Thursday, 18 September 2014
Posted by Richard Hunt
We're delighted to welcome Richard Anderson, our first guest blogger, to the Turnkey Consulting Key Insights blog.
New "Guidance on Risk Management, Internal Control and Related Financial and Business Reporting" from the Financial Reporting Council
After much turmoil in our economy, and many, many months, if not years of consultation, the long awaited guidance on risk management (and all the rest of the things included in its snappy title) from the FRC was published at midnight last night (16/17 September 2014). And – I never thought that I would write this – it was well worth the wait. This document is miles ahead of the former incarnations of the Rutteman Report (remember that?) and subsequently various versions of the Turnbull Report. At last we have something that really addresses the needs of companies, and boards in particular, to do something sensible about risk management.
Thankfully this guidance is also pulling together the various sources of guidance on risk including the former Sharman Report on addressing the knotty issues of reporting under the going concern principle. So this becomes a one-stop source of reference and guidance for boards.
Contextually, as the document says:
The Code defines the role of the board as being "to provide entrepreneurial leadership of the company within a framework of prudent and effective controls which enables risk to be assessed and managed". Effective development and delivery of a company’s strategic objectives, its ability to seize new opportunities and to ensure its longer term survival depend upon its identification, understanding of, and response to, the risks it faces.
At last we are looking at risk management in the context where it belongs: the entrepreneurial leadership of the board, seizing new opportunities and long term survival. In other words this is not a mere governance issue: it is about the creation and protection of value. It goes on to say that the “Company’s approach to risk [needs to be] properly considered in setting the company’s strategy”. In other words risk and its proper management is a strategic issue – as I have been arguing for a very long time. Of course this is divergent with the common practice in many companies today where it is largely a compliance issue dealing with operational matters.
The responsibilities of the board are set out in Section 2 of the guidance and are comprehensive. I have summarised them below:
- Design and implementation of appropriate risk and control systems and robust assessment of principal risks;
- Determining risk appetite;
- Ensuring appropriate culture and reward systems are embedded;
- Agreeing on the approach to managing principal risks;
- Monitoring and reviewing risk management; and
- Ensuring sound information on risk management is published
There is also more material on the board’s responsibility for the Going Concern principle, which I will deal with in a subsequent note. Interestingly, references in earlier drafts to stress testing appear to have been relegated to Appendix B where the approach to longer term viability is discussed. With that exception, the list of responsibilities includes three comparatively recent additions to directors’ responsibilities: namely risk appetite, risk culture and ensuring that sound information is published on risk matters. While risk appetite appeared in the UK Corporate Governance Code a few years ago by inference, it is here explicitly (albeit in brackets!)
My personal take on this is that directors who take this list of responsibilities seriously (and who wouldn’t given the potential impact of failing to do so) will have some considerable work on their hands to address the first two of these issues: namely risk appetite and risk culture. The more fundamentalist members of the ISO31000 community will likely have a collective frenzy of horror at the “Risk Appetite” phrase creeping in – I on the contrary am delighted to see it appearing, because I believe it to be the cornerstone of an effective risk management approach, especially in the strategic domain. At a recent Internal Audit conference I asked how many internal auditors were reviewing their corporate risk culture in anticipation of these changes (they have been well trailed). The response was that depressingly low numbers are doing so and even fewer could articulate their approach to risk appetite.
Section 3 of the guidance advises boards on the exercise of their responsibilities. Five key areas strike me as being particularly relevant and they include:
- Having the board ensure that the "appropriate culture is on place". Indeed the guidance goes on to say that "it is not sufficient for the board to set the desired values."
- Ensuring that there is adequate discussion at the board: this is a far cry from the comments made by Nigel Turnbull after his Report was published when he said to the effect that it was sufficient for the board to have a chat once or twice a year. The guidance now says that "the board needs to ensure that it engages in informed debate and constructive challenge and keeps under review the effectiveness of its decision-making processes."
- Considering whether the board and any committees and management groups have the "necessary skills, knowledge, experience, authority and support to enable it to assess the risks the company faces and exercise its responsibilities effectively". For some time now, I have predicted that this is an area where boards are going to need help. There is far more to the style of risk management that is being asked for here than was implied under the previous guidance. My take on this is that we will see more boards looking for a risk specialist on their team of non-executives, and quite probably seeking board advice specifically about these areas, rather than the broader advice that might be offered to management more generally on the topic.
- Specifying and then monitoring the information that it requires to discharge its risk responsibilities, and in particular that "it is of sufficient quality to allow effective decision-making". Much of what currently passes for risk management is a data-free zone. This will have to change as boards demand better quality information over which appropriate governance procedures are exercised, more akin to the disciplines over accounting data.
- Identifying and seeking assurance on risk matters, including from "compliance, risk management, internal control and internal audit functions within the company, the external auditor’s communications to the audit committee … and other internal and external sources of information or assurance." The guidance goes on to say that "the board should satisfy itself that these sources of assurance have sufficient authority, independence and expertise to enable them to provide objective advice and information to the board." Expertise is written in my italics: it ought not to be good enough for anyone to hold themselves out as a professional risk practitioner without having appropriate credentials. In my view appropriate credentials are rarely provided solely by dint of a qualification in another professional area.
Section 4 of the guidance provides some thought on the establishment of risk management and internal control systems. There is comparatively little that is new or innovative in this regard in this document. Section 5 addresses the requirements to monitor and review risk management and internal control systems. Most important in this section are the recommendations as to what an annual review of effectiveness should address. These include:
- Risk appetite
- The operation of the risk and control systems;
- The integration of risk and control with considerations of strategy and business model;
- Changes in risks and the ability to change in response to the external environment;
- Risk communications
- Issues dealt with by the board during the year; and
- The effectiveness of the reporting process to the public.
It will be up to the board to determine how this review is carried out. No doubt internal audit will often be the default choice. I would merely caution the board to consider the relevant domain qualifications, skills and expertise resident in their internal audit departments. Some will have it, others definitely will not and the board will have to satisfy itself that the right people are conducting the review.
Section 6 of the guidance addresses specific reporting requirements, which I do not propose to cover here, apart from the “Safe Harbour Provision in relation to the Strategic Report, Directors’ Report and the Directors’ Remuneration Report”. Directors will benefit from some protection from making misleading statements in these areas provided that they did not know that the statements were untrue or misleading and did not know that the omission was a dishonest concealment of a material fact. Again, this suggests to me that directors may well wish to engage with professional advisors to assist in the preparation of relevant information being provided to shareholders (and others) in these various reports.
Appendices A and B deal with Going Concern and the Longer Term Viability Statement respectively. I will address these in a subsequent note.
Appendix C provides some useful questions for the board to consider, and Appendix D sets out the relevant sections of the UK Corporate Governance Code and other regulatory provisions.
This document is far reaching in how it addresses risk management. Many companies are going to struggle to articulate their risk appetite or understand their risk culture with sufficient depth to make the concepts meaningful. I anticipate that boards will start to recruit “risk” non executives to their cadre and that we will see more risk board advisors emerging.
My key recommendation is that all boards should consider the content of this guidance carefully and take steps sooner rather than later to address any shortcomings in their current procedures.
Richard Anderson is the Chairman of the Institute of Risk Management and was the principal author of their guidance on risk appetite and tolerance. He is the principal at AndersonRisk and works with a number of UK and overseas Boards on governance and risk management matters.
If you'd like to get in touch with Richard, please contact us at email@example.com with your questions or comments.
Friday, 4 April 2014
Posted by Richard Hunt
Last week I attended the US based SAP GRC conference for the eighth year in a row and this year it was back to where it all started for us, Orlando Florida.
It was a great opportunity to catch up with our US based SAP colleagues and customers and I was joined by three members of our US team and a couple of our team in the UK who were speaking at the conference. The team at SAP Insider put on another well organised event and co-hosting it with the SAP Financials event, I felt, worked really well as everybody had an interest of some sort in GRC.
The event was again well attended and it was a fantastic opportunity to hear from US customers how they are leveraging their SAP GRC tools.
The highlights for us this year were:
1. The official launch of SAP GRC Audit Management on HANA.
Audit Management is the latest addition to SAP’s GRC focused solutions. The solution is focused on helping companies manage the audit cycle. The solution is still evolving and with a HANA backend its future roadmap is sure to include some very interesting audit analytics capabilities.
Here’s an overview diagram of the new product:
2. More customers leveraging Process Controls.
At this year’s event we noted more customers with experience of SAP GRC Process Controls in their environments. This led to a lot more detailed discussions around the capabilities and potential use cases of the product and it was great to explore ideas with these customers.
It was encouraging to hear that our customers are still at the leading edge in terms of getting benefits from process controls.
3. Increased uptake of HANA in the US customer base.
We noted that the take up of HANA was significantly more prevalent amongst US based customers than we have found to be the case in Europe to date. This is a very positive development as it indicates a shift towards this technology amongst the SAP customer base generally.
HANA offers a lot of exciting possibilities in the GRC space and we are looking forward to helping more customers to harness this technology.
4. Increasing interest in SAP GRC Risk Management.
Having successfully implemented Access and Process Controls we are finding more and more customers turning to the Risk management module. This is an area we have put significant focus on over the past two years having developed a Rapid Deployment Solution (RDS) with significant enhancements over and above the SAP standard solution.
We met with a number of customers on this topic in Orlando and are looking forward to helping more customers to utilise this product.
5. Increased product integration across AC, PC and RM.
Many customers we spoke to at the event were interested in how they can make their usage of GRC more efficient and improve their GRC processes by further integrating the GRC components. We had several discussions around options for sharing risks across AC, PC and RM and around how best to integrate the products to take a more holistic approach.
This is something that we have been seeing more in our own customer base and its encouraging to see other SAP GRC users looking to maximise the return on their GRC investment.
It was great to be back in Orlando and we are already looking ahead to next year which may well be back in Vegas (TBC). For those who were not able to join us at the US conference the good news is that this year's European event is only a few weeks away and will be held at a new venue in Nice, France. We will be there again, with our speakers repeating their sessions in addition to some other content we have been asked to provide. If you’re interested in attending the Nice event please let us know – as exhibitors we are able to offer you a customer discount.
Hopefully we will see you there!
Thursday, 24 October 2013
Posted by Richard Hunt
The cyber threat to IT systems in on the increase and this time it is not bored teenagers that we need to worry about. In this blog I ask, is it time to refocus some of our efforts towards the external threats to our SAP systems?
I recently watched a BBC documentary called “Horizon: Defeating the Hackers”. For anyone who didn’t see it I would thoroughly recommend it. Irrespective of your involvement or interest in the IT security industry it is an interesting programme.
The programme attempts to explain to the mainstream viewer some of the most complex IT security events of the past 5 years. This included Stuxnet, widely believed to be a US cyber attack on Iranian nuclear facilities. Understanding and explaining Stuxnet is something that I have attempted myself on several occasions so I take my hat off to the BBC for pulling it off so effectively!
If you haven’t already seen it here’s a clip - https://www.youtube.com/watch?v=UCy2KyBC9sk
Whilst an interesting story in itself, the importance of Stuxnet to me is that it represents a shift change in the threats that our customers’ SAP systems face from external sources and consequently the vulnerabilities that our clients need to manage. Stuxnet had a very clear purpose once it breached the IT security perimeter. It’s objective was to cause maximum disruption to the IT systems that would hurt it’s target organisation most. In the case of Stuxnet this was the systems controlling centrifuges within an Iranian nuclear facility. However, with many large corporations placing an increasing reliance on their IT systems SAP could be the more likely target for a lot of big corporate brands.
The other significance of Stuxnet is that it was a state sponsored attack. Last month the Ministry of Defence announced that it was to create a new ‘Cyber Defence Force’ - http://www.bbc.co.uk/news/uk-24321717. In a written statement in December last year, Cabinet Office Minister Francis Maude said 93% of large corporations and 76% of small businesses had reported a cyber breach in 2012. We are not talking about spotty teenagers looking to get a kick out of their next cyber conquest. These are highly organised teams from both the government and private sector looking to gain competitive advantage at an industry and national level.
Having allocated significant time and resources to segregation of duties and other internal controls for some years now we are seeing a new trend in our more risk aware customers. Those organisations who are more susceptable or aware of their vulnerability to cyber attacks are increasingly asking us to refocus our efforts towards the external threats to their SAP systems. Perhaps this is something that all SAP users should be taking more seriously?
Tuesday, 21 May 2013
Posted by Richard Hunt
Apart from the introduction of our new US team the most exciting announcement at SAP GRC 2013 in Las Vegas this year was the launch of the new Fraud Management module!
Fraud Management is an exciting new addition to the SAP GRC family and adds a number of capabilities to the existing SAP GRC solution set. In this blog we explore some of these features and also discuss some of the possibilities that SAP GRC Fraud Management might open up for the future.
A HANA Backbone
The first thing to note about Fraud Management is that it is based on SAP HANA technology. We have been asked several times by customers about whether Fraud Management is available without HANA. The answer, unfortunately is no. HANA is a pre-requisite. That is not necessarily bad news though as the next release of SAP GRC, 10.1 - scheduled to enter ramp-up in June, will also be (optionally) available on HANA.
With HANA as the backend engine Fraud Management is able to offer some of the real-time transaction monitoring capabilities that were either difficult or in some cases impossible with SAP GRC Process Controls. The Fraud Management analytical engine also enables more effective management of alerts, suspected fraud cases, etc.
How it Works
Fraud Management is essentially an application or use-case of SAP HANA. Data relevant for Fraud analysis (from an SAP or non-SAP source) is extracted into the HANA database. This data is then interrogated using pre-defined fraud patterns and detection rules. The output is used to monitor and report on the likelihood of fraudulent activity through KPIs and KRIs and to trigger responses and/or alerts where appropriate.
Alerts can take the form of an RFC call to the backend ECC system, for example triggering a workflow or calling a BAPI to block a suspicious business transaction in real-time.
An example might be the analysis of vendor payment transactions within a certain tolerance % of purchasing approval limits. E.g. if multiple payments of £19,950 were found to the same vendor authorised by an approver with an approval limit of £20,000 these payments might be blocked pending further investigation.
What Does the Future Hold?
Fraud Management can already be combined with SAP Predictive Analytics to perform more advanced pattern analysis of fraud relevant data and to explore more complex modelling scenarios. In addition to further enhancements of these capabilities we would hope to see standard BAPIs available to enable pre-configured responses to fraud incidents. Another key functionality gap that we would expect to be available in the next release is configuration wizards for the fraud detection rules, currently these are defined manually using SQL queries.
From a customer perspective I think that applications of Fraud Management could extend well beyond fraud analysis, leveraging the capabilities of the tool for continuous transaction monitoring scenarios. For example the capabilities of the tool might be used to optimise working capital by highlighting and postponing vendor payments that were made prior to payment terms.
Our initial assessment of the Fraud Management module is that the key to getting benefit from it is a strong understanding of the indicators of fraud in your environment. This will be a combination of three things:
- An understanding of the key risk factors specific to your organisation
- A knowledge of any past incidents or fraud exposures.
- Content from your implementation partner.
To this aim we have been working with a well-known forensic accounting specialist, to develop content for our Fraud Management offering. We’ve also been exploring the technology in our own demo environment and are evaluating Fraud Management with several customers.
Real-time transaction analysis is a very welcome addition to the functionality available from SAP GRC solutions and significantly enhances the possibilities for continuous transaction monitoring as well as the obvious fraud management applications. Personally I am looking forwards to the prospect of exploring these possibilities further with our customers.
Friday, 14 December 2012
Posted by Richard Hunt
With the New Year approaching I thought it might be a good time to reflect on my observations for the SAP GRC and security market in 2012 and think about what 2013 might have in store for us.
Observations from 2012
With the release of SAP GRC 10.0 in late 2011 this year was always going to be an exciting one in the SAP GRC space. As expected, we’ve seen a lot of customers migrating from older versions of GRC into the new, ABAP based, application. Many have taken the opportunity to revisit their business case for GRC and consider how they could take advantage of what the new software has to offer. This has led to a significant increase in the deployment of process controls and risk management in 2012. We have also seen customers using their migration or upgrade project as an opportunity to re-evaluate automated access provisioning and as a result are seeing more projects in this area.
Whilst perhaps not as high profile we have also seen interesting developments in the SAP security space. The new authorisation concept in SAP HANA together with SAP’s push into mobility and cloud computing solutions have given our SAP security team a number of new technical challenges to solve. They have found it interesting to be at the cutting edge on this area and it’s been a great way to apply their existing SAP security knowledge.
In conclusion, a year of consolidation and expanded reach for SAP GRC with a number of interesting developments in the SAP security space.
Looking forwards to 2013
So what does 2013 have in store in the SAP Security and GRC space?
If our recent survey is anything to go by then automated controls are going to be a big topic in 2013. With over 63% of respondents intending to invest in this area in the next 12 months next year looks set to be an important year for SAP GRC Process Controls. This product is maturing fast and it's flexibility means that customers are putting it to a number of innovative uses. For me, this will be the biggest growth area in 2013 in terms of GRC but I also think we will continue to see an increase in access controls automation initiatives with further migrations/upgrades and more customers maturing in their usage of the access controls 10.0 products.
Continuous transaction monitoring and proactive fraud prevention continue to gather interest and we can expect new products from SAP to address this growing market. Demand for these products will also be fuelled by the increased interest in process controls and I think we can expect to see deeper integration with SAP process controls from vendors like Oversight and Greenlight.
HANA and mobility will remain strong focus areas for SAP in 2013 and this will drive a need for security solutions to address the new business risks that these solutions create. This was again borne out by our survey results which found that 48% of respondents planning to invest in mobility solutions together with additional security and 26% with similar plans around HANA.
All in all, I think 2013 has a positive outlook in terms of opportunities for those with SAP security and GRC experience. With continued ‘doom and gloom’ in the overall economy those working in the IT security and GRC space are fortunate to see a continued increase in the demand for their skills. The challenge, as it has been this year, is to align our efforts and solutions with the overall economic climate – a continued focus on return on investment and delivering cost savings is crucial in achieving this goal.
Wednesday, 14 November 2012
Posted by Richard Hunt
In this blog I would like to follow up on my earlier entry around the benefits of including GRC in a greenfield implementation. Previously we explored this area in the context of access controls. We now look at the benefits of implementing Process Controls at the outset of your SAP journey.
Integrated Control Framework
An SAP control framework is something that will be developed over time by most organisations. Typically Internal Audit will have a control framework against which they test the company's existing controls. This will be updated by IA either during the initial SAP implementation or, more commonly, at the first audit cycle post go-live. The inclusion of process controls at the outset of the project enables an organisation to focus resource towards the adaptation of the control framework to suit the SAP environment. It also gives the opportunity to ensure that these controls are designed efficiently for SAP.
Automated Process Controls
With or without GRC technologies in place your SAP implementation will need to define business process controls to ensure the control and smooth running of your business processes. The inclusion of GRC technologies in your initial implementation scope will enable these controls to be defined and developed in the most efficient way possible, taking advantage of the latest controls automation technology to drive down the costs associated with operating and testing these controls post go-live.
Internal Audit Efficiencies
Testing an SAP environment can be a very labour intensive and inefficient process from an audit perspective. Investing effort to understand where these inefficiencies occur during the initial implementation will help to reduce these inefficiencies, ensuring that duplication of testing is minimised and control testing is automated wherever possible.
Familiarity with the SAP Environment
Ensuring that IA are familiar with controls in the SAP environment from the outset of the project is an important but difficult challenge. Without focused effort from IA to get up to speed on the various complexities of auditing an SAP environment they could find themselves playing catch up post go-live. The inclusion of PC in the implementation scope of GRC will give your audit team a natural 'home' on the project and enable them to develop the skills they need to audit the new SAP environment over the course of the project.
Maturity in the GRC market and in the GRC applications available from SAP means that these solutions should be a consideration for any greenfield SAP implementation. Whilst it may not be in every project scope from the outset customers should consider the benefits of addressing some of the problems that GRC solves during their initial implementation. As we have seen in this blog entry, taking a proactive approach has a number of benefits and tackling your GRC challenges early will surely result in a stronger and more efficient control environment.
Wednesday, 24 October 2012
Posted by Richard Hunt
Typically GRC deployments have focused initially on Access Controls, maybe followed by Process Controls and then possibly Risk Management. In this blog entry I want to challenge the status quo and think about the most approproate way to deploy the SAP GRC toolset as an integrated Enterprise Risk Management solution.
One of my colleagues, Marc Jackson, recently delivered a session at the SAP Insider GRC conference titled 'a Risk Based Approach to Security Audits using SAP Solutions'. The session outlined the way that the Big Four take a 'top down' approach to auditing SAP systems, focusing on the corporate objectives, the risks to the achievement of these objectives and the derivation of the controls required to mitigate those risks.
This got me thinking about the way that most companies approach their SAP GRC implementations. Typically a company will start their SAP GRC journey with an Access Controls implementation to address audit issues or regulatory concerns such as Sarbanes Oxley. This is partly due to these tools being the first to market and partly due to the resolution of those issues being the highest profile/priority. Many companies are now looking to build on this with improvements and automation of business process controls through the SAP GRC Process Controls solution. A few have deployed Risk Management, perhaps alongside PC or as a stand alone implementation.
Taking a step back, the overall objective of the SAP GRC solutions is improved risk management and internal controls. If we consider the risk based approach advocated by the Big Four audit firms and many professional bodies (e.g.PCAOB, IIA, and ISACA) then it would follow that a more logical sequence to implement the SAP GRC toolset might actually be the inverse of today's scenario. This question is particularly relevant with v10.0 as the three solutions now offer much better integration.
Starting with the implementation of the Risk Management tool has several advantages. Firstly this solution is targeted at C-Level and Snr Management users. Therefore it should follow that the project has senior level sponsorship from the outset, a key success factor for any GRC initiative. Furthermore the subsequent implementation of Process Controls will inherently align controls with corporate objectives and the risks to the achievement of those objectives since all controls will be derive from those risks identified by management and the board. While Access Controls are often some of the most robust control options available they are only one control option in the overall control environment. It therefore follows that these should be derived from the control framework defined in SAP GRC Process Controls.
Taking a risk based approach is not going to work for everyone. Many companies look to SAP GRC as a spot solution to specific challenges and they may not have the appetite for an Enterprise GRC Solution. However, for those that do it may be worth rethinking the standard deployment strategy for SAP GRC solutions with a little more focus on the overall objective, Risk Management.
Thursday, 2 August 2012
Posted by Richard Hunt
Many Greenfield SAP implementations will exclude SAP GRC from scope, treating it as an optional module that can easily be implemented post go-live. In this two part blog entry we explore how the deployment of the SAP GRC toolset at the outset of a Greenfield implementation can improve the effectiveness of internal controls in the long-run.
A conversation with one of our customers recently got me thinking about the way that most GRC projects are commissioned, and about how things could be different if a slightly more forward thinking approach was taken. This blog will explore, in two parts, how the deployment of the SAP GRC toolset at the outset of a Greenfield implementation can offer a significantly more effective implementation in the long-run. We start with SAP GRC Access Controls.
A GRC Access Controls project will typically be initiated for one of two reasons:
- In response to an audit report recommending improved controls.
- As a result of a process improvement initiative.
Unfortunately we still rarely see GRC as part of a Greenfield SAP deployment. GRC will often either be overlooked in scoping or become a casualty of tightening budgets at some stage of the project. This is a shame as there are a number of reasons why implementing GRC Access Controls at the outset of a project can be hugely beneficial.
A Compliant Role Design
Any implementation of SAP will require the implementation of SAP roles to support access control requirements and facilitate segregation of duties (SoD). Whilst SAP roles are often designed and built without a segregation of duties tool this approach will inevitably lead to some form of role remediation to align the SAP roles with an SoD ruleset. Even if SoD rules are not defined during the initial implementation a subsequent audit will almost always necessitate some form of remediation activity to achieve this.
By implementing the SoD monitoring tool (Access Risk Analysis) at the same time as the SAP roles it is possible to develop a role design that aligns with the SoD ruleset from the outset, avoiding this subsequent re-work and the associated costs and disruption to the business. This approach is also likely to result in a role design that is easier to maintain as, in the absence of a complete re-design, most post go-live role remediation projects will necessitate some compromise in role design.
A Complete Audit Trail from Day One
Although not widely used in pre-production systems the Emergency Access Management (EAM) module comes into it’s own in a project environment. There are a number of scenarios during a project where elevated access needs to be allocated in a controlled way and EAM is the ideal tool to achieve this. For example, during cutover it will often be necessary for project team members to execute business transactions as part of a data load. Similarly, fire fighting during the hypercare period immediately after go-live will often necessitate higher access privileges than a ‘normal’ business as usual support environment. Making the EAM module available to the project team is an excellent way to provision this elevated access in a controlled way and it will also ensure that an audit trail of high privileged access is available from day one.
Modern Access Control Processes
A Greenfield SAP implementation will most likely require some changes to the IT support model in order to provide an adequate run and maintain environment post go-live. User Access Management processes will vary significantly if an SoD tool is in scope as these processes will need to incorporate SoD analysis. Today’s GRC applications also enable automated provisioning which will further change the UAM process. By deploying these tools into the Greenfield implementation it is possible to design UAM processes that incorporate the most effective use of the GRC tools available from the outset. This will not only save money but will also avoid some of the challenges that many GRC implementations face in failing to secure sufficient business engagement to make best use of the GRC tools.
Many Greenfield SAP implementations will exclude SAP GRC from scope, treating it as an optional module that can easily be implemented post go-live. Clearly this over simplifies things. My hope is that readers of this blog entry will challenge the assertion that the deployment is of GRC is not part of the initial project scope and will argue that GRC should be treated as part of the core solution infrastructure in a similar way to solution manager. After all, why wait until your first audit to be told that you should have included it?