) for information technology (IT) management created by the Information Systems Audit and Control Association (ISACA), and the IT Governance Institute (ITGI) in 1996. COBIT provides managers, auditors, and IT users with a set of generally accepted measures, indicators, processes and best practices to assist them in maximizing the benefits derived through the use of information technology and developing appropriate IT governance and control in a company. Compensating Controls Compensating Controls are controls which compensate for missing segregations of duties (i.e. for approved SoD conflicts). These can be: - Preventive Controls: Ex-ante controls that prevent fraud e.g. “2-pairs-of-eyes”-principle at credit note processing Detective Controls: Ex-post controls that allow detecting if unwanted events of SoD risks have occurred. Where automated systems provide basis information for detective controls, manual monitoring processes are required for review of this information. Example: An exception report is regularly provided by IT-application and lists the actual bookings by users with SoD-conflicts; the manager in charge is required to review this report timely and to sign-off the listed transactions retrospectively. Critical Roles Critical Transactions Some Roles might be critical in itself. Reasons might be: - Role that bear a SoD conflict in itself (defined exceptions) - Privileged authorizations for e.g. process owner, key user, etc - Collection of critical transactions in a critical role to control their assignment to users Some single transactions have an inherent risk and are defined as critical transactions. Examples: Classification: internal Version 1.93 - Technical transaction: Debugging with (prohibited by IT Security Policy in all cases) replace - Business transaction: Release of vendor payment block (only assigned to a limited number of well instructed Page 97 of 111 SoD Documentation users) Detective Controls Detective controls detect the occurrence of SoD risks ex-post. Controls can be Enterprise Roles - Periodic monitoring of user accounts with approved SoD conflicts - Compensating Controls like manual ex-post review of actual user bookings Enterprise Roles define access rights and authorizations within the entire enterprise, i.e. across IT systems and applications. Global SAP Platform GSP Globally standardized business processes and standard SAP systems Henkel Meta Directory HMD … Identity and Access Management IAM IAM is an administrative area that deals with identifying individuals in a system (such as a country, a network or an organization) and controlling the access to resources in that system by placing restrictions on the established identities. Identity Management IdM Process and tool landscape for managing the lifecycle of userIDs. Services: User administration, IAM Request Mgmt, IAMReports. ISO 27002 ISO 27002 is an information security standard published by the International Organization for Standardization (ISO). ISO 27002 provides best practice recommendations on information security management for use by those responsible for initiating, implementing or maintaining Information Security Management Systems (ISMS). Least Authority See Need-to-Know principle Least User Access See Need-to-Know principle Least-Privilege See Need-to-Know principle Need-to-Know Principle The Need-to-Know Principle (also known as least user access, least privilege, or least authority) describes a security concept, in which all users at all times should run with as few authorizations as possible, and also launch applications with as few access rights as possible. The principle is widely recognized as an important design consideration in enhancing the protection of data and functionality from faults (fault tolerance) and malicious behavior (computer security). Preventive Controls Privileged Authorizations Page 98 of 111 Controls that prevent the occurrence of SoD risks. Controls can be - Segregation of Duties in role design - Segregation of Duties in user authorizations - Built-In Controls in business transactions - Compensating Controls like additional “2-pairs-of-eyes”principle. Some users need access rights and authorizations beyond the Version 1.93 Classification: internal SoD Documentation usual scope or beyond the profile of the employee, in order to support others or other topics. Examples can be a Key User, a Business Process Owner, a temporary project member, etc. The Privileged Authorizations assigned in these cases require a special handling and controls beyond the usual control. Request & Workflow Tool R&WT Roles Segregation of Duties The Request and Workflow tool is used by end-users to place requests on assignment or removal of authorization roles and to direct the request to a named Role Admin See Business Roles SoD Segregation of duties (SoD) is the concept of having more than one person required to complete a task. Besides organizational measures this includes the segregation of access rights to and authorizations within the corresponding IT systems. SoD Compliance Governance processes and compliance controls that support the Governance of SoD Compliance SoD Conflict A SoD conflict occurs, when a user actually has the authorization to conduct a combination of duties in a business process that is defined as a high or very high SoD Risk in the SoD Framework. Depending on the risk rating, SoD Conflicts can be neglected (low risk), or require approval (high risk, controlled with a Compensating Control). In case of very high risk, SoD conflicts are not allowed; the duties have to be segregated. SoD Controls The segregation of areas of responsibility in business processes and of corresponding authorizations, access rights, and built-in system behavior within the IT systems is called SoD Control. This is a preventive control against SoD-risks. SoD Framework The SoD Framework is a set of rules that defines which combinations of functions have to be segregated in a business process in order to mitigate the risk of fraud and erroneous transactions. SoD Risks The SoD Framework (see chapter 10.4: “Enclosures”) defines combinations of duties as “High” or “Very High” risk. These potential combinations are called SoD Risks. The combinations are marked in the SoD matrix as “High” or “Very High” and are described in the SoD Risk Register with examples. Technical Authorizations Technical Authorizations define the technical objects with an IT system (e.g. SAP tables, transactions, plant, sales organization, etc. Dangerous Combination of Roles The Authorization Concept uses Roles that group authorizations which a user needs to execute business functions in an IT system. Objective is to ease the assignment of authorizations to users, but also to ensure that every user has exactly the authorizations he/she needs to perform business functions in a compliant way. Roles are designed not to have a SoD conflict within the role itself. I.e. every user with one role assigned shall be free of SoD conflicts. Only with the assignment of two or more roles to a Classification: internal Version 1.93 Page 99 of 111 SoD Documentation user, a SoD conflict might occur. There exist pairs of Roles that contain duties that are marked as a SoD risk in the SoD framework. With the assignment of both Roles to a user, a SoD conflict occurs. The combination of these Roles is called a Dangerous Combination. Example: Role “Procurement” and Role “Warehouse” are in itself free of SoD risks. The role “Procurement” contains among others the function “create purchase order” and the role “Warehouse” contains among others the function “book goods receipt”. The combination of these functions (“create purchase order” and “book goods receipt”) is a SoD risk identified in the SoD matrix. Thus assigning the two roles “Procurement” and “Warehouse” to a single user would lead to a SoD conflict. I.e. “Procurement” and “Warehouse” are a. User A user is a person in a company that uses an IT system. User Authorization Administration processes and compliance controls that support the life cycle of user authorizations within an IT system User ID Administration processes and compliance controls that support the life cycle of user IDs User-ID A user-ID (also called user account) identifies a user (employee or Contractor) within the company by the username. It allows one to authenticate to IT systems. It also generally provides one with the opportunity to be authorized to access them. Page 100 of 111 Version 1.93 Classification: internal SoD Documentation 10.3 Acronyms Acronym Acceptation AC Access Control ACL Access Control List ADS Active Directory Service BI Business Intelligence BPO Business Process Owner CCT Compliance Control Tool COBIT Control Objectives for Information and related Technology CUP Compliant user provisioning component GHR Global HR System GRC Governance, Risk, and Compliance. Here: Synonym for software to check and monitor SoD compliance GSD Global Service Delivery (IT) GSP Global System Program (Global SAP Platform) HAD Henkel Active Directory HMD Henkel Meta Directory (IT tool) HR Human Resources IAM Identity & Access Management IdM Identity Management ISO International Organization for Standardization IT Information Technology JCo Java Connector LDAP Lightweight Directory Access Protocol OTC Order-to-Cash PTP Purchase-to-Pay RAR Risk analysis and removal RFC Remote Function Call RTA Real time agent R&WT Request and Workflow Tool SAP BO AC SAP Business Objects Access Control (GRC) SMTP Simple Mail Transfer Protocol SoD Segregation of Duties SPML Service Provisioning Markup Language VIA Internal Audit at Henkel Classification: internal Version 1.93 Page 101 of 111 SoD Documentation 10.3.1.1 Country codes Stay here or to place in ACC. The country codes are fixed and only the below indicated country codes may be used. ID Country AT Austria BE Belgium BX Benelux CH Switzerland CN China DA Denmark DE Germany ES Spain FI Finland FR France GR Greece HK Hong Kong IB Iberia IR Ireland IT Italy LU Luxembourg NL Netherlands NA North-Americas NO Norway PT Portugal SW Sweden TU Turkey UK United Kingdom US United States Note 1: BX is the combined codification of NL, LU and BE; Note 2: NA is currently used for North-America, in the future this will be changed to the appropriate ISO country codes; Note 3: Not all countries where Henkel has representation are listed. Countries are added when addressed in the current projects. Note 4: IB is the combined codification of ES and PT Page 102 of 111 Version 1.93 Classification: internal SoD Documentation 10.3.1.2 Company Indicator Stay here or to place in ACC. The company code indicator is a 1-character identifier for a particular enterprise within the GSP systems. Initially, a logical abbreviation is seeked (H for Henkel, L for Loctite, S for Schwarzkopf). This is done because these businesses re-occur in many countries. If no logical character can be found, a sequential alphabetical character will be set to use. Note that deciding the appropriate character is a technical security team decision that has no impact on the project(s) or the business. Below the currently allocated combinations are shown: Classification: internal Country AT Company S Description Schwarzkopf Austria BE H Henkel Belgium BE L Henkel Loctite BX H Henkel Benelux BX S Schwarzkopf Benelux BX X Benelux General CA T Canada Service Technologies DE A HENKEL KGaA /TM/SE (Sichel) DE B HENKELTeroson Heidelberg DE D Dorus Bopfingen DE K Cognis DE DE O S SHCP Schwartzkopf Henkel C. Production Schwarzkopf Hamburg DE T Service Technologies – Germany DE Z Concept Task for non-migrated KgaA FR L Loctite Luxembourg FR T Luxembourg Service Technologies FR Z France old concept IR L Loctite Ireland IT T Italy Technologies IT H Italy Henkel SPA IT S Italy Schwarzkopf & Henkel LU C Chemolux Luxembourg NA A North-America (U.S.) NA C Henkel Canada NA X North-America General NL H Henkel Netherlands UK L Loctite UK UK S Schwarzkopf UK US D U.S. Dial XX S Schwarzkopf International Version 1.93 Page 103 of 111 SoD Documentation 10.3.1.3 Business and Process Indicator The business and process code indicator is a 1-character identifier for a particular business and process within the GSP systems. Initially, a logical abbreviation is seeked (I for IT, F for finance, O for OtC...). If no logical character can be found, a sequential alphabetical character will be set to use. Note that deciding the appropriate character is a technical security team decision that has no other impact. Below the currently allocated combinations are shown: Page 104 of 111 ID Business A Adhesive I IT F Finance K Cosmetics W Detergent ID Process O OtC P PtP Version 1.93 Classification: internal SoD Documentation 10.4 Enclosures Stay here. 10.4.1 SoD Governance 10.4.1.1 Corporate Standard SoD Location: HimDOC: http://sf-apps-i201.de.henkelgroup.net/corporate/sustainability/himdochg.nsf Contact: Christian.twehues@henkel.com 10.4.1.2 SoD Relevant Transaction Directory Location: Lotus Notes Database “SoD Compliance Management” Folder “SoD Documentation” Document: “3. SoD Relevant Transaction Directory” Contact: Christian.twehues@henkel.com 10.4.1.3 SoD Relevant Permission Directory Location: Lotus Notes Database “SoD Compliance Management” Folder “SoD Documentation” Document: “ 4. SoD Permission Directory” Contact: Christian.twehues@henkel.com 10.4.1.4 GRC SoD Rule Set Documentation Location: Lotus Notes Database “SoD Compliance Management” Folder “SoD Documentation” Document: “ 5. GRC SoD Rule Set Documentation” Contact: Christian.twehues@henkel.com 10.4.1.5 SoD Compensating Control Directory Location: Lotus Notes Database “SoD Compliance Management” Folder “SoD Documentation” Document: “ 6. SoD Compensating Control Directory” Contact: Christian.twehues@henkel.com 10.4.1.6 SoD Built In Controls Location: Lotus Notes Database “SoD Compliance Management” Classification: internal Version 1.93 Page 105 of 111 SoD Documentation Folder “SoD Documentation” Document: “7. SoD Built-in Controls” Contact: Christian.twehues@henkel.com 10.4.1.7 SoD Compensating Control Reports Location: Lotus Notes Database “SoD Compliance Management” Folder “SoD Documentation” Document: “8. Compensating Control Reports” Contact: Christian.twehues@henkel.com Page 106 of 111 Version 1.93 Classification: internal SoD Documentation 10.4.2 Authorization Management 10.4.2.1 Global Role Ownership files Lotus Notes Database “Project SIGMA-2” Folder “SoD Green Roles” Document: “1. Global Role Ownership” Contact: Javier.Alvarez@henkel.com 10.4.2.2 Regional Role Ownership files Lotus Notes Database “Project SIGMA-2” Folder “SoD Green Roles” Document: “2. Regional Role Ownership” Contact: Javier.Alvarez@henkel.com 10.4.2.3 Local Role Ownership files Lotus Notes Database “Project SIGMA-2” Folder “SoD Green Roles” Document: “3. Local Role Ownership” Contact: Javier.Alvarez@henkel.com 10.4.2.4 Role Admin (SPOC) Table Lotus Notes Database “Project SIGMA-2” Folder “SoD Green Roles” Document: “4. Role Admin (SPOC) table for Role Selection Stage 1 in CUP” Contact: Javier.Alvarez@henkel.com 10.4.2.5 Role Admin (Assignment Approver) Table Lotus Notes Database “Project SIGMA-2” Folder “SoD Green Roles” Document: “4. Role Admins for Role Approval Stage 2 in CUP” Contact: Javier.Alvarez@henkel.com Classification: internal Version 1.93 Page 107 of 111 SoD Documentation 10.5 Revision History and Document Reviews Revision history Version Author Date Revision v 0.10 V 0.11 Christian Twehues Christian Twehues 16 August 2010 18 August 2010 V 0.12 V 0.13 Christian Twehues Christian Twehues 18. August 2010 19. August 2010 V 0.14 Christian Twehues 19. August 2010 V 0.15 Christian Twehues 23.08.2010 V 0.16 V 0.17 Christian Twehues Christian Twehues 27.08.2010 3.09.2010 V 0.18 V 0.19 Christian Twehues Christian Twehues 7.09.2010 10.09.2010 V 0.20 V 0.21 V 0.22 V 1.00 Christian Twehues Christian Twehues Christian Twehues Christian Twehues 21.09.2010 22.09.2010 23.09.2010 24.09.2010 V 1.01 Christian Twehues 27.09.2010 V 1.02 V 1.03 Christian Twehues Christian Twehues 5.10.2010 27.10.2010 V1.04 Koen Menten 15.11.2010 V1.05 Javier Romera 22.11.2010 V 1.06 Diego Alvarado 23.11.2010 V 1.07 Christian Twehues 30.11.2010 V 1.08 V 1.90 Christian Twehues Christian Twehues 13.12.2010 24.01.2013 V1.91 V1.92 Christian Twehues Christian Twehues 22.02.2013 23.04.2013 V1.93 Christian Twehues 23.09.2013 Initial version Check on consistency of Organizational Concept, Compliance Controls, IAM Process design, and Tool analysis. Process Numbering changed Process “Define Compensating Controls” and “Review Compensating Controls” changed from Role Owner responsibility to BPO responsibility Confirmation of 1-step approval for request and 2step approval for exception approval by S. Braun; Review of concept with Layla El Kastite on consistent Controls Feedback of First Integration Test (Role of Compensating Control Receiver skipped, tasks assigned to Supervisor, et al) Feedback of Stefan Braun, VIA Feedback of Coreteam on Organizational Concept: Changes to Role Owner and Role Admin Roles Feedback of Second Integration Test of Sept 6 Review of Chapter 9 and specified detailed requirements Several smaller corrections after review with HR Detailed requirements (chapter 9.7 – 9.9) added. Update of chapter 9.7.3, 9.8.1, and 9.8.2 Approval of Chapter 1-7 by Sounding Board Approval of chapter 9 by IT (SIGMA Tool Analysis) Results of Business Roles Requirements Analysis added to Chapter 8 Feedback of Barbara Schmitz Correction of smaller errors; description of Control C43 Documentation Built-In and Compensating Controls for PTP added Documentation Built-In and Compensating Controls for PTP added Documentation of Henkel Authorization Concept, Coexistence Plan, Migration Plan Feedback of KPMG on Technical Authorization Concept Documentation of functional specification of tools Documentation of the finally implemented processes and tools; first DRAFT General editing Update of chapter 5: SoD Governance. After installation of CRC system (consolidation system), and after HR joining the SAP GRC, the SoD governance framework required final stage Change of IAM-200: SoD Risk Analysis mandatory at stage 1-Role Selection and optional at stage 2Role Approval (before vice versa) Page 108 of 111 Version 1.93 Classification: internal SoD Documentation This document has been reviewed by Reviewer (Name, Organizational Unit) Date reviewed 1 First integration test (Felix Sobotka, Ilka Erkens, Andy Fischer, Nils Jung, Barbara Schmitz, Joachim Dahl, Layla El Kastite, Gereon Koks, Christoph Gramp, jochen.wiedemann@accenture.com): Processes IAM-200-203 and IAM-300-303 only Aug. 23, 2010 2 Stefan Braun, VIA Aug. 26, 2010 3 Coreteam, Feedback received from Barbara Schmitz, Gereon Koks, Felix Sobotka (and Martin Andersen for chapter 4 processes and tools) Sept 3, 2010 4 Second integration test (Felix Sobotka, Andy Fischer, Barbara Schmitz, Layla El Kastite, Gereon Koks): All Processes Sep 6, 2010 5 Ina Schreckenberger Sep 20, 2010 6 b Sep 23, 2010 7 SIGMA Sounding Board Sep 24, 2010 8 KPMG (chapter 8 & 12) Nov 26, 2010 9 This document was approved by Chapter Reviewer (Name, Organizational Unit) Date reviewed 1 1 to 4.4 SIGMA Coreteam Sep 20, 2010 2 1 to 7 SIGMA Sounding Board Sep 24, 2010 3 9 IT (SIGMA Tool Analysis) Sep 24, 2010 4 9 IT (GSD, PCA-ARC, SIGMA Tool Analysis) Nov 5, 2010 5 9 ARC Fit Meeting Nov 5, 2010 6 8 SIGMA Coreteam Nov 15, 2010 7 1-12 SIGMA Sounding Board Nov 19, 2010 8 9 SIGMA Coreteam (Request Tool within Compliance Control Tool) Nov 22, 2010 9 V1.93 SoD Coreteam June 27, 2013 Classification: internal Version 1.93 Page 109 of 111 SoD Documentation Page 110 of 111 Version 1.93 Classification: internal SoD Documentation Classification: internal Version 1.93 Page 111 of 111