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
11 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-02-01214880SOD-02 | Director, Revenue DataStation owner and gate approver | Revenue OperationsCRM Data Stewardship | A. Owns 3 stations on line RO1B B. Approves the same 3 gates: Approve, Steward review, Owner review | No owner assigned | Detected, unowned |
| SOD-02-E6C330B1SOD-02 | VP PricingStation owner and gate approver | Revenue OperationsPricing & Rate Cards | A. Owns 4 stations on line RO2B B. Approves the same 4 gates: Approve, Legal check, Pricing council approve and others | No owner assigned | Detected, unowned |
| SOD-02-2DED8DDDSOD-02 | Director, Quote OperationsStation owner and gate approver | Revenue OperationsQuote-to-Order | A. Owns 3 stations on line RO3A B. Approves the same 3 gates: Route approvals, Countersign, Approve | No owner assigned | Detected, unowned |
| SOD-02-C27CCA31SOD-02 | Director, Order ManagementStation owner and gate approver | Revenue OperationsBooking & Order Management | A. Owns 2 stations on line RO4C B. Approves the same 2 gates: Leader review, Human resolve | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-09-28 | Mitigated |
| SOD-02-80CC5D2CSOD-02 | Director, Billing OperationsStation owner and gate approver | Revenue OperationsBilling Interlock | A. Owns 3 stations on line RO5A B. Approves the same 3 gates: Exception hold, Flag material, Approve above threshold | No owner assigned | Detected, unowned |
| SOD-02-5F213DDBSOD-02 | Director, Revenue AccountingStation owner and gate approver | Revenue OperationsRevenue Recognition Interlock | A. Owns 3 stations on line RO6B B. Approves the same 3 gates: Controller approve, Controller sign, Controller review | No owner assigned | Detected, unowned |
| SOD-02-B374BA21SOD-02 | Director, Renewal OperationsStation owner and gate approver | Revenue OperationsRenewals & Churn Ops | A. Owns 2 stations on line RO7B B. Approves the same 2 gates: Save attempt, Leader review | No owner assigned | Detected, unowned |
| SOD-02-64FD34A1SOD-02 | Director, Sales OperationsStation owner and gate approver | Revenue OperationsTerritory & Comp Ops | A. Owns 3 stations on line RO8C B. Approves the same 3 gates: Sign-off, Approve, Escalate ambiguity | Group Financial ControllerCompensating detective control: every clearance by the conflicted holder is sampled at 100 per cent rather than by attribute.due 2026-10-02 | Mitigated |
| SOD-02-5282F7D9SOD-02 | VP Revenue OperationsStation owner and gate approver | Revenue OperationsForecast Integrity | A. Owns 2 stations on line RO9B B. Approves the same 2 gates: Leader review, Leader readout | No owner assigned | Detected, unowned |
| SOD-02-B3E2A8E9SOD-02 | Director, Revenue SystemsStation owner and gate approver | Revenue OperationsSystems & Integration | A. Owns 3 stations on line RO10B B. Approves the same 3 gates: Change board approve, Escalate, Owner attest | No owner assigned | Detected, unowned |
| SOD-02-EAA5221BSOD-02 | VP Revenue AnalyticsStation owner and gate approver | Revenue OperationsRevenue Analytics | A. Owns 4 stations on line RO11C B. Approves the same 4 gates: Ratify, Finance review, Revenue chief sign and others | 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.