GRC2016 - Cummins - Tipsandtrickstocustomize - Rule Set PDF
GRC2016 - Cummins - Tipsandtrickstocustomize - Rule Set PDF
GRC2016 - Cummins - Tipsandtrickstocustomize - Rule Set PDF
Nathan Cummins
PwC
Produced by Wellesley Information Services, LLC, publisher of SAPinsider. © 2016 Wellesley Information Services. All rights reserved.
In This Session
The ruleset is the heart of the GRC Access Control application. In this session, we will
explore basic to emerging ruleset functionality and the options available to you to enhance
your risk reporting.
Designed for both functional and technical stakeholders, this session guides you through
the ruleset design process and shows you what you need to consider – and what you
should expect – during each stage of your SoD ruleset design project
We will take a simple and practical approach to examining ruleset customization, leaving
you with actionable techniques to improve risk management activities via the GRC tool
1
What We’ll Cover
2
Protecting Your Organization – The Need for Controls
www.irs.gov/uac/Examples-of-Corporate-Fraud-Investigations-Fiscal-Year-
2016 Insights from the global state of Information Security® Survey 2016.
3
The SAP GRC Ruleset – The “Heart” of the Application
4
Ruleset Definitions – Let’s Level Set
Term Definition
Ruleset A collection of risks used for SoD or sensitive access reporting
Function A grouping of one or more related actions and/or permissions for a specific business area
Risk A grouping of one or more conflicting functions that presents an opportunity for physical loss, fraud, process disruption, or
productivity loss
Rule Two or more conflicting actions and/or permissions that create a risk
Action An activity that is performed in the system in order to fulfill a specific function, for example, Create Purchase Order. This is
equivalent to a transaction code in SAP.
Permission Authorizations that allow a user to perform a particular activity in a system. This is equivalent to an authorization object
in SAP.
Role Roles are not equitable to the ruleset! A role exists on an application as a container of capabilities and user membership
according to the system’s security concept.
System/Connector An application connected to GRC for purposes of risk analysis, user provisioning, or firefighter
5
The Ruleset Structure
Ruleset
AND
AND Object: F_LFA1_BUK
• Evaluation logic is inherent to Object 3
Object 1 AND Object 2
GRC at all levels, but the
individual field values AND
Field A
AND
Field B
Field Value
1
Field Value
2 Customizable: AND/OR/NOT
6
Risks
Risk ID – Description(s);
Risk Level;
Business Process;
Risk Owner(s);
Control Objective;
Ruleset(s)
7
Risk Types Within SAP GRC
8
Functions – The Foundation of Your Ruleset
• Functions are a grouping of one or more related actions and permissions for a specific
business activity
• Functions are made up of:
Actions (Tcodes)
Permissions (Authorization Object/Field/Values)
Business Process
Can be – single or cross-system
9
Functions – Permission Settings
• The permissions for newly added actions default from SU24 values pulled in from GRC’s
authorization synchronization job
• Permission settings should focus on defining the minimum level of authorizations
required to execute a transaction code in context of the ruleset function
10
How Do Permission Settings Work?
• The logic between permission objects for a specific action is always AND relationship
Both M_BEST_BSA and
M_BEST_EKO is required
• The logic between fields within a specific permission object is always AND relationship
Both ACTVT and BSART is
required for M_BEST_BSA
11
How Do Permission Settings Work? And, Or, Not
NOT = Any field value, but the setting (confusing with multiple NOTs)
Use OR ranges
excluding value(s)
rather than NOT
12
Connectors – Associating the Functions with System(s)
13
Connector Groups
• Logical system – two or more physical systems grouped together to allow you to
maintain rules against one system grouping instead of each physical system
• Cross system – two or more physical systems grouped together so you can perform user
analysis operations across multiple systems
14
Connector Group Guidance
RFC Name only. No
active connection info.
• System-specific (LG_ECC; LG_SRM; LG_CRM)
• Ensure the groups are transportable (not ECC_DEV;
ECC_QA; ECC_PRD)
• Use “dummy” RFCs in development to transport
connector-specific configuration for production
systems
• Use a Logical System Basis Connector Group to
evaluate IT risks across all systems
15
Rules – Making It All Work
Risk: P002
• GRC generates individual Maintain a fictitious vendor and direct disbursements
• A unique rule ID represents F.13 Automatic Clearing without Currency XK01 Create vendor (centrally)
each combination with a F-18 Payment with Printout MK01 Create vendor (Purchasing)
nomenclature built on the risk F110 Parameters for Automatic Payment M-07 Create one-time vendor
ID and combination number F-58 Payment with Printout XK02 Change vendor (centrally)
F-07 Post Outgoing Payments FK06 Mark Vendor for Deletion (Acctng)
P002001 – Risk ID F-31 Post Outgoing Payments XK06 Mark vendor for deletion (centrally)
16
Transports and Workflow Considerations
17
What We’ll Cover
18
Cross-System Rules – Managing Risk Across Applications
• In today’s increasingly complex SAP landscapes business processes are often carried
out across multiple systems creating the need to separate functions across systems
• Cross-system rules are created from risk(s) that contain functions with actions mapped
to multiple systems
Risk: E019
Approve SRM PO and Receive Goods in ECC
SRM ECC
Function Function
Function ID: SR07 Function ID: MM05
SRM PO Approval - VS - Goods Receipts
BBP_POC_WF_APP Approval Transaction for the PO MB01 Post Goods Receipt for PO
19
Cross-System Rules – Managing Risk Across Applications (cont.)
20
Cross-System Rules – Managing Risk Across Applications (cont.)
• Create cross-system
connector groups:
Set up a cross-system
connector group that
contains each of the SAP
systems, which will be used
to run the cross-system risk
analysis
21
Cross-System Rules – Managing Risk Across Applications (cont.)
22
Supplementary Rules – Enhancing Specificity
• Allows for additional criteria, beyond authorizations, to be evaluated which must be met
before an apparent conflict is reported as a violation
Extends specificity of an existing function and its associated risks
Valuable for workflow or approval limits controlled outside of authorizations
23
Organization Level Rules – Eliminating False Positives
• Allows you to eliminate specific false positives where conflicting transaction codes are
assigned, but for differing organization values
24
Organization Level Rules – Eliminating False Positives (cont.)
$OrgValue settings mean
Org reporting should be
used going forward
25
What We’ll Cover
26
Introduction to Fiori
Transactional FIORI UI
Apps
27
Fiori Integration with GRC Ruleset
28
Introduction to HANA Security
29
HANA Integration with GRC Ruleset
• SAP HANA can be integrated with GRC 10.1 for SoD Reporting and Mitigation and User
Provisioning activities
• HANA rules can be defined for System, Object, Package, and Analytic privileges. See
format:
Privilege Permission Field Value
Object/SQL <Schema:SQL Object.Value> SQLPRIVILEGE SELECT, INSERT, UPDATE, etc.
End Users – Sensitive data in HANA can be monitored with rules focusing on Analytic Privileges
30
GRC Reporting Example with HANA Risks
31
Web Dynpros and the GRC Ruleset
• Complementing the push to Fiori interface, SAP continues to release new UI using Web
Dynpro applications
• SAP has extended scope of running risk analysis to analyze Web Dynpro Applications
with SP06 of GRC 10.1. Refer to SAP Note 2048207 and 2171822 for more details.
Authorization Synchronization Job – Extended to synchronize Web Dynpro master data and SU24 material. Prefixed
with [WDY] in the repository to differentiate from tcodes.
Risk Analysis – In the Analysis Results screen, the Resource column reflects S_START for the Web Dynpro material
Action Usage is not possible for Web Dynpro applications
32
Web Dynpros Rules for SRM 7.x
• The SAP standard ruleset released the first Web Dynpros content for SRM7.x
BC Set GRAC_RA_RULESET_SAP_SRM is updated in SP11 of GRC 10.1. This BC Set will have SRM 4.0
ABAP-based rules plus new action/permission data of SRM Web Dynpro application.
All the Web Dynpro application actions start from [WDY] to differentiate it from the transaction codes
33
What We’ll Cover
34
Ruleset Customization Project Overview
• Although every business and system is unique, each implementation follows a similar
risk-based methodology to customizing the GRC ruleset
1 2 3 4 5 6
Rule Building and Continuous
Risk Recognition Analysis Remediation Mitigation
Validation Compliance
“How can this tool help “What are SoDs? “If auditors can rely on “The tools need to
us to provide only the They don’t help me our reports, we can show us a clear view of
access that is achieve my goals.” reduce audit costs. who poses a risk to the
necessary?” I want to ensure the financial statements.”
main risks are covered
and the ruleset is
standardized.”
Obtain clear view of system accessUnderstand risk and controls Standardize rules across organization
Complete and accurate reporting
Move Ownership of risk from Ensure
IT to business
risks and controls add value
Ensure
to business
compliance and regulatory risk is Financial
managed statement risk is managed
Provide access to only accessTrust
needed
IT that access to systems is correct
Leverage tool to minimize audit costs Review of rules for reliance
36
Risk Recognition
Key tasks:
• Compile your sources
Key deliverables
• Assess existing Risk and Control matrix and mitigating controls
• Assess existing audit assessments, findings, or recommendations • Documented business risks and
• Assess business process flows for SoD relevance supporting descriptions
• Involve the right people – IT, business, compliance, and internal/external audit • Risk classification of business
• Define risk classification criteria. Assess and rank each (critical, high, medium, low, no risk). risks and supporting rationale
• For those that present little or no risk, drop at this stage to avoid over-reporting for classification
• Identify, engage, and conduct workshops with key business stakeholders
Outcomes:
• Set of risks in line with your customized processes to efficiently decrease audit exposure
• Agreed upon risk rating approach that identifies risks as unacceptable to the business vs. requiring
mitigation/remediation vs. operational/reporting risks
37
Rule Building and Validation
Objective:
For the risks that have been identified, a common language is defined to specify the functions within the system.
Business requirements around risk are translated into transactions and authorizations. Validation confirms
completeness and accuracy.
Key tasks:
• Start with your sources
• The standard GRC ruleset is a starting point, but will need to be supplemented Key deliverables
• Common functions transaction codes permission settings • SoD ruleset defined at transaction
• Evaluate your custom transaction codes code and permission level
• Utilize documentation, parameter, and change documents
• Define permission settings to minimum standard to eliminate false positives
• Generated rules in GRC
• Load rules, perform risk analysis, tune settings
Outcomes:
• Technical ruleset build aligning to business risk requirements
• Complete and accurate risk reporting
38
Analyze, Remediate, and Mitigate
Objective:
Get Clean! Production SoD reports are actively monitoring environment. Remediation and mitigating control activity
eliminates and/or minimizes risk in the environment.
Key tasks:
• Baseline risk report and results Key deliverables
• Remediation roadmap: Single roles Business Roles Users • Documented SoD results and
• Leverage SAP usage information baseline
• The right role design helps!
• Mitigating controls and mitigating
• Mitigation – design to cover residual risk that can not be remediated
• Generally detective in nature when automated controls do not eliminate or minimize risk control assignments
• Align controls to enterprise controls framework • Remediation actions and results
• Ensure they pass controls testing and meet evidence retention policy
Outcomes:
• SoD and SA violation analysis and recommendations
• Dynamic violation dashboards to support future analysis
• Incorporation of usage data to assess appropriateness of access
• Remediation and mitigation activity
39
Getting Clean – Monitor Your Progress and Plan
Mitigations
deployed
40
Continuous Compliance
Objective:
Stay Clean! Production SoD ruleset is proactively enforced during user provisioning and role change processes. Ruleset
change management processes continually update rules as environment evolves.
Key tasks:
• Automating risk analysis in provisioning and role maintenance process
Key deliverables
• Establish control points within IT processes to assess security and developmental changes
• Could include: Role changes, new functionality/projects, SAP standard rules release, etc. • Documented business risks and
• Determine if they constitute a risk to the environment supporting descriptions
• If so, then a change to the ruleset is initiated to capture the risk • Risk classification of business
risks and supporting rationale
for classification
Outcomes:
• Automated processes to enforce risk evaluation
• Ruleset change management processes and procedures
41
Reports to Help – Actions in Roles, but Not Rules
• Evaluates transaction codes in roles, not active in ruleset for selected criteria
• Mark an action as “analyzed” to denote it has been reviewed and is not relevant for
ruleset – allows comments for detail
• Keep in an in-system list of analyzed transaction codes – table GRACANALYZEDOBJ
42
What We’ll Cover
43
Where to Find More Information
• Scott Osterman, Jamie Draper, and Jonathan Levitt, “Closing the Access Loop: Effective
techniques to manage your segregation of duties and sensitive access” (PwC, 2014).
www.youtube.com/watch?v=2Qar7FyMOHo
• Luis Bustamante, “AC 10.0 Enhanced Access Risk Analysis” (SAP, June 2011).
http://bit.ly/1QxuGm1
44
7 Key Points to Take Home
• The ruleset is the heart of the tool – it will drive risk management across modules
• The ruleset must be customized to create real value from the application
• Cross-system, organization-level rules, and supplementary rules can all be utilized to
improve specificity of reporting
• SAP GRC can be utilized to manage risk of emerging technologies such as Fiori and
HANA, which traditional transaction code level reporting cannot
• The ruleset design process is a top-down approach identifying and classifying risks
before building out the technical rules
• Ruleset management is an ongoing activity – integrate this activity within your security
and upgrade processes
• Customizing your ruleset is not the last step! Expect to use this information to remediate
risks, develop and use mitigating controls, and/or redesign your security roles.
45
Your Turn!
Nathan Cummins
[email protected]
©2016 PwC. All rights reserved. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network.
Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. This content is for general information purposes only,
and should not be used as a substitute for consultation with professional advisors.
47
Wellesley Information Services, 20 Carematrix Drive, Dedham, MA 02026
Copyright © 2016 Wellesley Information Services. All rights reserved.