A.5.3 Segregation of duties
Split conflicting duties so no single person can run a sensitive process end to end unchecked.
12
artefacts
2
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Financial transaction approval logs · SIEM / log platform
- User provisioning and de‑provisioning logs · Identity provider / directory
periodic reviewEvidence produced at each review
- Quarterly access rights review report · Identity provider / directory
- Privileged access review meeting minutes · Identity provider / directory
governing documentDocuments that govern the control
- Organizational role separation matrix · Policy repository / GRC workspace
- Job description matrix with duty segregation notes · Policy repository / GRC workspace
- RACI chart for critical business processes · Policy repository / GRC workspace
- Change management approval forms · Policy repository / GRC workspace
- Incident response escalation approvals · Document repository
- Conflict of interest register · Policy repository / GRC workspace
- Segregation of duties exception request forms · Policy repository / GRC workspace
- Exception approval documentation · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 2 system-held artefacts from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Combining conflicting roles in small teams
- Lack of documented exceptions
- Infrequent access rights reviews
- Reliance on informal approvals
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetA.5.2 Information security roles and responsibilities · A.5.4 Management responsibilities