Context
Commercial, corporate and SME segmentation rested on a customer's asset size, turnover and headcount. Yet those figures could be entered and updated by branches and service units with no document requirement at all. The result was segmentation resting on self-declaration. If the segment is wrong, pricing, limits, product offers and risk assessment all rest on a wrong basis — and the error propagates quietly inside the system.
Approach
- The principle was adopted that segmentation rest on the financial data the customer files with the state.
- Branches scanned documents into the Customer Document System through a financial document scanning screen reached from the demographic screen.
- A flow was built so the scanned document routed automatically to operations and data entry was made on the basis of that document.
- Shifting data entry responsibility from branch to operations strengthened segregation of duties.
- Reinforcement e-learning was developed to support correct application of the process.
Outcome
- The financial data underpinning segmentation moved from declaration to evidence.
- Separating the party entering data from the party using it strengthened control.
- The source of pricing and limit errors caused by wrong segmentation was closed.
- The link between document and data became auditable after the fact.
This case study describes the project through its scope and approach. Client name, commercial figures and performance metrics are withheld under confidentiality obligations.
What This Project Left Behind
The accuracy of a data point depends on who enters it and under what incentive. Allowing a unit with a target to enter, without evidence, a figure that affects that target is a control weakness — it requires no bad intent, only the structure. This is precisely the most common finding under the heading of input controls in internal audit.
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