QAD Enterprise Edition Segregation of Duties Presented By

QAD Enterprise Edition Segregation of Duties Presented By: Andy Vitullo Logan Consulting

Presentation Objective q. How to Deploy Segregation of Duties (SOD) along with Role Based Security to Ensure SOX Compliance § Role Based Security § SOD § Define Logan Approach Page 2

What is Segregation of Duties? q. Segregation of Duties (SOD) § An internal control designed to prevent error and fraud by ensuring that at least two individuals are responsible for separate parts of a business process. q. SOD involves § Breaking down tasks, within a process, that might reasonably be completed by a single individual into multiple tasks so that no one person is solely in control. q. Although it improves security, breaking tasks down into separate components can § Negatively impact business efficiency. § Increase costs, complexity and staffing requirements. q. Efficiency and Cost § Most organizations apply SOD to only the most vulnerable and the most mission critical elements of the business. Page 3

Business Purpose of SOD q. Publicly traded companies must comply with the Sarbanes. Oxley Act of 2002. q(SOX) is a Federal Law intended to protect investors from the possibility of fraudulent accounting activities by corporations. q. SOX codified into Law the requirement for businesses to sustain an internal control environment. Page 4

A SOD Example Payroll management is an administrative area in which both fraud and error are risks. A common segregation of duties for payroll: § A resource responsible for the accounting portion of the job. § An additional resource responsible for signing the checks. Page 5

Does QAD Support System Based SOD? q. Yes! q. An entire SOD module was added to QAD and integrated with the Standard QAD Role Based Security Model. q. Non-Standard QAD Security Models not integrated with SOD. § EAM § Channel Islands Page 6

Components of QAD SOD q. SOD Categories § An Collection of QAD Security Roles. q. SOD Matrix § A Relationship of a SOD Category to All other SOD Categories. § Defines conflicted Categories. q. SOD Policy Exceptions § User level definition allowing access to Menus that are in conflicting SOD Categories. Ø Non system “Mitigating Controls” must be implemented! Ø Controller reviews all disbursement checks and physically signs the checks. q. SOD Role Exclusion § Roles that do not require conflict management. i. e. Report Roles. Page 7

Case Study The Players: q. The Company q. External Auditors q. SOX Compliance Consultants q. ERP Consultants Page 8

The Conditions q. The Company’s previous external audit discovered material weaknesses in their ERP internal control environment. § Material Weakness - Fraudulent, negligent, or innocent misstatement, or an incomplete statement, of a material fact. Ø Intentional – Fraudulent Ø Unintentional – Negligent or Innocent q. What was the Material Weakness? § Improper System Based Segregation of Duties Page 9

Impact of Material Weakness q. External Auditors will/may return a “Qualified Opinion” on the Financial Results presented to the Markets via the Annual SEC 10 K as a result of material weakness finding. q. Will have a direct impact of market value of publicly traded stock. q. CEO And CFO in legal jeopardy as a result of SOX. Page 10

Mitigation Approach q. Perform Analysis of Current State § Review current Roles § Review Roles for Internal Control Conflicts within Permissions § Create Incremental Roles § Mitigate Privileged Access q. Design SOD to Integrate with Role Based Security § Set SOD Categories to Roles in a one to one relationship. § Set SOD Categories equal to the Roles Names (Same Code Value). Page 11

Review Current Roles q. Run Application SOD Import/Export (36. 3. 27. 15) § Make sure to check the box for “Include roles” § Right Click on the “Export to Excel” button Page 12

Review Current Roles Ø Access your saved file in Excel and the following file will appear Page 13

Review Current Roles Page 14

Review Roles for Internal Control Conflicts q. Identify Resources/Menus that would be in conflict in an SOD environment § Example: Supplier Create(28. 20. 1. 1) and Purchase Order Maintenance(5. 7) q. Isolate Roles with the inherit SOD Conflicts Page 15

Roles Example q. Each Task in process will have a unique defined role § Procure to Pay Cycle Ø Supplier Create Ø PO Creation Ø Purchase Orders Receipt Ø Supplier Invoice Creation Ø Supplier Payment Processing Ø Bank Reconciliation Page 16

Mitigate Privileged Access q. Privileged Access = Superuser § A user that has unfettered Access to all Menu. § Superuser should only be used during implementation. § Superuser access is “OK” in test and development environments. q. De-activate Unnecessary Roles q. Create Report Roles § Example: Role: NFR – Non Financial Reports q. Remove Superuser Role access to all Users except System Roles. § No one person should have unfettered access to all menus Page 17

Exclusions from SOD q. Application Role Exclude from SOD (36. 3. 27. 8) § This function will allow you to remove roles that should be excluded in the SOD security configuration. Page 18

Set Up of Segregation of Duties – Process Flow Page 19

QAD SOD Functionality q. There are five main Functions needed in the SOD Configuration § Role Permissions Maintain § Role Membership Maintain § Role Exclude from SOD § SOD Policy Exception Create/Delete/Modify § SOD Import/Export § SOD Configuration Page 20

Role Permissions q. Assigns QAD Menus to a Role. q. Assigns other QAD Programs not on a menu to a Role. Page 21

Role Permissions Page 22

Role Membership q. Assignment of Users to Roles. q. Role Membership are domain/entity specific. Page 23

Role Membership Maintain - View Page 24

Role Membership to Role Permission Relationship Page 25

Role Membership to Role Permission Relationship Page 26

SOD Policy Exceptions q. Allows a user access to a pair of SOD Categories that are not compatible under SOD policy. § An Example – A user has access to both Supplier Creation and Purchase Order Maintenance. Ø Violates Procure to Pay Cycle SOD policy Ø A SOD Policy Exception is required for this users to have access to both menus. Ø The mitigating control can be documented SOD Policy Exemptions. Ø The SOD Policy Exception can be removed later if resources come available. Page 27

SOD Policy Exception - View Page 28

SOD Import/Export q. A Microsoft Excel / QAD Integration Program. q. Export SOD and Role Permission Configuration into a multisheet workbook. q. Performs SOD validity checks against Rule 1 and Rule 2 SOD Violations. § Any rule violations will prevent a successful import. Page 29

Import SOD Configuration q. Load Validation Rules § Rule 1 Violations – Role Permissions Ø Are any Menu to Role relationship is in violation of the SOD configuration? § Rule 2 Violations – Role Membership Ø Are any Role to User relationship is in violation of the SOD configuration? Page 30

SOD Import/Export Application Window Page 31

SOD Matrix Maintain q. SOD Matrix Maintain(36. 3. 27. 3) § Defines Conflicting SOD Categories. Page 32

SOD Configuration Application Window Page 33

SOD Configuration q. Activates the SOD Configuration § When activated, all validation rules are performed to check for violations. You cannot continue implementing SOD if role permission violations exist on your system. You must resolve the violations raised, and then activate SOD. q. Block SOD Violations § When activated, the system prevents administrators from making changes to role-based security that violate role permission (Rule 1) and role membership (Rule 2) segregation of duties rules. Page 34

No One Person Has Privileged Access q. IT will have access to: § User Creation § Role Membership Maintain – Assignment of Users to the Role § Role Permissions Maintain - Assignment of Menus to the Role q. Finance and Accounting will have Access to SOD menus. § Prevents IT from circumventing controls. § IT would be unable to assign themselves Roles that are in conflict of SOD. Page 35

Audit Firm Due Diligence q. Audit firms can analyze your configuration through their SOD Models for specific ERP packages. q. Audit Firms Key Requirements § SOD Categories / Roles are appropriately assigned conflicts in SOD Matrix. § SOD Policy Exceptions Are Appropriately Documented. § Non-system mitigating controls are sufficient to overcome system policy exceptions. § User Provisioning process Ø Onboard resources to ERP and other systems. Ø Offboard resources when employees leave the company. Ø Evidence exists with business approval for access. Page 36