Separation and termination processes

Put in place processes to properly close an individual or organisation’s engagement or involvement with an agency or programme.

This control targets both internal and external fraud risks.

Examples

Examples of this control include:

using checklists to ensure all access, equipment and responsibilities are closed out for former employees and contractors
terminating staff or contractors for fraud or misconduct
cancelling registrations if providers are found to be involved in fraud or misconduct
removing suppliers from a procurement panel due to fraud or misconduct.

Unclear or inconsistent separation and termination processes can lead to:

Methods to evaluate the effectiveness of this control include:

reviewing processes and/or guidelines for termination or separation
confirming that employees, contractors or providers would be terminated or expelled for fraud or non-compliance
confirming that data is captured and reported for all terminations involving fraud or misconduct
identifying cases where staff members, contractors or providers have been terminated for fraud or non-compliance
confirming processes are adhered to and reported on when contracts end by making sure:
- assets are returned
- system access is revoked
- building access is revoked (passes are returned)
- information, documentation and intellectual property is protected
confirming that reasons for termination are recorded by keeping a permanent record for the customer, staff member, contractor, provider or supplier
confirming that any request for a serious misconduct disciplinary record made to a previous employer was in line with the Workforce Assurance Model Standards and Privacy Act 2020.

Other capability, prevention, detection and response controls that can enhance this control’s effectiveness:

Types of behaviour this control is designed to mitigate:

Explore a range of controls that can be put in place to reduce the risk of fraud happening in your organisation.