Delegation of Authority Matrix Validator
Segregation of duties pair

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

Clauses

6 clauses
RegimeClause
COSOCOSO P10 Principle 10: Selects and develops control activities
ISO/IEC 27001ISO/IEC 27001 5.3 Segregation of duties · ISO/IEC 27001 5.18 Access rights
NIST SP 800-53NIST SP 800-53 AC-5 Separation of duties · NIST SP 800-53 AC-6 Least privilege
COBITCOBIT DSS06.03 Manage roles, responsibilities, access privileges and levels of authority
COSO P10 Principle 10: Selects and develops control activities

The 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.

What an auditor asks to see: Control matrices linking risks to control activities across processes and levels, with segregation of duties analysis
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 duties

Split conflicting duties so no single person can run a sensitive process end to end unchecked.

What an auditor asks to see: Role separation matrix; Approval workflow records; Access rights review reports; Segregation conflict log
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 rights

Provision, review, modify and remove access rights in line with the access control policy.

What an auditor asks to see: Access provision records; Access review reports; Access revocation logs; Role definition documents
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 duties

Requires 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.

What an auditor asks to see: Documented conflicting duty pairs for the mission and system in question; Role definitions and entitlement mapping showing conflicting duties are not held together; Toxic combination report from the identity system or a manual conflict analysis; Approved exceptions with the compensating detective controls applied
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 privilege

Requires 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.

What an auditor asks to see: Role to entitlement mapping showing privileges justified against job function; Privileged account inventory with business justification for each; Review evidence where excess privilege was identified and removed; Configuration showing service and application accounts run without administrative rights
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 authority

Business 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.

What an auditor asks to see: Authority and limit matrices; segregation of duties allocations; access aligned to roles with prompt removal; privilege reviews and exception reports
Where matrices usually fall short: Transaction limits not enforced in the system; Access accumulated across role changes
Source: COBIT 2019