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EMPLOYEE ACCESS
TERMINATION PROJECT




   A whale of a tale…
Agenda
         • Background and Overview
         • Policy 95 Review
         • Access Termination
           Process
         • IT Processes/Functionality
         • EAT Project
           Implementation
         • Summary
Overview

Background
  • WCU received an Institutional Audit comment
    regarding termination of access to systems
  • State Auditor’s review based on ISO 27002 which
    requires:
     Immediate termination of access upon severance or leaving
     employment
  • Employee Separations = Access Terminations
  • A team was formed to address the audit comment,
    identify a new process, and automate account
    termination within 24 hours of separation
  • Project was named EAT (Employee Access
    Termination)
EAT Project Process and Scope
Process:
1. Department notifies HR/Career Services/Financial
   Aid/Graduate School of separation via appropriate
   separation paperwork.
2. HR separates the employee’s record accordingly in
   Banner.
3. Automated process reads employee records in
   Banner to inactivate accounts on the date provided
   by the appropriate separation paperwork.

Scope: Only addressed access termination
   Granting access was not included in scope
      Access still dependent on same procedures (hiring / compliance
      paperwork required)
Policy 95 Review

Existing policy for Data Network Security and Access
Control
   • Revised to reflect the realities and possibilities of
     automated termination
Review and approval occurred at many levels
   • Executive Council
   • Internal Audit
Policy revision required lots of communication
   • Deans
   • Department Heads
   • Administrative Assistants

Policy 95: http://www.wcu.edu/25378.asp
Policy 95 stipulates who, what, how, and when… (the rules)
Accountability for
Policy Fulfillment
WCU’s Office of Internal Audit Review Perspective:
  It is the responsibility of each department to
  provide timely notification of employment and
  termination to HR. Departmental notifications
  and personnel processing actions are subject to
  audit by the University’s Internal Auditor and by
  external auditors. As such, the timeframes for
  compliance rest at the departmental level.
For audit reporting purposes:
   Comments are added to Banner when paperwork
   is received by HR after separation date.
Termination Paperwork:
Timeliness and Accountability
• Departments need to provide paperwork to HR/Career Services/Financial
  Aid/Graduate School as soon as possible before last work date

• If Termination is ‘last minute’, they can call HR to expedite
    both employee and access termination

• Termination: Last work date = last access date
   - If paperwork is submitted late to HR and no notification is made prior to
     last work date, access will continue past true last work date.
   - If Account Access is terminated retroactively for the employee, it may
     prompt audit questions. Such questions will be directed to the
     department for clarification and accountability.
New Terminology and Clear
Definition Required
Terminations are based on “Last Day of Access” (Last
Day in the Chair)
   • Last Work Date, for WCU, references last day of
     formal work
   • Formal Contract dates must incorporate complete
     date range for required network resource access
     - Contract dates for fixed term
       Faculty employees reflect time for
       course fulfillment past last day of
       class to allow for final tasks to be
       completed
Access Termination Process

How this affects the campus:
  • Affects all employees and affiliates
     - SPA, EPA Non-Teaching, Hourly, etc.
          Account Inactivation on last work date
     - Fixed Term ‘Instructor’ type roles (Adjuncts,
       Teaching GA’s, Faculty, etc.)
         Account inactivation on Contract End Date
     - Tenure Track Faculty
         Account Inactivation based on individual situation

    • Any remaining business after an employee separation
      date or contract end date must be facilitated by
      Director/Department Head since the employee is no
      longer affiliated with the University
How Access Termination
  Affects Employees
Non Fixed-Term (SPA and EPA) employees
  • Last Access date determined by last day
     of work.
  • Already managed in Banner.
Hourly Employees
  • Last Access date determined by last day of work.
  • If hourly employee not paid in 6 weeks will be
    reviewed for termination
Fixed-Term (Contract Driven) Employees
  • Last Day of Access is determined by Contract
    dates.
  • Contract start and end dates have been aligned to
    match true work dates in Banner.
Non-Fixed Term
Based Employees
    SPA, EPA Non-Faculty, Administrative GA’s, and Hourly




                                              No Access



           Employee         Former Employee



               Last Work Date             Last Paycheck
               Last Access Date

Last Work Date = Last Access Date
Fixed Term
Based Employees
Teaching Employees: Fixed Term Faculty, Graduate TA’s, and Adjuncts

            •   No access allowed when not under contract
            •   Access terminated when not under a contract


                         No Access



        Under Contract       Not Under Contract



                  Contract End

Dates to use on contracts supplied by HR and Graduate School
Faculty Continuous Access
       Access remains intact provided that new contracts and
    compliance paperwork are processed by HR before the end of
                              contract.




          Spring                Fall         Spring
          (contract)        (contract)       (contract)




           No break in access
Faculty Access
Between Terms
Break in Service occurs when a faculty member does not
have a contract between major terms.                     State Regulations
                                                         and WCU’s Policy
                  Break in Service                       95 on Data and
                                                         Network Security
                                                         prohibits access
                                                         for employees
                                                         that are not
                         Fall                            under contract.
     Spring                           Spring             Therefore access
                          (no                            is not allowed
     (contract)                       (contract)
                        contract)
                                                         during a break in
                                                         service.
How Access Termination Affects
Instructor of Record

Instructor Record
   • Any Instructor of Record association for Faculty,
     Adjuncts, and Teaching GA’s is ‘Terminated’
   • Existing advising association is ‘Terminated’
Instructor Relationships are Affected
   • Instructor/Advisor role ended for term (SIAINST)
   • Instructor removed from incomplete and future
     sections (SSASECT )

Department Head facilitates any questions
regarding students after access is terminated
How Access Termination Affects
Email and Network Login
• Network login is ‘Terminated’ on Last Day of Access

• Email is ‘Terminated’ on Last Day of Access

• When Expiration Date is Known Before
  ‘Termination’, Automated Email Reminders
   Sent to Employees :
   – Employees may wish to create an auto-response to
     inform others of their Last Access Day and alternative
     contact information prior to their last work date
IT Processes and Functionality
Engaged to Facilitate Terminations
• Supplemental Data Engine fields
  -   Capture ‘paperwork received date’ to track tardy paperwork and
      access terminations, which provides audit information

• WCU Identity Management Roles utilized
  -   Easily apply termination rules to specific population sets

• Event Initiation and Processing
  - Last Day of Access determines entry into the event
    processing queue
  - Access Termination is processed for registered applications
  - Scalable mechanism for additional automated event and
    termination processing
Banner Set-up for SDE




4) Run the generated DDL as appropriate user
DDL Creates New View
PEAEMPL_ADD view contains existing table
elements, plus additional comment fields:
PEAEMPL -- Comment Fields
WCU Roles: What are they?

A high level view of our data reveals three basic roles
Role Sub-Components: Each Role (i.e.,
“STUDENT”) Reveals a Variety of Sub-Roles

                          Intending
                          Student?




               Future                  Cullowhee
              Student?                 Commuter?




                          STUDENT




               Former                  Currently
              Student?                 Enrolled?




                         Continuing?
Role Creation: Scalable Mechanism for
Identifying, Managing, and Consuming Roles


                        Role



                  Role Memberships



                Sub-Role Memberships
Role Set-Up
Role Validation Table:

                         Rule Definitions
                         for Role Creation:
Example of Role Membership
Worker
Guests                                                • One role may, or may
Cullowhee Commuter
Permanent Staff              Worker                     not, be a member of
Hourly Staff                 Worker
Temporary Staff              Worker
                                                        other roles
All Faculty
Adjunct Faculty
                             Worker
                             All Faculty              • One role may consist of
Faculty
Administrative Student
                             All Faculty
                             Worker
                                                        many combined roles
Worker
Work Study                   Administrative Student
                                                      • One role may be a
Non-Work Study
                             Worker
                             Administrative Student
                                                        member of multiple
                             Worker                     other roles
GA (non-teaching, non-lab)   Administrative Student
                             Worker
Role Maintenance
                            • Individual role
• PLSQL packages
                              memberships are
  written to utilize role
                              activated/in-activated
  definition rules to
                              every two hours, based
  create/maintain role
                              upon data changes in
  populations
                              Banner, our system of
                              record

• Populations refreshed     • One individual may
  via UC4 (AppWorx)           belong to multiple
  batch processing jobs       roles concurrently
Sample Person Look-Up Report Utilizing
Role Information




                    …
Roles Provide:
•   Precise definition  understanding
•   Stability of populations  error reduction
•   Single source of data sameness across systems
•   Auditing information policy enforcement
    – Banner data drives role membership




    – Banner data drives access control
Sample Role Selection (used in
BlackBoard Integration)
WITH BB_Users AS
(SELECT * FROM TABLE (wcuidm.f_group_members ('E'))
UNION
SELECT * FROM TABLE (wcuidm.f_group_members ('35'))
UNION
SELECT * FROM TABLE (wcuidm.f_group_members ('SA'))
UNION
SELECT * FROM TABLE (wcuidm.f_group_members ('8')))




                                      Role Codes
WCU Identity Management
Roles
• Easy to figure out problems and solutions
• Wide application for use campus-wide
                                                       PeopleAdmin
                                   Active                            Online Directory
                                  Directory                           (synced with
                                                                         Outlook)
                 Pawprint


          Reports                           Identity
                                          Management
      (PersonLookup,                                                 Security Groups
        New Hires,                                                   and Distribution
       Terminations)                                                      Lists


                                                      LMS
                       Portal (Luminis)
                                                  (Blackboard)
Event Initiation, Fulfillment and
Processing
Events: Process and Timing

• Processing Runs Daily at 1am
• Individuals in Active Roles, with access
  expiration as of previous date, are placed in the
  queue for termination
• Registered applications are processed against
  each event termination
• Backup data is archived
• Detailed outcomes are logged
• Event processing is auditable and reportable
Events: Timing and Human Error

• Recognizing we are all
  human, we allowed for
  inevitable unintended
  consequences…
• One caveat was built into the processing to
  allow for human error and paperwork
  timeliness
  – Seven-day window for automated “un-termination”
      Paperwork was a day late
      “Fat-finger” on the keyboard resulted in incorrect update
Event Processing Report Samples


Instructor Associations – Useful for Departments
Upcoming Terminations

Departments can subscribe to reports to track
known, upcoming terminations. This is helpful for getting
paperwork in on time.
Event Queue Summary
Useful for Audit and Internal Control
Event Log Details Per Registered
Application
Useful for Audit and Internal Control
Project Magnitude and
Resources
  • Upper level support (multiple project demands)
  • Subject Matter Experts involved for expertise and
    judgment calls (HR, IT, Project Management; others
    as needed: Departments, Registrar, etc.)
  • Time commitment (2 hr meetings/twice weekly,
    independent work time)
  • Complexity (policy, rules, process, data)
  • Reporting to the Executive Council weekly
  • End user training to departmental users, as well as
    internal users (i.e. help desk)
  • Communication Plan campus wide
Project Timeline
• Project kickoff in November
• Initial request for Go-Live: January
• Complexities, communication, holiday
  timing, policy changes, program spec and
  development, and thorough testing
  demanded longer timeline
• Revised Go-Live: March
• Implemented in Audit mode in PROD: February 8
• Implemented in Update mode in PROD: March 1
• Continued communication, as well as minor program
  and reporting revisions during March
• Final Project Wrap-Up: early April
Lessons Learned
• Clearly defined business practices and
  policies are crucial
• Continuous education is necessary for
  management turnover
• “Panic control” can be managed by having
  solid business practices in place for problem
  investigation and resolution when possible
  issues arise
• Change is difficult; education is key
Summary
• Audit defensible system
  – Revising policies to meet auditor and WCU
    business practices
  – Clarifying early access / late access based on
    stakeholders/audit requirements
• Created efficiencies
• Provide timely service to campus
• Accountability
Conclusion

   "Change is hard because people
 overestimate the value of what they
have—and underestimate the value of
what they may gain by giving that up."

               - James Belasco and Ralph Stayer
                     Flight of the Buffalo (1994)

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Employee Access Termination -- Cause 2011

  • 1. EMPLOYEE ACCESS TERMINATION PROJECT A whale of a tale…
  • 2. Agenda • Background and Overview • Policy 95 Review • Access Termination Process • IT Processes/Functionality • EAT Project Implementation • Summary
  • 3. Overview Background • WCU received an Institutional Audit comment regarding termination of access to systems • State Auditor’s review based on ISO 27002 which requires: Immediate termination of access upon severance or leaving employment • Employee Separations = Access Terminations • A team was formed to address the audit comment, identify a new process, and automate account termination within 24 hours of separation • Project was named EAT (Employee Access Termination)
  • 4. EAT Project Process and Scope Process: 1. Department notifies HR/Career Services/Financial Aid/Graduate School of separation via appropriate separation paperwork. 2. HR separates the employee’s record accordingly in Banner. 3. Automated process reads employee records in Banner to inactivate accounts on the date provided by the appropriate separation paperwork. Scope: Only addressed access termination Granting access was not included in scope Access still dependent on same procedures (hiring / compliance paperwork required)
  • 5. Policy 95 Review Existing policy for Data Network Security and Access Control • Revised to reflect the realities and possibilities of automated termination Review and approval occurred at many levels • Executive Council • Internal Audit Policy revision required lots of communication • Deans • Department Heads • Administrative Assistants Policy 95: http://www.wcu.edu/25378.asp
  • 6. Policy 95 stipulates who, what, how, and when… (the rules)
  • 7. Accountability for Policy Fulfillment WCU’s Office of Internal Audit Review Perspective: It is the responsibility of each department to provide timely notification of employment and termination to HR. Departmental notifications and personnel processing actions are subject to audit by the University’s Internal Auditor and by external auditors. As such, the timeframes for compliance rest at the departmental level. For audit reporting purposes: Comments are added to Banner when paperwork is received by HR after separation date.
  • 8. Termination Paperwork: Timeliness and Accountability • Departments need to provide paperwork to HR/Career Services/Financial Aid/Graduate School as soon as possible before last work date • If Termination is ‘last minute’, they can call HR to expedite both employee and access termination • Termination: Last work date = last access date - If paperwork is submitted late to HR and no notification is made prior to last work date, access will continue past true last work date. - If Account Access is terminated retroactively for the employee, it may prompt audit questions. Such questions will be directed to the department for clarification and accountability.
  • 9. New Terminology and Clear Definition Required Terminations are based on “Last Day of Access” (Last Day in the Chair) • Last Work Date, for WCU, references last day of formal work • Formal Contract dates must incorporate complete date range for required network resource access - Contract dates for fixed term Faculty employees reflect time for course fulfillment past last day of class to allow for final tasks to be completed
  • 10. Access Termination Process How this affects the campus: • Affects all employees and affiliates - SPA, EPA Non-Teaching, Hourly, etc.  Account Inactivation on last work date - Fixed Term ‘Instructor’ type roles (Adjuncts, Teaching GA’s, Faculty, etc.) Account inactivation on Contract End Date - Tenure Track Faculty Account Inactivation based on individual situation • Any remaining business after an employee separation date or contract end date must be facilitated by Director/Department Head since the employee is no longer affiliated with the University
  • 11. How Access Termination Affects Employees Non Fixed-Term (SPA and EPA) employees • Last Access date determined by last day of work. • Already managed in Banner. Hourly Employees • Last Access date determined by last day of work. • If hourly employee not paid in 6 weeks will be reviewed for termination Fixed-Term (Contract Driven) Employees • Last Day of Access is determined by Contract dates. • Contract start and end dates have been aligned to match true work dates in Banner.
  • 12. Non-Fixed Term Based Employees SPA, EPA Non-Faculty, Administrative GA’s, and Hourly No Access Employee Former Employee Last Work Date Last Paycheck Last Access Date Last Work Date = Last Access Date
  • 13. Fixed Term Based Employees Teaching Employees: Fixed Term Faculty, Graduate TA’s, and Adjuncts • No access allowed when not under contract • Access terminated when not under a contract No Access Under Contract Not Under Contract Contract End Dates to use on contracts supplied by HR and Graduate School
  • 14. Faculty Continuous Access Access remains intact provided that new contracts and compliance paperwork are processed by HR before the end of contract. Spring Fall Spring (contract) (contract) (contract) No break in access
  • 15. Faculty Access Between Terms Break in Service occurs when a faculty member does not have a contract between major terms. State Regulations and WCU’s Policy Break in Service 95 on Data and Network Security prohibits access for employees that are not Fall under contract. Spring Spring Therefore access (no is not allowed (contract) (contract) contract) during a break in service.
  • 16. How Access Termination Affects Instructor of Record Instructor Record • Any Instructor of Record association for Faculty, Adjuncts, and Teaching GA’s is ‘Terminated’ • Existing advising association is ‘Terminated’ Instructor Relationships are Affected • Instructor/Advisor role ended for term (SIAINST) • Instructor removed from incomplete and future sections (SSASECT ) Department Head facilitates any questions regarding students after access is terminated
  • 17. How Access Termination Affects Email and Network Login • Network login is ‘Terminated’ on Last Day of Access • Email is ‘Terminated’ on Last Day of Access • When Expiration Date is Known Before ‘Termination’, Automated Email Reminders Sent to Employees : – Employees may wish to create an auto-response to inform others of their Last Access Day and alternative contact information prior to their last work date
  • 18. IT Processes and Functionality Engaged to Facilitate Terminations • Supplemental Data Engine fields - Capture ‘paperwork received date’ to track tardy paperwork and access terminations, which provides audit information • WCU Identity Management Roles utilized - Easily apply termination rules to specific population sets • Event Initiation and Processing - Last Day of Access determines entry into the event processing queue - Access Termination is processed for registered applications - Scalable mechanism for additional automated event and termination processing
  • 19. Banner Set-up for SDE 4) Run the generated DDL as appropriate user
  • 20. DDL Creates New View PEAEMPL_ADD view contains existing table elements, plus additional comment fields:
  • 22. WCU Roles: What are they? A high level view of our data reveals three basic roles
  • 23. Role Sub-Components: Each Role (i.e., “STUDENT”) Reveals a Variety of Sub-Roles Intending Student? Future Cullowhee Student? Commuter? STUDENT Former Currently Student? Enrolled? Continuing?
  • 24. Role Creation: Scalable Mechanism for Identifying, Managing, and Consuming Roles Role Role Memberships Sub-Role Memberships
  • 25. Role Set-Up Role Validation Table: Rule Definitions for Role Creation:
  • 26. Example of Role Membership Worker Guests • One role may, or may Cullowhee Commuter Permanent Staff Worker not, be a member of Hourly Staff Worker Temporary Staff Worker other roles All Faculty Adjunct Faculty Worker All Faculty • One role may consist of Faculty Administrative Student All Faculty Worker many combined roles Worker Work Study Administrative Student • One role may be a Non-Work Study Worker Administrative Student member of multiple Worker other roles GA (non-teaching, non-lab) Administrative Student Worker
  • 27. Role Maintenance • Individual role • PLSQL packages memberships are written to utilize role activated/in-activated definition rules to every two hours, based create/maintain role upon data changes in populations Banner, our system of record • Populations refreshed • One individual may via UC4 (AppWorx) belong to multiple batch processing jobs roles concurrently
  • 28. Sample Person Look-Up Report Utilizing Role Information …
  • 29. Roles Provide: • Precise definition  understanding • Stability of populations  error reduction • Single source of data sameness across systems • Auditing information policy enforcement – Banner data drives role membership – Banner data drives access control
  • 30. Sample Role Selection (used in BlackBoard Integration) WITH BB_Users AS (SELECT * FROM TABLE (wcuidm.f_group_members ('E')) UNION SELECT * FROM TABLE (wcuidm.f_group_members ('35')) UNION SELECT * FROM TABLE (wcuidm.f_group_members ('SA')) UNION SELECT * FROM TABLE (wcuidm.f_group_members ('8'))) Role Codes
  • 31. WCU Identity Management Roles • Easy to figure out problems and solutions • Wide application for use campus-wide PeopleAdmin Active Online Directory Directory (synced with Outlook) Pawprint Reports Identity Management (PersonLookup, Security Groups New Hires, and Distribution Terminations) Lists LMS Portal (Luminis) (Blackboard)
  • 33. Events: Process and Timing • Processing Runs Daily at 1am • Individuals in Active Roles, with access expiration as of previous date, are placed in the queue for termination • Registered applications are processed against each event termination • Backup data is archived • Detailed outcomes are logged • Event processing is auditable and reportable
  • 34. Events: Timing and Human Error • Recognizing we are all human, we allowed for inevitable unintended consequences… • One caveat was built into the processing to allow for human error and paperwork timeliness – Seven-day window for automated “un-termination”  Paperwork was a day late  “Fat-finger” on the keyboard resulted in incorrect update
  • 35. Event Processing Report Samples Instructor Associations – Useful for Departments
  • 36. Upcoming Terminations Departments can subscribe to reports to track known, upcoming terminations. This is helpful for getting paperwork in on time.
  • 37. Event Queue Summary Useful for Audit and Internal Control
  • 38. Event Log Details Per Registered Application Useful for Audit and Internal Control
  • 39. Project Magnitude and Resources • Upper level support (multiple project demands) • Subject Matter Experts involved for expertise and judgment calls (HR, IT, Project Management; others as needed: Departments, Registrar, etc.) • Time commitment (2 hr meetings/twice weekly, independent work time) • Complexity (policy, rules, process, data) • Reporting to the Executive Council weekly • End user training to departmental users, as well as internal users (i.e. help desk) • Communication Plan campus wide
  • 40. Project Timeline • Project kickoff in November • Initial request for Go-Live: January • Complexities, communication, holiday timing, policy changes, program spec and development, and thorough testing demanded longer timeline • Revised Go-Live: March • Implemented in Audit mode in PROD: February 8 • Implemented in Update mode in PROD: March 1 • Continued communication, as well as minor program and reporting revisions during March • Final Project Wrap-Up: early April
  • 41. Lessons Learned • Clearly defined business practices and policies are crucial • Continuous education is necessary for management turnover • “Panic control” can be managed by having solid business practices in place for problem investigation and resolution when possible issues arise • Change is difficult; education is key
  • 42. Summary • Audit defensible system – Revising policies to meet auditor and WCU business practices – Clarifying early access / late access based on stakeholders/audit requirements • Created efficiencies • Provide timely service to campus • Accountability
  • 43. Conclusion "Change is hard because people overestimate the value of what they have—and underestimate the value of what they may gain by giving that up." - James Belasco and Ralph Stayer Flight of the Buffalo (1994)