1. OBJECTIVE AND SCOPE
The objective of this procedure is to describe the BFC internal controls (users access, customizing activities, sensitive Admin actions…).
Both maintenance and customizing activities must be performed in compliance with internal controls designed with Data Compliance and Audit team and audited twice a year by Deloitte (mid-year and year-end cycles).
2. BFC INTERNAL CONTROLS
BFC Administration team is the control owner of the following internal controls: Audit
SEC-01 (APP.05) Password Management
SEC-03 (APP.01) Functional Profiles
SEC-04 (APP.10) Access Rights
SEC-07 (APP.01) Access Requests
SEC-09 Authorization contact
SEC-10 (APP.03) Audit Trails
SEC-11 (APP.02) Users Deactivation
2.1 SEC-01 (APP.05) Password Management
Purpose: Check the compliance of the password guidelines implementation
This Control is restricted to “Internal Users” (authentication type internal) as “External Users” (authentication type external) are using the Single Sign On.
Description: The Administration Manager reconciles an extract of password settings from the Financial Consolidation system and the password guidelines included in the security policy: all the directives must be respected.
Control type: (Completeness, Accuracy, Validation, and Restricted Access): Completeness, Accuracy and Restricted Access
Frequency: Yearly
Control evidence:
In “Action” menu / “Password Manager” option, the BFC Administration team defines length of Internal password as well as their validity duration.
After 60 days using the same password, BFC will automatically oblige the Internal user to change his / her password. Without this renewal, the Internal user cannot connect anymore to BFC.
The Single Sign On enables users to use their personal login and password (the one used to connect to their computer) to connect also to BFC.
When they will change their Windows password, it will be automatically taken into account by BFC too.
Evidence stored in GDrive: https://drive.google.com/drive/folders/1GI_ZB6EsHhhHrVKSolXdjofT3ip0LFNI
2.2 SEC-03 (APP.01) Functional Profiles
Purpose: All the Functional Profiles creation/modification requests are formally validated by the Consolidation Manager (KUF = Key User Function).
Description: The BFC Administration Manager, before updating the role into the system, checks manually the presence of incompatibilities in the role design, according to the matrix of incompatible actions. In case of some incompatibilities are found he/she informs the Consolidation Manager (KUF) who validates them.
A functional profile defines the types of rights to perform specific tasks in the application. For example, whether or not a user is authorized to create, change or delete data in schedules.
The major risk to be managed is to avoid uncontrolled data modification in BFC due to the allocation of an inappropriate Functional Profile.
Control type: (Completeness, Accuracy, Validation, and Restricted Access): Validation, Accuracy
Frequency: On Flow
A) Functional Profiles created in BFC since its implementation in 2005
B) Functional Profiles currently used (10/11/2021)
C) Description of Functional Profiles currently used (10/11/2021)
Evidence stored in GDrive: https://drive.google.com/drive/folders/19Dc-vvsciksgLYn2UK4uYbuZbLyxGdw2
2.3 SEC-04 (APP.10) Access Rights
Purpose: Matrix of incompatible transactions by critical level is maintained and updated in order to include each new critical transaction.
Description: The file “IT FC SEC-04 Access Rights 2021” is a validation of the updated matrix of incompatibilities by the Key User Function (Consolidation manager):
- The "Responsibilities Matrix" tab is a Description of the Functional Profiles that are used in BFC.
- This matrix is approved before each Audit Sprint by the Consolidation Manager (KUF).
- The content in BFC is validated at each Audit Sprint to check if the Functional Profiles are correctly implemented in the system.
- This matrix is signed by the Consolidation Manager (KUF), scanned and published in Google Drive.
The "Functional Profiles Definitions" tab is a detailed description of the Functional Profiles.
Control type (Completeness, Accuracy, Validation, and Restricted Access): Validation
Evidence stored in GDrive: https://drive.google.com/drive/folders/1cZ5Dm7QTzifrxoy6yjRXabrdURMwPlo2
