Granting access and reviewing access
The role that grants privileged access also signs off the review of that access. It is read across two lines of the matrix; one role on both sides of one line is read as self-approval instead.
The question for the matrix owner
Who reviews the access this role grants, and does the review cover the role's own accounts?
The two halves
- Approving privileged system access grants
- Approving user access review sign-off, by the same role
Clauses
6 clauses| Regime | Clause |
|---|---|
| COSO | COSO P10 Principle 10: Selects and develops control activities |
| ISO/IEC 27001 | ISO/IEC 27001 5.3 Segregation of duties · ISO/IEC 27001 5.18 Access rights |
| NIST SP 800-53 | NIST SP 800-53 AC-5 Separation of duties · NIST SP 800-53 AC-6 Least privilege |
| COBIT | COBIT DSS06.03 Manage roles, responsibilities, access privileges and levels of authority |
COSO P10 Principle 10: Selects and develops control activitiesThe organization selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels. Points of focus: Integrates with risk assessment; Considers entity-specific factors; Determines relevant business processes; Evaluates a mix of control activity types; Considers at what level activities are applied; Addresses segregation of duties. Control activities are selected and developed integrated with the risk assessment, considering entity-specific factors (environment, complexity, nature, scope), the relevant business processes, a mix of control activity types (preventive and detective, manual and automated), the level at which activities are applied, and segregation of duties where practical, with alternative controls where not.
Where matrices usually fall short: Controls not traceable to assessed risks; Segregation conflicts unmitigated
Source: COSO Internal Control, Integrated Framework
ISO/IEC 27001 5.3 Segregation of dutiesSplit conflicting duties so no single person can run a sensitive process end to end unchecked.
Where matrices usually fall short: Combining conflicting roles in small teams; Lack of documented exceptions; Infrequent access rights reviews; Reliance on informal approvals
Source: ISO/IEC 27001:2022
ISO/IEC 27001 5.18 Access rightsProvision, review, modify and remove access rights in line with the access control policy.
Where matrices usually fall short: Reviews lack documented corrective actions; Access changes not tied to approved request workflow; Legacy accounts remain active after employee departure; Role definitions not updated to reflect current business processes
Source: ISO/IEC 27001:2022
NIST SP 800-53 AC-5 Separation of dutiesRequires the organization to identify and document the individual duties that must be kept apart to limit malevolent activity without collusion, and to define system access authorizations so that those duties cannot be exercised by one person.
Where matrices usually fall short: Conflicting duties named for finance processes only and never for system administration; Small teams create unavoidable conflicts that are tolerated rather than documented and compensated; Separation enforced at role definition but broken by direct entitlement grants
Source: NIST SP 800-53 Rev 5
NIST SP 800-53 AC-6 Least privilegeRequires access for users and for processes acting for them to be limited to what their assigned tasks actually need, so that no account, role or process holds privileges beyond the minimum required to do its job.
Where matrices usually fall short: Administrator rights granted as a default to speed up troubleshooting and never revoked; Service accounts run with far more privilege than the application needs; Least privilege applied to people while automation and pipeline identities are unrestricted
Source: NIST SP 800-53 Rev 5
COBIT DSS06.03 Manage roles, responsibilities, access privileges and levels of authorityBusiness roles, responsibilities, levels of authority and segregation of duties supporting the process objectives are managed, and access to all information assets related to business processes is authorised: roles and responsibilities follow approved job descriptions and process activities; levels of authority for approving transactions, transaction limits and other decisions follow approved job roles; sensitive activities are allocated so that duties are clearly segregated; access rights and privileges are the minimum needed for predefined job roles, removed or revised immediately on role change or termination; regular awareness and training cover roles, responsibilities, the importance of controls and the security, integrity, confidentiality and privacy of information; administrative privileges are secured, tracked and controlled to prevent misuse; and access control definitions, logs and exception reports are periodically reviewed so that privileges remain valid and aligned with current staff and roles.
Where matrices usually fall short: Transaction limits not enforced in the system; Access accumulated across role changes
Source: COBIT 2019