Access Management: Going beyond SoD rulesManaging Segregation of duties is not enough to implement an ethos of good practice and build a firm foundational control environment. Most organizations routinely perform access reviews. These verify whether users have appropriate access to the processes and programs necessary for their roles and responsibilities. Although the procedures used to monitor and verify user access will often vary, you must carry out an annual review to reduce organizational risk. It would be best if you addressed the following when conducting such a review: Show
Failing to
de-provision unnecessary or inappropriate access granted over time or for short-term needs is one significant factor contributing to employees having unintended access. The responsibility for performing periodic verification of the appropriateness of access rests with the relevant system and/or business owners. ALLOut TipAlways start your user access review process by eliminating inactive users that no longer need to be in the system. With this approach, you will not waste time unnecessarily in each of the next steps. Similarly, performing a critical process access validation before a Segregation of Duties review ensures that you do not spend time in remediation or mitigation for access that is not really needed. Critical process access reviews are most commonly completed based on a review of users with critical roles assigned or by utilizing the lists of programs that allow access to the critical process and reporting on users that have access to them. When determining what critical processes to include, do not forget to include access to inquiry or report over confidential or protected data such as employee personal information. If you would like to learn more about user access reviews, watch our on-demand webinars - Managing User Access in JD Edwards..
On this pageThis is a Controlled Document Inline with GitLab's regulatory obligations, changes to controlled documents must be approved or merged by a code owner. All contributions are welcome and encouraged. PurposeGitLab's user access review is an important control activity required for internal and external IT audits, helping to minimize threats and provide assurance that the right people have the right access to critical systems and infrastructure. This procedure details process steps and provides control owner guidance for access reviews. Benefits to the organization:
ScopeIn-Scope SystemsSecurity Compliance performs Access Reviews for Tier 1 and Tier 2 systems in scope for our compliance and regulatory programs. See the tech stack for the current listing of Tier 1 and Tier 2 systems. Out-of-scope SystemsTier 3 applications as defined in the tech stack are not in scope, however, all system owners are highly encouraged to perform a minimum of an annual terminated access review for their owned systems using this process as a guide. Roles & Responsibilities
What is Authomize and why do I have an Okta tile for it?Authomize is GitLab's User Access Review tool. It is used to facilitate all user access reviews. By default, all team members will receive access to Authomize upon onboarding. To access Authomize, team members can select the Authomize tile in Okta. If you are assigned an access review, please follow the runbook linked below to complete the access review. Access Review ProcedureTerminated Users
Entitlement
Access Review runbookThe Authomize review runbook here provides the outline to complete these access reviews, including how to confirm least privilege. In the event access is identified to no longer be required, open an Access Removal issue for each account that no longer requires access and relate it to the system access review issue. If you have any questions or require assistance with completing an access review, please contact the GitLab Security Compliance team. Access Review Cadence FY23:
All components of a user access review must be completed within the time period under audit. For example, if a user access review is scheduled for Q2, all components of the review including any required actions for modification/removal and lookbacks must be completed by the end of the quarter. It would not be sufficient to have outstanding requests for modification/removal at the quarter end, regardless of the users being identified for modification/removal prior to quarter end. The determination and tracking of systems ranked by tiers 1-4 are managed in the GitLab Critical Systems Inventory and is the SSOT of which systems require UARs and should always be referenced when in doubt. Access RemovalsIf appropriateness of access cannot be verified as part of the review or a system owner/reviewer flags a user for removal, a validation will take place with the team member’s manager prior to access removal as per the Observation Management Procedure. This validation must take place within 7 calendar days and if access is determined to not be required OR no agreement can be reached within that SLA between the Manager and system owner/reviewer, access will be removed. If the risk associated with unvalidated access is too high, access will be revoked immediately and impacted users will be directed towards the new access request process for re-provisioning. While we want to avoid disruption in access whenever possible, we need to balance the impact of that disruption with the risk of continued and unvalidated access to GitLab systems. Additional GuidanceTiming of Quarterly Access Reviews
Lookback ReviewsFor any accounts that require any removal of access (full removal or individual roles/privileges), a lookback review may be required. A lookback review is a review of activity for the period of time which the access was inappropriate. Example scenarios where a lookback may be required:
In cases where there is a disagreement between system owner and manager as to whether a lookback is required, it should be completed. Engage the appropriate personnel (i.e system owner) to perform a lookback assessment to validate the account(s) did not use the access inappropriately. It may not be necessary to perform a lookback in all cases, for example:
The most simple method to perform a lookback for users is to review their last login date/time and validate it was not after the date access was no longer appropriate. If a last login shows the account did authenticate after the access was inappropriate, a full review should be performed to determine any activity from the account during that time to validate no risk. If a last login is not available, other validations should be performed to confirm the account was not used inappropriately after termination (i.e review of key transactions etc.) Evidence of the completed lookback review should be retained and documented within the access review workbook or other associated documentation. Validation of Modifications completedFor any accounts that are requested for modification or removal, validation they were modified as requested should be completed and evidence captured of their successful modification (i.e screenshot, updated user listing that reflects changes made). Access Review Notification RemindersSecurity Compliance managed access reviews required for audit evidence have a deadline of 10 business days from the launch of the review in Authomize. Automated reminders will be used based on number of days out from the due date:
{-If an access review is not completed within 10 days, identified access will be removed.-} Access List For ReviewAccess List GenerationBased on how the system access is maintained will determine the method of account and related permissions export for access review. This will most likely fall to the business or technical owner identified in the Tech Stack Applications.
Access List Data FieldsThe following fields are the most comprehensive to assist in performing a thorough access review: (all are helpful, but all might not be available)
Access Listing Generation Validation
How to provide a desktop timestamp screenshot:
ExceptionsExceptions to this procedure will be tracked as per the Information Security Policy Exception Management Process. References
How should the information security manager treat regulatory compliance?assess the risk of noncompliance. The information security manager should treat regulatory compliance requirements as: just another risk. Management decided that the organization will not achieve compliance with a recently issued set of regulations.
Which of the following is the most important consideration when developing an information security strategy?Which of the following is MOST important in developing a security strategy? B is the correct answer. Technical vulnerabilities as a component of risk will be most relevant in the context of threats to achieving the business objectives defined in the business strategy.
Which of the following aspects has the highest impact on the implementation of an organization's information security governance model?Which of the following aspects has the highest impact on the implementation of an organization's information security governance model? Consistency and continuity of information is an important factor in incident responses.
What would a risk management program be expected to accomplish?Essentially, the goal of risk management is to identify potential problems before they occur and have a plan for addressing them. Risk management looks at internal and external risks that could negatively impact an organization.
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