| A comprehensive analysis of transactions was performed 
                      to identify each transaction where sensitive information 
                      could be accessed directly or through standard drill-down 
                      functionality. The authorizations for these transactions 
                      were assessed and fields identified which could control 
                      access appropriately. Using these authorization fields, 
                      the security model was redesigned to appropriately limit 
                      sensitive data from non-US Citizens. User master records 
                      were identified as US versus non-US Citizens. Governance 
                      processes and procedures were put into place to ensure that 
                      on-going users are assigned to the appropriate roles.  As part of the redesign, legacy security roles were scrutinized 
                      for functionality as well as flexibility to adapt to the 
                      client’s changing requirements. Security and business 
                      process owners worked together to redefine global business 
                      functions to meet the requirements of the client’s 
                      detailed business operations. Leveraging industry business 
                      process best practices together with in depth knowledge 
                      of SAP security functionality, HBCG designed a security 
                      model to meet the client’s business requirements within 
                      a controlled and secure environment. The effort to design 
                      security around sound business processes not only created 
                      a more manageable security environment, but brought to light 
                      numerous business issues previously overlooked by the client, 
                      including the segregation of incompatible duties (SOD). 
                      Seemingly disparate client business units were united under 
                      a global strategy that could more easily adapt to meet the 
                      business’ requirements.   In addition, HBCG assisted the client in package selection 
                      of a SOD and controls monitoring software. Approva’s 
                      BizRights tool allowed rules to be created to monitor User 
                      Master Records (UMRs) belonging to non-US Citizens against 
                      their data-level authorizations. The reports are scheduled 
                      (or can be run on an ad hoc basis as needed) to run on a 
                      periodic basis and to notify data owners of any violations. 
                      This allows the business owners, who are ultimately accountable 
                      for the business controls, to continually monitor who has 
                      access to their data.
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