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.
Rules in force
6
1 enforced by refusal, the rest detective
Conflicts on the books
385
Standing register, triaged
Detected live
385
Recomputed from the estate on this page load
Unowned
291
Found, named, and nobody has been given the fix
In remediation
60
Owner and date assigned
People affected
160
Across 14 functions
This is the finding, not a decoration. 291 of 385 conflicts have no named owner and no remediation date. Detection is working; triage is not keeping up with it. That gap is carried as an open exception on CTL-005.
The duty pairs
What each rule separates, how it is enforced, and how many holders it currently finds.
SOD-01Raise and approve the same item
Raise a request or a work itemagainstApprove, escalate or clear that same item
CriticalBlocking
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.
When it is breached: The decision interface refuses the action, names the rule, and writes a refusal record to the evidence spine under the requester identity.
8
detected live
8
on the books
0
unowned
4
mitigated
SOD-02Own a station and clear its own gate
Own the station that produces the workagainstApprove the gate that checks that station
HighDetective
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.
When it is breached: Detected and listed. Not blocked, because in many small functions there is genuinely nobody else — the compensating control is that the conflict is named and owned.
153
detected live
153
on the books
122
unowned
13
mitigated
SOD-03Approve a policy and clear the gate it governs
Approve the policy itemagainstApprove a gate on a line the policy binds
HighDetective
Writing the rule and then judging compliance with it collapses two independent checks into one opinion.
When it is breached: Detected and listed with the policy reference and the gate that is affected.
153
detected live
153
on the books
120
unowned
9
mitigated
SOD-04Own an agent and attest its own rating
Own the sub-function whose agents are being changedagainstStand behind the estate rating that grades those agents
HighDetective
A rating signed by the person whose numbers it grades is a self-assessment. It may still be right; it is not independent.
When it is breached: Detected and listed. Independent re-rating is the remediation, not removal of the owner.
69
detected live
69
on the books
49
unowned
8
mitigated
SOD-05Delegate authority to oneself
Act as the delegator on an authority grantagainstHold the grant that was delegated
CriticalDetective
Self-delegation makes the authority register circular. A cap you set for yourself is not a cap.
When it is breached: Detected and listed. A self-delegated grant should be revoked and re-issued by the level above.
0
detected live
0
on the books
0
unowned
0
mitigated
No holder of this pair anywhere in the estate. Reported as zero because it is zero, not because the rule is switched off.
SOD-06Own a control and perform its own test
Own the controlagainstPerform the test that decides whether the control works
MediumDetective
This is the difference between "we have gates" and "the gates were tested by someone who does not run them".
When it is breached: Detected and listed. The test result is retained but is marked as not independent.
2
detected live
2
on the books
0
unowned
0
mitigated
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.
VP Revenue Operations5
Director, Legal Operations5
Director, Demand Development3
Director, Sales Enablement3
Director, Sales Compensation3
Director, Market Intelligence3
VP Demand Generation3
Director, Content3
Conflict register
49 matching, showing up to 120
| Reference | Holder | Where | Both sides | Owner and fix | State |
|---|---|---|---|---|---|
| SOD-04-5CA578F2SOD-04 | Director, Demand DevelopmentSub-function owner and rating attester | SalesDemand Qualification | A. Owns 9 agents running at autonomy level 83 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-A43AB709SOD-04 | Director, Market IntelligenceSub-function owner and rating attester | MarketingMarket & Competitive Intelligence | A. Owns 9 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-E9D1A83FSOD-04 | Director, ContentSub-function owner and rating attester | MarketingContent Studio | A. Owns 9 agents running at autonomy level 75 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-288AD5FFSOD-04 | Director, Campaign OperationsSub-function owner and rating attester | MarketingCampaign Orchestration | A. Owns 9 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-EDCE525FSOD-04 | Director, Field MarketingSub-function owner and rating attester | MarketingField & Events | A. Owns 9 agents running at autonomy level 69 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-A414174FSOD-04 | Director, Marketing OperationsSub-function owner and rating attester | MarketingMarketing Ops & MarTech | A. Owns 9 agents running at autonomy level 72 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-8ED6B2B7SOD-04 | Director, Marketing AnalyticsSub-function owner and rating attester | MarketingAttribution & Analytics | A. Owns 9 agents running at autonomy level 60 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-FAF5A3CCSOD-04 | Director, Order ManagementSub-function owner and rating attester | Revenue OperationsBooking & Order Management | 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-E99423EFSOD-04 | Director, Revenue SystemsSub-function owner and rating attester | Revenue OperationsSystems & Integration | 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-04-913E67C9SOD-04 | Director, Legal OperationsSub-function owner and rating attester | LegalOutside Counsel Management | A. Owns 8 agents running at autonomy level 79 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-280789F4SOD-04 | Director, Procurement AnalyticsSub-function owner and rating attester | Procurement & Source-to-PaySpend Analytics | A. Owns 8 agents running at autonomy level 93 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-B3F6BD8FSOD-04 | Director, Supplier ManagementSub-function owner and rating attester | Procurement & Source-to-PaySupplier Onboarding | 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-CAA7262ESOD-04 | Director, Inventory ManagementSub-function owner and rating attester | Supply ChainInventory Optimization | A. Owns 8 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-B1DBF898SOD-04 | Director, LogisticsSub-function owner and rating attester | Supply ChainLogistics & Transportation | 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-04-191E39A8SOD-04 | Director, Fulfillment OperationsSub-function owner and rating attester | Supply ChainWarehouse & Fulfillment | A. Owns 8 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-B3E293ECSOD-04 | Director, Supplier CollaborationSub-function owner and rating attester | Supply ChainSupplier Collaboration | A. Owns 8 agents running at autonomy level 79 B. Stands behind the A estate rating that grades those same agents | 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 |
| SOD-04-366EC505SOD-04 | Director, External InnovationSub-function owner and rating attester | Research & DevelopmentExternal Collaboration | A. Owns 8 agents running at autonomy level 61 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-6E02FF2FSOD-04 | Director, R&D AnalyticsSub-function owner and rating attester | Research & DevelopmentPortfolio Analytics | A. Owns 8 agents running at autonomy level 67 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-255F6FC1SOD-04 | VP Financial Planning & AnalysisSub-function owner and rating attester | FinanceFP&A & Planning | A. Owns 8 agents running at autonomy level 51 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-5511AC68SOD-04 | Director, BudgetingSub-function owner and rating attester | FinanceBudgeting & Forecasting | 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-04-3DE1FFE3SOD-04 | Director, Management ReportingSub-function owner and rating attester | FinanceManagement Reporting | A. Owns 8 agents running at autonomy level 81 B. Stands behind the AA estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-11794D4CSOD-04 | Corporate ControllerSub-function owner and rating attester | FinanceRecord-to-Report & Close | A. Owns 9 agents running at autonomy level 77 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-D272E99BSOD-04 | Director, Employee ExperienceSub-function owner and rating attester | Human ResourcesOnboarding | 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-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-04-48069863SOD-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-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-04-90DAA907SOD-04 | Director, Workplace ServicesSub-function owner and rating attester | AdministrationFacilities & Workplace | A. Owns 11 agents running at autonomy level 73 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-ECC07752SOD-04 | Director, Travel & ExpenseSub-function owner and rating attester | AdministrationTravel & Expense | A. Owns 11 agents running at autonomy level 77 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-728F1B69SOD-04 | Director, Corporate ServicesSub-function owner and rating attester | AdministrationCorporate Services | A. Owns 10 agents running at autonomy level 76 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-27D7598ESOD-04 | Director, Tier-1 ServiceSub-function owner and rating attester | Customer ServiceTier-1 Resolution | A. Owns 10 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-B37F18AASOD-04 | Director, Technical SupportSub-function owner and rating attester | Customer ServiceTier-2 Technical | A. Owns 10 agents running at autonomy level 68 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-E65AD3FDSOD-04 | Director, Service OperationsSub-function owner and rating attester | Customer ServiceCase Management | A. Owns 10 agents running at autonomy level 89 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-15B66F27SOD-04 | Head of Knowledge ManagementSub-function owner and rating attester | Customer ServiceKnowledge Management | A. Owns 10 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-ECCB0185SOD-04 | Director, Warranty & ReturnsSub-function owner and rating attester | Customer ServiceWarranty & Returns | A. Owns 10 agents running at autonomy level 84 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-956BBC67SOD-04 | Head of Service AnalyticsSub-function owner and rating attester | Customer ServiceService Analytics | A. Owns 10 agents running at autonomy level 54 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-05AEDEF5SOD-04 | Tower Lead, Source-to-PaySub-function owner and rating attester | AI GBS & Global Business ServicesS2P Control Tower | A. Owns 12 agents running at autonomy level 85 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-51ECE3FCSOD-04 | Tower Lead, Order-to-CashSub-function owner and rating attester | AI GBS & Global Business ServicesO2C Control Tower | A. Owns 12 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-DD55BC4CSOD-04 | Tower Lead, Record-to-ReportSub-function owner and rating attester | AI GBS & Global Business ServicesR2R Control Tower | A. Owns 12 agents running at autonomy level 79 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-19FCAF72SOD-04 | Head of AutomationSub-function owner and rating attester | AI GBS & Global Business ServicesAutomation Factory | A. Owns 11 agents running at autonomy level 68 B. Stands behind the A estate rating that grades those same agents | No owner assigned | Detected, unowned |
| SOD-04-948CDD61SOD-04 | Head of Master DataSub-function owner and rating attester | AI GBS & Global Business ServicesMaster Data Management | A. Owns 11 agents running at autonomy level 79 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.
291
Start unwinding a detected conflict
Found by the rule and nobody has picked it up.
60
Finish a remediation already underway
Owner named, plan written, not yet closed.
5
Decide whether a detective rule should block
These rules report a conflict after the fact instead of preventing it.
2
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
Detected, untouched29176%
In remediation6016%
Mitigated349%
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.
How to read this honestly
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.