HRS-11: Separation of Duties (SoD)

There is no evidence of a capability to implement and maintain Separation of Duties (SoD) to prevent potential inappropriate activity without collusion.

C|P-CMM1 is N/A, since a structured process is required to implement and maintain Separation of Duties (SoD) to prevent potential inappropriate activity without collusion.

Human Resources Security (HRS) efforts are requirements-driven and governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Ensures industry-recognized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. o Defines terms of employment, including acceptable and unacceptable rules of behavior for the use of technologies, including consequences for unacceptable behavior.

• Personnel management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for personnel management.
• The Human Resources (HR) department:
• The responsibility for training users and enforcing policies being assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
• Personnel managers ensure personnel are routinely made aware of the organization's cybersecurity / data privacy policies and provide acknowledgement.
• Administrative processes require all employees and contractors to apply cybersecurity and data privacy principles in their daily work.
• Administrative processes avoid incompatible development-specific roles through limiting and reviewing developer privileges to change hardware, software and firmware components within a production/operational environment.
• Administrative processes implement and maintain Separation of Duties (SoD) to prevent potential malevolent activity without collusion.

Human Resources Security (HRS) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Ensures industry-recognized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. o Ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. o Identifies and implements industry-recognized HR practices related to cybersecurity and data privacy training and awareness to help ensure secure practices are implemented in personnel operations to help manage risk to both technology assets and data. o Manages personnel security risk by assigning a risk designation to all positions and establishing screening criteria for individuals filling those positions.

• The Human Resources (HR) department:
• Administrative processes require Non-Disclosure Agreements (NDAs) or similar confidentiality agreements that reflect the needs to protect data and operational details, for both employees and third-parties.
• Administrative processes avoid incompatible development-specific roles through limiting and reviewing developer privileges to change hardware, software and firmware components within a production/operational environment.
• Administrative processes implement and maintain Separation of Duties (SoD) to prevent potential malevolent activity without collusion.

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to implement and maintain Separation of Duties (SoD) to prevent potential inappropriate activity without collusion.

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to implement and maintain Separation of Duties (SoD) to prevent potential inappropriate activity without collusion.