Separation and termination processes
Summary
These are processes for ending an individual’s or entity’s engagement or involvement with an organisation or program.
Why this countermeasure matters
Unclear or inconsistent separation and termination processes may lead to:
- insider threats
- dysfunctional workplace cultures
- fraudsters being reemployed.
How you might apply this countermeasure
Some ways to implement this countermeasure include:
- separation checklists and reporting for all staff and contractors
- terminating staff or contractors for fraud or misconduct
- cancelling registrations if providers are found to be involved in fraud or misconduct
- expelling suppliers from a procurement panel due to fraud or misconduct.
How to check if your countermeasures are effective
To measure the effectiveness of this type of countermeasure:
- review processes/guidelines for termination/separation.
- confirm that staff members, contractors or providers would be terminated or expelled for fraud/non-compliance.
- confirm that data is captured and reported for all terminations involving fraud/misconduct.
- identify cases where staff members, contractors or providers have been terminated for fraud/non-compliance.
- confirm processes are adhered to and reported on by making sure:
- assets are returned
- system access is revoked
- building access is revoked (passes are returned)
- information, documentation and intellectual property is protected.
- confirm that reasons for termination are recorded by keeping a permanent record for the customer, staff member, contractor, provider or supplier.
- confirm that termination reasons are shared with other parties with a need-to-know such as informing other organisations or programs of:
- serious or organised fraud
- staff/contractor/vendor terminations for fraud/misconduct.
Related countermeasures
This type of countermeasure is supported by the below countermeasures:
Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.
Develop clear instructions and guidance for activities and processes, such as instructions for collecting the right information to verify eligibility or entitlements, procedures to help staff apply consistent and correct processes and guidance to help staff make correct and ethical decisions.
Make sure requests or claims use a specific form, process or system for consistency.
Have processes in place to properly archive or dispose of old or unnecessary systems, assets, staff positions and accesses, client accounts and records.
Create lists to quickly compare information to automate or require further actions.
Conduct quality assurance activities to confirm that processes are being followed correctly and to a high standard and/or that material or goods are what they are claimed to be.
Quality assurance checks not only improve processing standards, they can also detect potentially fraudulent activity and are a significant deterrent to fraud.
Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs. It can also include referrals to law enforcement agencies for those groups that reach the threshold for complex criminal investigations.
Related Fraudster Personas
This countermeasure helps prevent, detect or respond to the following Fraudster Personas:
