Functions of SAP GRC Access Control

WHITE PAPER
SAP GRC Access Control Solution.
-White paper on Implementation Methodology.
HCL SAP GRC Practice
January 2008
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Table of Content
Executive Summary
3
Introduction
4
SOX, SoD and SAP
4
Functions of SAP GRC Access Control
6
Implementation Methodology
7
ANNEXURE 1:Various Aspects
10
ANNEXURE 2: Role and Responsibilities
11
ANNEXURE 3: Time Lines
12
ANNEXURE 4: Challenges
12
ANNEXURE 5: SAP GRC Business benefits
13
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Executive Summary
In the era of stringent corporate governance new regulatory requirements have made tighter internal control as
standard compliance across the globe.
All organization irrespective of size are struggling to comply with these regulations and managing the risk.The cost and
effort to establish, maintain and prove compliance demand both money and time which can be invested for more value
addition rather than value protection.
For many organization the technology solutions is to try automation using standard office tools such as spreadsheet
which in spite of its low cost advantage may become a part of problem rather than a compliance solution.
Fortunately newly available software platform that have become known as the GRC technology can help streamline the
automation.This white paper pertains to one of the most accountable control automation tool: SAP Access Control and
details its implementation methodology.
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SAP GRC Access Control
He who cannot obey himself will be commanded.
Integrated GRC is an offshoot of SOX and such other
That is the nature of living creatures.
compliances existing across industries worldwide.
- Friedrich Wilhelm Nietzsche
Evolution of Integrated GRC:
©
Barings Bank – Nick Lee son’s $1.2 Billion loss –
Barings’ forced into bankruptcy.
§
Due to improper supervision and SoD
violations delayed detection.
©
Daiwa Bank – Toshihide Iguchi’s $1.1 Billion loss
and $340 Million fine for unauthorized trades.
©
Mgmt tried to conceal losses by overriding
controls and SoD violations
©
Sumitomo Bank – Yasuo Hamanaka’s $1.8
Billion copper position losses.
In itself GRC is not new. Corporate Governance, Risk
management and Compliance as individual issues where
the most fundamental concerns of Business and its Top
leaders.What's new is Integrated GRC.
It an approach the organization practices and the various
roles the board and the senior management, line
management and rest of the organization play in relation
to oversight, strategy risk management and strategy
execution regarding compliance with laws and
regulations and internal policies and procedures.
©
Maintained 2 sets of books for over a decade
©
NatWest U.K. – Kyriacos Papoulis concealed
over $100 Million in option losses
§
Manipulated the books.
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Enron, Tyco International, Adelphia, Peregrine
Systems and WorldCom…………………..Socite
General….
SOX, SoD and SAP
As per the requirement to be SOX (Sarbanes Oxley Act)
compliant, the main issue arises in SoD (Segregation of
Duties) management i.e. Access related problems in
organizations. For this purpose the necessity is to make
an automated approach to implement the rules and
Introduction
Sarbanes Oxley Compliance was a result of such
Scandals.Also known as the Public Company Accounting
Reform and Investor Protection Act of 2002 and
commonly called SOX, it is a controversial United States
federal law passed in response to a number of major
corporate and accounting scandals.
Signed by Congress on July 30, 2002 its overall purpose is
to protect investors by improving the accuracy and
reliability of corporate disclosures made pursuant to the
securities laws.
policies of SOX compliance.
SAP is in process of addressing the various compliance
and risk management issues across the verticals with the
development of automated solutions.
One of the Solutions they have developed comprises
GRC Access Control an application that handles
sustainable prevention of segregation of duties
violations. By implementing the automated Access
control solution, it will provide the enablement to fulfill
the requirements of SOX compliance without any SoD
violation and its severity.
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SAP Definition for SoD
A primary internal control intended to prevent or
Segregation of Duties deals with access controls.Access
decrease the risk of errors or irregularities by assigning
Control ensures that one individual should not have
conflicting duties to different personnel.
access to two or more than two incompatible duties.
Some examples of incompatible duties are:
Segregation of Duties (SoD)
Across an enterprise there are various functions and
©
Creating vendor and initiate payment to him.
these functions are performed, together by a set of
©
Creating invoices and modifying them.
roles/responsibilities.
©
Processing inventory, and posting payment.
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Receiving Checks and writing pay-offs.
SoD says that these set of Roles/responsibilities should
be assigned in such a way that, across an enterprise, any
individual should not have end to end access rights over
Ideally, single individual must not have authority of
creation, modification, reviewing and deletion for any
transaction / tasks / resources.
any function.
If any individual has access rights to creation and
modification, he can create and after getting it reviewed,
he can modify it to do some fraudulent exercises.
Similarly if an individual has creation and deletion rights
End to end access
SoD
Actual job titles and organizational structure may vary
greatly from one organization to another, depending on
the size and nature of the business.With the concept of
SoD, business critical duties can be categorized into four
types of functions: authorization, custody, record keeping
and reconciliation. In a perfect system, no one person
should handle more than one type of functions.
The Roles and Responsibilities for the function should
be divided in such a way that one person does not have
full right over the function that the risk of malicious
activity of manipulation of the function is reduced. The
more critical the function is, greater and clearer
Segregation of Duties should be.
he can create, initiate payment and later delete any
transaction logs that can track his activity.
Segregation of Duties ensures that:
©
There are no errors, as SoD ensures cross check of
roles/responsibilities
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Risk of Fraud is reduced as fraud will involve two or
more than two individuals
©
Clear separation of Roles/Responsibilities across
various functions in organization.
©
Segregation of Duties must be so performed that it
reduces the risk associated with a function/process
that can be mal-functioned to practice any
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fraudulent exercises. If proper SoD does not exist in
an organization, then:
©
There are ineffective internal access controls
©
There is improper use of materials, money, financial
application for SAP. When deployed together,they
provide an end-to-end Access Control solution that
addresses the following areas:
assets and resources
©
Estimation of financial condition may be wrong
©
Financial documents produced for audits and review
©
Risk detection SAP applications for Access Control
detect even the most obscure access and
may be incorrect
Manual Approach for SoD
Traditional approaches for identifying and preventing
SoD issues are costly, time-consuming, and exhaustive
with scope for errors. In the increased regulatory
environment, companies cannot afford to waste time
and money hoping that a manual approach will satisfy
their audit requirements. Companies now seek a
comprehensive, automated approach to help them
quickly resolve the SoD challenges without disrupting
their business.
SAP Access Control
authorization risks across SAP and non-SAP
SAP GRC Access Control delivers a comprehensive,
applications, providing protection against every
cross-enterprise set of Access Control that enables all
potential source of risk, including segregation of
corporate compliance stakeholders -- including business
duties and transaction monitoring.
managers, auditors, and IT security managers -- to
©
Risk remediation and mitigation These applications
collaboratively define and oversee proper SoD
for access and authorization control enable fast,
enforcement, enterprise role management, compliant
efficient remediation and mitigation of access and
provisioning, and Superuser privilege management.
authorization risks by automating workflows and
enabling collaboration among business and technical
Functions of SAP GRC Access
Control
users.
©
Repor ting The
applications deliver the
The SAP GRC Access Control Includes the Virsa
comprehensive reports and role-based dashboards
Compliance Calibrator application for SAP, the Virsa
businesses need to monitor the performance of
Role Expert application for SAP, the Virsa Firefighter
compliance initiatives and to take action as needed.
application for SAP, and the Virsa Access Enforcer
©
Risk prevention Once access and authorization risks
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have been remediate, only SAP applications for
This implementation methodology when followed step
Access Control can prevent new risks from entering
by step makes access and authorization risk
a production system. By empowering business users
management and further its compliance adherence, an
to check for risks in real time and automating user
integral part of customary organizational activities. The
administration, the applications make risk
implementation process is based on Best Practices
prevention a continuous, proactive process.
provided by SAP and extends from GET CLEAN
(identify and resolve the access risk issues) phase to
Implementation Methodology
based on SAP Best Practice
STAY CLEAN (complaint user provisioning process is
channeled into automated structure) phase.
The implementation process starts from installation and
configuration of Compliance Calibrator. In line with the
SoD Management Process, Business Process Owners
identify any fraudulent or accidental corruption activity,
subjected to access and authorization or SoD risks and
then implement the necessary mitigation controls on
them. Next, during implementation of Role Expert,
through Role Designer we design the role designation
methodology of the organization. In Access Enforcer
implementation, we define workflows. Workflows are
meant for channelizing the different work processes into
structured, transparent and automated manner.
At last, Fire Fighter is implemented which endow
selected users with exceptional rights. To ensure risk
occurrence, all the activities of users with fire fighter
rights are logged and documented.
HCL has come out with an excellent approach and
methodology for implementation of SAP GRC Access
Control Suite.This Suite embraces four tools:
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Access risk analysis and remediation
©
Complaint user provisioning
©
Role Management
©
Privileged user access management
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The proposed methodology which helps in
Control Tools.
implementing SAP GRC Access Control projects has six
phases:
Access Control Tool Suite can be easily downloaded
from SAP Support Portal at SAP Service Marketplace at:
©
Implementation Readiness
service.sap.com. You need to login from your service
©
Deploy & Install GRC Access Control Tool Suite
marketplace ID. It will ask for your Customer Number
©
Risk Analysis and Remediation
or Installation Number.
©
Super User Privilege Management
©
Compliance User Provisioning
The SAP GRC Access Control Tool Suite includes
©
Enterprise Role Management
following tools:
©
Virsa Compliance Calibrator
Preparation of Implementation
©
Virsa Access Enforcer
We recommend the implementation life-cycle of GRC
©
Virsa Role Expert
Access Control Tool includes every thing from
©
Virsa Firefighter for SAP
Installation and configuration of all 4 software’s to their
integration and validation.
Risk analysis and remediation
Risk Analysis and Remediation is done by
Preparation Includes:
Compliance Calibrator.
©
Net Weaver installation configured and validated i.e.
ready for applications installation
©
Resource Identification
©
Requirement Validation: It will include review and
Risk Analysis and Remediation provides real-time
compliance around the clock and prevents security and
controls violations before they occur. Once deployed,
validation of customer’s requirement against
business managers can analyze real-time data, find
product functionality.There should be a brief analysis
hidden issues and help ensure the effectiveness of access
of customer’s business environment which will
and authorization controls across the enterprise.
include the organizational scan and study of their
business processes. BPX along with implementation
The scope of the process includes following key
consultant and BPO will architect solutions to
areas:
address requirement gaps.
©
Identification of critical access and segregation of
duties
Deploy & Install GRC Access Control Tool
©
Real-time risk assessment
Suite
©
Simulation and remediation
Once the preparations for implementation are done, we
©
Documentation of mitigation controls
proceed for installation and configuration of Access
©
Summary and drill-down reports
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Super user Privilege Management
©
Identify SoD Issues in Real Time
Superuser Privilege Management is done
©
Streamline Approvals
using Firefighter
Enterprise Role Management
©
Superuser Privilege Management is a solution used
Introduction to Role Expert
for emergency situations, extensive and/or special
Role Expert is a Role Creation and Management Tool.
access, and when you do not have time to obtain
This SAP GRC Access Control Tool is a web enabled tool
logins, passwords. Feature provided by it:
that can ease the overhead in an Organization in
©
Provides Super User access control
creation and management of Roles.
©
Compliant controls for emergency access
Apart from creation and management of Roles it also
§
Users assigned to specific firefighting IDs with
defined authorizations and validity dates
§
Separate
login is required as well as
documentation regarding reason for use
takes care of Risks associated with different Roles,
Segregation of Duties, and Generation of types of
reports useful for management and auditors and also the
mitigation of risks.
§
Can only be used by one user at a time
©
Auditable reporting
§
Logs actions without turning on SAP logging
Purpose of Role Expert
Role Expert implementation serves the following
purposes in an organization:
©
It helps implement best practices of good role
Compliant User Provisioning
Compliant User Provisioning will be done
by Access Enforcer
naming conventions.
©
Automates the creation and maintenance of Roles.
©
Implements best practices of Approval workflow
automation for Role in the Organization.
©
Automates the generation of reports of various
Access Enforcer enables fully compliant user
types to serve the purpose of management and
provisioning throughout the employee life cycle and
auditors as well.
prevents new SoD violations. Businesses can automate
©
Performing automatic risk analysis at all levels and
provisioning, test for SoD issues, streamline approvals,
also mitigation of risks before approving or creating
and reduce the workload for IT staff. The solution
the requested role.
performs following activities:
©
Transparency, tracking and monitoring of creation
and implementation of Roles.
©
Automate Provisioning Workflow
§
©
Provide Compliant User Provisioning Across the
Enterprise
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ANNEXURE 1:Various Aspects.
Steps
Activities Involved
Person Involved
Duration/Days
Implementation
Readiness
• Hardware/Software requirement
analysis
• Software Installation
• NetWeaver Environment Validation
Basis/Security
Consultant
GRC AC Tool Consultant
17
Deploy & Install GRC
Access Control Tool Suite
• Software installation as well certain GRC AC Tool Consultant
one-time initial configuration activities.
15
Risk Analysis and
Remediation
• Identification of critical access and
GRC AC Tool Consultant
segregation of duties
GRC Business Process Analyst
SOX Domain Consultant
• Real-time risk assessment
• Simulation and remediation
• Documentation of mitigation controls
• Summary and drill-down reports
26
Super User Privilege
Management
The application tracks, monitors, and
logs every activity a super user
performs with a privileged user ID.
• Creation of Firefighter Ids
• Assignment of Firefighter roles to
applicable User IDs
• Mapping Firefighter IDs to Owner,
Firefighter, and Controller
4
Compliance User
Provisioning
GRC AC Tool Consultant
• Learn about Access Enforcer
workflows and their components
GRC Business Process Analyst
• Define process stages and approvals
• Create test initiators, stages, and paths
• Define test users and request types
• Test initial workflows
• Define escalations and detours
• Complete workflow configuration
20
Enterprise Role
Management
• Creation of Role Attributes required GRC AC Tool Consultant
for any Role
GRC Business Process Analyst
• Creation of Role Generation
Methodology
• Creation of Naming Conventions for
Roles
• Creation of Role in Role Expert
• Reports in Role Expert
15
GRC AC Tool Consultant
GRC Business Process Analyst
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ANNEXURE 2: Role and Responsibilities
Role
Number
Group
Responsibility
Basis/Security
Consultant
1
HCL GRC
• Hardware/Software requirement analysis
• Software Installation
• NetWeaver Environment Validation
GRC AC Tool
Consultant
2
HCL GRC
•
•
•
•
•
•
•
•
•
•
SOX Domain
Consultant
1
HCL GRC
• Risk identification
• Creation of Mitigation Controls
• Approve or Reject already created Risks and Mitigation
Controls
• Scenario Analysis and Identification of Format & Content of
Reports
GRC Business
Process Analyst
1
HCL GRC
•
•
•
•
•
•
•
Client Technical
Team
To be
decided
Client
• Hardware/Software requirement analysis
• Software Installation
• NetWeaver Environment Validation
Client Business
Team
To be
decided
Client
• Identifying risk and/or approving controls for monitoring
risks
• Approving remediation to address user access issues
• Approve or reject risks between business areas and approve
mitigating controls for risks.
Client Project
Manager/
Coordinator
To be
decided
Client
• Managing the implementation project
Client Audit /
Internal Control
Team
To be
decided
Client
• Perform risk assessments on a regular basis to identify new
risks, perform periodic testing of rules and mitigating
controls; act as a liaison with external auditors.
Master Data Creation
Configuration of all 4 tools
Integration of all 4 tools
Risk Recognition, Remediation, Mitigation
Rule Building and their Maintenance
Configuration of workflows
Configuration of Role Attributes
Configuration of Role Generation Methodology
Configuration of Naming Conventions
Report Generation
Risk Analysis and Validation
Designing alternative controls to mitigate SoD issues
Designing workflows for user and role provisioning
Identification of Role Attributes
Identification of Role Generation Methodology
Identification of Naming Conventions
Identification of risk & role owners and approvers
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ANNEXURE 3:Time Lines
Implementation Activity
Duration/Days
Formation of project team*
Software Installation and Validation*
Requirement Validation/System and User Landscape Study/Master Data Creation*
Implementation Readiness
Compliance Calibrator Configuration and Implementation
Firefighter Configuration and Implementation
Role Expert Configuration and Implementation
Access Enforcer Configuration and Implementation
Roll-Out/Deployment/Go-Live
2
5
10
17
26
4
15
20
10
Note: * These activities are performed simultaneously.The total implementation time is 56 calendar days.
ANNEXURE 4: Challenges
Challenges
Solution
Real-time alert generation and
notification through mail
Alert Generation and its notification through e-mail was configured not
only for mitigating controls but also for risk execution and critical
transaction execution
Setting up organizational rules and
running risk analysis based on
these rules
Compliance Calibrator provides a supplemental table to address
organizational restrictions without having to change and maintain the entire
rules database. These restrictions were configured as organizational rules.
Integrating workflows in
Compliance Calibrator
for various processes
Various processes of Compliance Calibrator can be automated and
structured through workflows which are created and executed through
Access Enforcer. Path for connecting the Compliance Calibrator to the
workflows is entered in the Workflow service URL.
Efficient handling of false
positives
Rule Building is done at authorization objects level to prevent false positives
of SoD violations.
Designing user-provisioning
workflows and proper
initiators to trigger them
User provisioning workflows are created and configured through Access
Enforcer
Cross-application
implementation
The system includes rules at both the transaction and object level that
address the SAP applications for APO, Basis, CRM, EBP, SRM, FI/CO, HR /
Payroll, Procure to Pay, MM/QM, Order to Cash, and Portals.
Cross-system
implementation
The Virsa Compliance Calibrator "out-of-the-box" rule set includes
transaction objects and value combinations analyzing some 120,000 possible
combinations of potential risk for access rights. These cover - SAP: 20,000,
Oracle: 20,000, PeopleSoft: 3,800, JDE 151.
Cross-geo implementation
A centralized monitoring system is provided by connecting various systems
across geo.
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ANNEXURE: 5
SAP GRC Business Benefits:
SAP helps organizations build an integrated GRC approach in a step-by-step approach. SAP solutions for governance,
risk, and compliance help you leverage your SAP and non-SAP IT investments, and deliver the following business benefits:
Increased shareholder value – Good corporate governance is reflected in many intangibles, including brand and
reputation – and it translates directly into share price premiums.
Optimized risk/return portfolios – Greater transparency and insight enables your decision makers to select or
reject projects based on risk impact and probability relative to potential return.
Reduced GRC costs – Integrated corporate governance significantly reduces the number of people – and time –
required to ensure and manage compliance and risk management.
Improved business performance and predictability – SAP solutions for governance, risk, and compliance deliver
enterprise wide transparency, a systematic process for anticipating risks, and the tools to proactively determine proper
actions.
Business sustainability – Using solutions delivered through automation, analytics, and alerts, businesses can more
effectively mitigate risks stemming from myriads of legislations.
Assumptions for the Duration/Days in Annexure:
1.
Minimum Net Weaver support Pack is already installed and validated on identified systems.
2.
All the database and memory requirements for installation of Access Control Tools are met.
3.
Hardware and memory sizing is already performed.
4.
Organization already possesses the license for all required Access Control Tool.
5.
Person efforts and time would go on reducing in subsequent implementation in different geographies
6.
The company would go for addressing compliance management issues subsequently across different locations.
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