Separation of concerns
Segregation of duties
Six duty pairs that should not sit in one pair of hands. The register below is not a policy document — it is recomputed against the live estate on every load, so what you see is who holds both sides right now.
Health
Whether incompatible duties are separated
Segregation rules in force, the conflicts detected against them and how many have been mitigated.
The duty pairs
What each rule separates, how it is enforced, and how many holders it currently finds.
The oldest control in existence. If the person who asks for something is the person who says yes to it, no amount of evidence afterwards makes the decision independent.
A gate approved by the person who owns the work upstream of it is a formality. This is the most common structural conflict in a shared-service estate.
Writing the rule and then judging compliance with it collapses two independent checks into one opinion.
A rating signed by the person whose numbers it grades is a self-assessment. It may still be right; it is not independent.
Self-delegation makes the authority register circular. A cap you set for yourself is not a cap.
This is the difference between "we have gates" and "the gates were tested by someone who does not run them".
Who holds both sides most often
Concentration matters more than the raw count. One person on eight conflicts is a different problem from eight people on one each.
Conflict register
28 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-02-01FA0556SOD-02 | VP Engineering OperationsStation owner and gate approver | EngineeringPortfolio & Intake | A. Owns 4 stations on line EN1A B. Approves the same 4 gates: Commit to sprint, Prioritization forum, Leader review and others | Head of Agent OperationsAccepted for now with a named risk owner and a review date, because no second qualified approver exists in this sub-function.due 2026-09-29 | In remediation |
| SOD-02-BC97F1D4SOD-02 | Chief ArchitectStation owner and gate approver | EngineeringArchitecture & Design | A. Owns 3 stations on line EN2A B. Approves the same 3 gates: Review board ratify, Owner review, CTO ratify | No owner assigned | Detected, unowned |
| SOD-02-9630F1E2SOD-02 | Director, Platform EngineeringStation owner and gate approver | EngineeringBuild | A. Owns 4 stations on line EN3A B. Approves the same 4 gates: Human review, Merge, Escalate and others | No owner assigned | Detected, unowned |
| SOD-02-4CF437D4SOD-02 | Director, Engineering QualityStation owner and gate approver | EngineeringCode Review & Quality | A. Owns 5 stations on line EN4A B. Approves the same 5 gates: Merge, Human review, Ratify and others | No owner assigned | Detected, unowned |
| SOD-02-754CF120SOD-02 | Director, Quality EngineeringStation owner and gate approver | EngineeringTest & Assurance | A. Owns 3 stations on line EN5A B. Approves the same 3 gates: Escalate blocker, Sign quality gate, Flag regression | Head of Agent OperationsAccepted for now with a named risk owner and a review date, because no second qualified approver exists in this sub-function.due 2026-10-03 | Mitigated |
| SOD-02-CBB93CDDSOD-02 | Director, Release EngineeringStation owner and gate approver | EngineeringRelease & Deployment | A. Owns 3 stations on line EN6A B. Approves the same 3 gates: Change board approve, Release manager sign, Notify | No owner assigned | Detected, unowned |
| SOD-02-623C7D6BSOD-02 | Director, Site ReliabilityStation owner and gate approver | EngineeringSite Reliability | A. Owns 3 stations on line EN7C B. Approves the same 3 gates: Escalate cost, Freeze releases, Escalate to human commander | No owner assigned | Detected, unowned |
| SOD-02-C5E3811ASOD-02 | Director, Engineering EffectivenessStation owner and gate approver | EngineeringTechnical Debt | A. Owns 3 stations on line EN8A B. Approves the same 3 gates: Owner accept, Escalate holdout, Ratify | No owner assigned | Detected, unowned |
| SOD-02-7183E7E6SOD-02 | Director, Developer PlatformStation owner and gate approver | EngineeringDeveloper Experience | A. Owns 2 stations on line EN9B B. Approves the same 2 gates: Owner accept, Manager confirm | No owner assigned | Detected, unowned |
| SOD-02-202F9BE7SOD-02 | Director, Security EngineeringStation owner and gate approver | EngineeringSecurity Engineering | A. Owns 4 stations on line EN10A B. Approves the same 4 gates: Escalate critical, Close, Notify and others | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-08-29 | In remediation |
| SOD-02-CA4010D3SOD-02 | Director, Engineering AnalyticsStation owner and gate approver | EngineeringEngineering Analytics | A. Owns 3 stations on line EN11A B. Approves the same 3 gates: CTO review, Ratify, Owner review | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | Mitigated |
| SOD-03-C58F4955SOD-03 | VP Engineering OperationsPolicy approver and gate approver | EngineeringPortfolio & Intake | A. Approved 4 policy items: EN1-POL-202, EN1-POL-203, EN1-POL-200, EN1-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-AF1EDC81SOD-03 | Chief ArchitectPolicy approver and gate approver | EngineeringArchitecture & Design | A. Approved 2 policy items: EN2-POL-200, EN2-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-F76062E5SOD-03 | Director, Platform EngineeringPolicy approver and gate approver | EngineeringBuild | A. Approved 4 policy items: EN3-POL-202, EN3-POL-203, EN3-POL-200, EN3-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FB2F9A61SOD-03 | Director, Engineering QualityPolicy approver and gate approver | EngineeringCode Review & Quality | A. Approved 3 policy items: EN4-POL-200, EN4-POL-201, EN4-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1EB5A55FSOD-03 | Director, Quality EngineeringPolicy approver and gate approver | EngineeringTest & Assurance | A. Approved 2 policy items: EN5-POL-200, EN5-POL-201 B. Also approves gates on the lines those policies bind | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-26 | In remediation |
| SOD-03-7EE9AB92SOD-03 | Director, Release EngineeringPolicy approver and gate approver | EngineeringRelease & Deployment | A. Approved 4 policy items: EN6-POL-201, EN6-POL-203, EN6-POL-200, EN6-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DBD6883ESOD-03 | Director, Site ReliabilityPolicy approver and gate approver | EngineeringSite Reliability | A. Approved 3 policy items: EN7-POL-201, EN7-POL-200, EN7-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-DA5E8C01SOD-03 | Director, Engineering EffectivenessPolicy approver and gate approver | EngineeringTechnical Debt | A. Approved 2 policy items: EN8-POL-200, EN8-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-FF066B7BSOD-03 | Director, Developer PlatformPolicy approver and gate approver | EngineeringDeveloper Experience | A. Approved 3 policy items: EN9-POL-201, EN9-POL-202, EN9-POL-200 B. Also approves gates on the lines those policies bind | Head of Platform SecurityA second approver from a different reporting line has been added to the gate. Target is every clearance carrying two names by the end of the quarter.due 2026-09-30 | In remediation |
| SOD-03-20B3B8AASOD-03 | Director, Security EngineeringPolicy approver and gate approver | EngineeringSecurity Engineering | A. Approved 3 policy items: EN10-POL-201, EN10-POL-200, EN10-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-C08161D2SOD-03 | Director, Engineering AnalyticsPolicy approver and gate approver | EngineeringEngineering Analytics | A. Approved 4 policy items: EN11-POL-203, EN11-POL-201, EN11-POL-202, EN11-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-04-889A8218SOD-04 | Director, Platform EngineeringSub-function owner and rating attester | EngineeringBuild | A. Owns 8 agents running at autonomy level 76 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-BC8F1ABBSOD-04 | Director, Release EngineeringSub-function owner and rating attester | EngineeringRelease & Deployment | A. Owns 8 agents running at autonomy level 81 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-7D79943ESOD-04 | Director, Site ReliabilitySub-function owner and rating attester | EngineeringSite Reliability | A. Owns 9 agents running at autonomy level 82 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-B1682013SOD-04 | Director, Engineering EffectivenessSub-function owner and rating attester | EngineeringTechnical Debt | A. Owns 8 agents running at autonomy level 71 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-BCE8F019SOD-04 | Director, Developer PlatformSub-function owner and rating attester | EngineeringDeveloper Experience | A. Owns 8 agents running at autonomy level 85 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-E496C9ACSOD-04 | Director, Security EngineeringSub-function owner and rating attester | EngineeringSecurity Engineering | A. Owns 8 agents running at autonomy level 72 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
Actions
What is waiting on a person
A separation rule is only real when somebody unwinds the combinations it forbids. Detected means found and not yet touched.
Start unwinding a detected conflict
Found by the rule and nobody has picked it up.
Finish a remediation already underway
Owner named, plan written, not yet closed.
Decide whether a detective rule should block
These rules report a conflict after the fact instead of preventing it.
Escalate a conflict past its date
Past the remediation date on the record and still combining both duties.
Operations
What this desk is allowed to start
A surface that only reports is not operable. This is the work this page can set in motion, and the bound it runs into.
Trigger and bound
This desk can raise, reassign or mitigate a conflict, and it can change a rule between detective and blocking. Only 1 of 6 rules currently block: the rest allow the combination to occur and report it afterwards, which means the desk finds out about a breach rather than preventing it.
Live observability
What the record shows right now
Conflict states across the estate. Mitigated means a compensating control was accepted, not that the combination was removed.
Current distribution
385 conflicts
Is policy and strategy coming to fruition
Whether the written intent is holding here
351 live conflicts against 6 written rules, and 5 of those rules cannot stop anything.
Not holding on the record
The written position is that no single holder should be able to both initiate and approve the same class of commitment. The record does not support that today: 351 combinations are live, 291 of them with nobody assigned, and only 34 have a compensating control accepted. The deeper issue is enforcement. 1 rule of 6 blocks at the point of action; the others are detective, so the platform is describing breaches it allowed rather than preventing them.
One rule is blocking and five are detective. SOD-01 is refused at the decision interface — the person who raised a work item cannot approve it, the attempt fails with the rule named, and a refusal record is written to the evidence spine. The other five are found and listed but not prevented, because in a sub-function with one senior person there is genuinely nobody else to hold the second duty. Naming the conflict and giving it an owner is the compensating control, and 291 of them do not have one yet.
The live detector and the standing register are computed by the same code, so they cannot drift apart. Every conflict the detector finds is on the register.