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ISO 27001 Segregation of Duty Beginner’s Guide

Last updated Jul 5, 2025

Author: Stuart Barker, ISO 27001 expert, thought leader and your number 1 source for everything ISO 27001.

ISO 27001 Segregation of Duty

ISO 27001 segregation of duty can be confusing and a challenge for small organisations. In this ISO 27001 article you will learn

  • What ISO 27001 Segregation of Duty is
  • How to implement it

What is ISO 27001 Segregation of Duty?

ISO 27001 Segregation of Duty is the act of dividing up critical tasks and responsibilities so that no one person has complete control over a process.

Why do ISO 27001 Segregation of Duty

Segregation of duty is a requirement of the ISO 27001 standard and covered in ISO 27001 Annex A 5.3 Segregation of Duties

By putting in place segregation of duty you will:

  • Prevent fraud: the single biggest reason to implement segregation of duty is to eliminate the opportunity for fraud and to make it more difficult for a single individual to manipulate a process for personal gain.
  • Enhance security: by implementing role based access (RBAC) and dividing roles and responsibilities based on business need and the experience of individuals will protect against unauthorised access and use.
  • Reduce errors: by involving more than one person mistakes and inconsistencies can be caught that a single person may not catch or see.
ISO 27001 Toolkit

Why ISO 27001 Segregation of Duty is important

Inadequate segregation of duties and responsibilities within an organisation can create significant security vulnerabilities. This lack of separation can increase the risk of fraud, misuse of resources, unauthorised access, and other security incidents.

Furthermore, when individuals can easily collude, the risk of these security breaches increases. Insufficient controls to prevent or detect such collusion exacerbate this problem.

To comply with the requirements outlined in ISO 27001 Segregation of Duty, organisations must:

  • Identify critical duties and areas of responsibility that require segregation.
  • Implement and maintain effective controls to enforce this segregation.

How to implement Segregation of Duty

Time needed: 1 hour and 30 minutes

How to implement ISO 27001 Segregation of Duty

  1. Approaches to Segregation of Duty

    There are many standard approaches with the most common being:
    Sequential separation: the two signature principle
    Individual separation: the four eyes principle
    Spatial separation: the principle of separate actions in separate locations
    Factorial separation: process completion requires several factors to be true

  2. Implement Role Based Access Control

    Role based access is one of the most common and practical approaches to implementing segregation of duty. By taking the time to identify the roles that you require and removing conflicts in those roles and then assigning individuals to roles rather that allocating access on a case by case basis will significantly help you to remove conflicts in a consistent way.

  3. Divide Responsibilities

    Understanding and documenting your processes and systems will allow you to identify the key roles and responsibilities which can then be allocated to more than one individual and ensure no one person has complete control for a process or system. This is part of role based access control.

  4. Prevent Collusion

    The way that teams are structured and where they are located and how they interact can have an impact on introducing the opportunity for collusion. Collusion is the working together to commit fraud or circumvent controls.

  5. Monitor and Review

    It may be the case that segregation of duty does not work as intended or requires continual improvement. By implementing logging, monitoring and review on a regular basis allows for the identification and management of when it goes wrong and the ongoing and continual improvements to ensure that it remains effective.

ISO 27001 Segregation of Duty Examples

The following are some common real world examples of Segregation of Duty:

Change Control: the change control process usually has several key steps that include the request for change, the approval of the change and the implementation of the change. There would clearly be a conflict of interest if the person requesting was the same person that approved and then actioned the change. In fact it would make the purpose of having a change control process redundant.

Human Resources: there are many processes in HR that require fairness and objectivity. Take the key processes of hiring, performance management and financial rewards such as pay rise reviews and bonus allocation. If the same individual is responsible for all of these key processes then there is a conflict of interest and a lack of impartiality.

Information Technology (IT): as most processes and business operations rely on the use of information technology this presents the biggest risk to information security and the confidentiality, integrity and availability of data. Most fraud occurs via a compromise of IT. Having one individual with total control can lead to changes being made that cannot be caught with tracks being covered via the manipulation or removal of monitoring and logging.

ISO 27001 Segregation of Duty Templates

ISO 27001 Access Control Policy

The ISO 27001 access control policy enables you to perform segregation of duty and access control management. Built into a powerful ISO 27001 access control policy template that is pre built and ready to go.

ISO 27001 Access Control Policy Template

ISO 27001 Roles and Responsibilities Template

The ISO 27001 Roles and Responsibilities document enables you to document your information security roles and identify and manage conflicts. Built into a powerful ISO 27001 Roles and Responsibilities template that is pre built and ready to go.

ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities Template

Watch the Tutorial

Watch the ISO 27001 tutorial How to implement ISO 27001 Segregation of Duty

Further Reading

For a detailed guide on how to implement Segregation of Duty, read the implementation guide ISO 27001 Annex A 5.3 Segregation of Duties

ISO 27001 Clauses

ISO 27001 Clause 4.1 – Understanding The Organisation And Its Context

ISO 27001 Clause 4.2 – Understanding The Needs And Expectations of Interested Parties

ISO 27001 Clause 4.3 – Determining The Scope Of The Information Security Management System

ISO 27001 Clause 4.4 – Information Security Management System

ISO 27001 Clause 5.1 – Leadership and Commitment

ISO 27001 Clause 5.3 – Organisational Roles, Responsibilities and Authorities

ISO 27001 Clause 6.1.1 – Planning General

ISO 27001 Clause 6.1.2 – Information Security Risk Assessment

ISO 27001 Clause 6.1.3 – Information Security Risk Treatment

ISO 27001 Clause 6.2 – Information Security Objectives and Planning to Achieve Them

ISO 27001 Clause 6.3 – Planning Of Changes

ISO 27001 Clause 7.1 – Resources

ISO 27001 Clause 7.2 – Competence

ISO 27001 Clause 7.3 – Awareness

ISO 27001 Clause 7.4 – Communication

ISO 27001 Clause 7.5.1 – Documented Information

ISO 27001 Clause 7.5.2 – Creating and Updating Documented Information

ISO 27001 Clause 8.3 – Information Security Risk Treatment

ISO 27001 Clause 9.1 – Monitoring, Measurement, Analysis, Evaluation

ISO 27001 Clause 9.2 – Internal Audit

ISO 27001 Clause 9.3 – Management Review

ISO 27001 Clause 10.1 – Continual Improvement

ISO 27001 Clause 10.2 – Nonconformity and Corrective Action

ISO 27001 Organisation Controls

ISO 27001 Annex A 5.1: Policies for information security

ISO 27001 Annex A 5.2: Information Security Roles and Responsibilities

ISO 27001 Annex A 5.3: Segregation of duties

ISO 27001 Annex A 5.4: Management responsibilities

ISO 27001 Annex A 5.5: Contact with authorities

ISO 27001 Annex A 5.6: Contact with special interest groups

ISO 27001 Annex A 5.7: Threat intelligence

ISO 27001 Annex A 5.8: Information security in project management

ISO 27001 Annex A 5.9: Inventory of information and other associated assets

ISO 27001 Annex A 5.10: Acceptable use of information and other associated assets

ISO 27001 Annex A 5.11: Return of assets

ISO 27001 Annex A 5.12: Classification of information

ISO 27001 Annex A 5.13: Labelling of information

ISO 27001 Annex A 5.14: Information transfer

ISO 27001 Annex A 5.15: Access control

ISO 27001 Annex A 5.16: Identity management

ISO 27001 Annex A 5.17: Authentication information

ISO 27001 Annex A 5.18: Access rights

ISO 27001 Annex A 5.19: Information security in supplier relationships

ISO 27001 Annex A 5.20: Addressing information security within supplier agreements

ISO 27001 Annex A 5.21: Managing information security in the ICT supply chain

ISO 27001 Annex A 5.22: Monitoring, review and change management of supplier services

ISO 27001 Annex A 5.23: Information security for use of cloud services

ISO 27001 Annex A 5.24: Information security incident management planning and preparation

ISO 27001 Annex A 5.25: Assessment and decision on information security events

ISO 27001 Annex A 5.26: Response to information security incidents

ISO 27001 Annex A 5.27: Learning from information security incidents

ISO 27001 Annex A 5.28: Collection of evidence

ISO 27001 Annex A 5.29: Information security during disruption

ISO 27001 Annex A 5.30: ICT readiness for business continuity

ISO 27001 Annex A 5.31: Identification of legal, statutory, regulatory and contractual requirements

ISO 27001 Annex A 5.32: Intellectual property rights

ISO 27001 Annex A 5.33: Protection of records

ISO 27001 Annex A 5.34: Privacy and protection of PII

ISO 27001 Annex A 5.35: Independent review of information security

ISO 27001 Annex A 5.36: Compliance with policies and standards for information security

ISO 27001 Annex A 5.37: Documented operating procedures

About the author

Stuart Barker is an information security practitioner of over 30 years. He holds an MSc in Software and Systems Security and an undergraduate degree in Software Engineering. He is an ISO 27001 expert and thought leader holding both ISO 27001 Lead Implementer and ISO 27001 Lead Auditor qualifications. In 2010 he started his first cyber security consulting business that he sold in 2018. He worked for over a decade for GE, leading a data governance team across Europe and since then has gone on to deliver hundreds of client engagements and audits.

He regularly mentors and trains professionals on information security and runs a successful ISO 27001 YouTube channel where he shows people how they can implement ISO 27001 themselves. He is passionate that knowledge should not be hoarded and brought to market the first of its kind online ISO 27001 store for all the tools and templates people need when they want to do it themselves.

In his personal life he is an active and a hobbyist kickboxer.

His specialisms are ISO 27001 and SOC 2 and his niche is start up and early stage business.