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
32 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-01-AFB04FBDSOD-01 | IT CoSItem owner and raiser | Information TechnologyAccess provisioning — September joiner cohort | A. Raised IT-6624 — Access provisioning — September joiner cohort B. Holds the decision on IT-6624 in the same queue | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-08-31 | In remediation |
| SOD-02-7BF3F095SOD-02 | Director, Service DeskStation owner and gate approver | Information TechnologyService Desk | A. Owns 1 station on line IT1C B. Approves the same 1 gate: Notify owner | No owner assigned | Detected, unowned |
| SOD-02-7FB6F3C4SOD-02 | Director, Identity & Access ManagementStation owner and gate approver | Information TechnologyIdentity & Access | A. Owns 2 stations on line IT2A B. Approves the same 2 gates: Manager approve exception, Owner approve | No owner assigned | Detected, unowned |
| SOD-02-7504B0BBSOD-02 | Director, Workplace TechnologyStation owner and gate approver | Information TechnologyEnd-User Compute | A. Owns 2 stations on line IT3C B. Approves the same 2 gates: Approve, Escalate holdout | No owner assigned | Detected, unowned |
| SOD-02-8D70B4C5SOD-02 | Director, Cloud InfrastructureStation owner and gate approver | Information TechnologyInfrastructure & Cloud | A. Owns 3 stations on line IT4A B. Approves the same 3 gates: Escalate spend, Owner approve, Flag failure | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-08-27 | Mitigated |
| SOD-02-D2185156SOD-02 | Director, Network ServicesStation owner and gate approver | Information TechnologyNetwork | A. Owns 3 stations on line IT5A B. Approves the same 3 gates: Escalate, Change board approve, Peer review | No owner assigned | Detected, unowned |
| SOD-02-EA2C7C4ASOD-02 | Director, Application ServicesStation owner and gate approver | Information TechnologyApplication Management | A. Owns 3 stations on line IT6B B. Approves the same 3 gates: Change board approve, Human escalate, Business owner approve | No owner assigned | Detected, unowned |
| SOD-02-69E55356SOD-02 | Director, Security OperationsStation owner and gate approver | Information TechnologyCybersecurity Operations | A. Owns 6 stations on line IT7A B. Approves the same 6 gates: Escalate incident, Analyst review, Declare and others | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | In remediation |
| SOD-02-F89BFC0ASOD-02 | Director, Data PlatformStation owner and gate approver | Information TechnologyData & Integration Platform | A. Owns 3 stations on line IT8B B. Approves the same 3 gates: Owner approve, Escalate, Steward approve | No owner assigned | Detected, unowned |
| SOD-02-DB7EC3DCSOD-02 | Director, IT Asset ManagementStation owner and gate approver | Information TechnologyAsset & License | A. Owns 5 stations on line IT9C B. Approves the same 5 gates: Respond, Legal review, Owner approve 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 2026-09-01 | In remediation |
| SOD-02-C446CCC5SOD-02 | Director, Change ManagementStation owner and gate approver | Information TechnologyChange & Release | A. Owns 3 stations on line IT10B B. Approves the same 3 gates: Change board approve, Declare, Retrospective approve | No owner assigned | Detected, unowned |
| SOD-02-2CA55538SOD-02 | Director, IT Financial ManagementStation owner and gate approver | Information TechnologyIT Financial Management | A. Owns 3 stations on line IT11C B. Approves the same 3 gates: CIO ratify, Owner review, CIO review | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-03 | Mitigated |
| SOD-03-7B77DB36SOD-03 | Director, Service DeskPolicy approver and gate approver | Information TechnologyService Desk | A. Approved 2 policy items: IT1-POL-201, IT1-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 2026-09-26 | In remediation |
| SOD-03-E9843B1DSOD-03 | Director, Identity & Access ManagementPolicy approver and gate approver | Information TechnologyIdentity & Access | A. Approved 4 policy items: IT2-POL-203, IT2-POL-201, IT2-POL-202, IT2-POL-200 B. Also approves gates on the lines those policies bind | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-09-27 | Mitigated |
| SOD-03-FD3C2FCCSOD-03 | Director, Workplace TechnologyPolicy approver and gate approver | Information TechnologyEnd-User Compute | A. Approved 3 policy items: IT3-POL-201, IT3-POL-200, IT3-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-059ED366SOD-03 | Director, Cloud InfrastructurePolicy approver and gate approver | Information TechnologyInfrastructure & Cloud | A. Approved 2 policy items: IT4-POL-200, IT4-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-32EB87CFSOD-03 | Director, Network ServicesPolicy approver and gate approver | Information TechnologyNetwork | A. Approved 4 policy items: IT5-POL-201, IT5-POL-203, IT5-POL-202, IT5-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-00517AD5SOD-03 | Director, Application ServicesPolicy approver and gate approver | Information TechnologyApplication Management | A. Approved 4 policy items: IT6-POL-202, IT6-POL-200, IT6-POL-203, IT6-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-1CC4522BSOD-03 | Director, Security OperationsPolicy approver and gate approver | Information TechnologyCybersecurity Operations | A. Approved 2 policy items: IT7-POL-200, IT7-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-84AA4AB5SOD-03 | Director, Data PlatformPolicy approver and gate approver | Information TechnologyData & Integration Platform | A. Approved 4 policy items: IT8-POL-201, IT8-POL-200, IT8-POL-203, IT8-POL-202 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-3024DF2FSOD-03 | Director, IT Asset ManagementPolicy approver and gate approver | Information TechnologyAsset & License | A. Approved 4 policy items: IT9-POL-200, IT9-POL-202, IT9-POL-203, IT9-POL-201 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-03-91080704SOD-03 | Director, Change ManagementPolicy approver and gate approver | Information TechnologyChange & Release | A. Approved 3 policy items: IT10-POL-200, IT10-POL-201, IT10-POL-202 B. Also approves gates on the lines those policies bind | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-26 | In remediation |
| SOD-03-EEAA7B0FSOD-03 | Director, IT Financial ManagementPolicy approver and gate approver | Information TechnologyIT Financial Management | A. Approved 2 policy items: IT11-POL-201, IT11-POL-200 B. Also approves gates on the lines those policies bind | No owner assigned | Detected, unowned |
| SOD-04-BA18A6ABSOD-04 | Director, Service DeskSub-function owner and rating attester | Information TechnologyService Desk | A. Owns 8 agents running at autonomy level 82 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-0ED4D4CFSOD-04 | Director, Identity & Access ManagementSub-function owner and rating attester | Information TechnologyIdentity & Access | A. Owns 9 agents running at autonomy level 84 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-3715F7BFSOD-04 | Director, Workplace TechnologySub-function owner and rating attester | Information TechnologyEnd-User Compute | A. Owns 8 agents running at autonomy level 74 B. Stands behind the A estate rating that grades those same agents | 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-04-48069863SOD-04 | Director, Cloud InfrastructureSub-function owner and rating attester | Information TechnologyInfrastructure & Cloud | A. Owns 8 agents running at autonomy level 78 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-E460F8A2SOD-04 | Director, Application ServicesSub-function owner and rating attester | Information TechnologyApplication Management | 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 |
| SOD-04-F48951F0SOD-04 | Director, Security OperationsSub-function owner and rating attester | Information TechnologyCybersecurity Operations | A. Owns 9 agents running at autonomy level 80 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-D45EC696SOD-04 | Director, IT Asset ManagementSub-function owner and rating attester | Information TechnologyAsset & License | A. Owns 8 agents running at autonomy level 87 B. Stands behind the A estate rating that grades those same agents | 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 2026-08-28 | In remediation |
| SOD-04-B1EACC1CSOD-04 | Director, Change ManagementSub-function owner and rating attester | Information TechnologyChange & Release | A. Owns 8 agents running at autonomy level 87 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-9969630DSOD-04 | Director, IT Financial ManagementSub-function owner and rating attester | Information TechnologyIT Financial Management | A. Owns 8 agents running at autonomy level 66 B. Stands behind the A estate rating that grades those same agents | Head of AI Business ServicesThe gate has been reassigned to the function leader one level above the station owner.due 2026-08-30 | Mitigated |
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.