Key Control Frameworks for Privileged Access Management (PAM), Risks, Controls and Policy Example

Key Control Frameworks for Privileged Access Management (PAM)

Privileged Access Management (PAM) encompasses two distinct but complementary domains: infrastructure PAM and Business Process System Privileged Access Management (BPAM). Infrastructure PAM focuses on securing access to IT infrastructure components, such as servers, networks, and databases, where privileged users like system administrators perform technical maintenance and configuration tasks. In contrast, BPAM addresses privileged access within business-critical applications and processes, such as Enterprise Resource Planning (ERP) systems, financial platforms, or customer relationship management tools, where access is often tied to specific business functions and requires alignment with operational objectives. Both require robust controls, logging, and monitoring to ensure security and compliance, but BPAM emphasizes business context and agility, often involving non-routine or emergency transactions critical to organizational processes.

Overview of Control Frameworks

Several leading control frameworks provide detailed requirements and best practices for managing Privileged Access Management (PAM), which refers to the processes and technologies used to secure, control, and monitor access to critical systems and data by privileged users:

1. COSO 2013 Internal Control—Integrated Framework: Developed by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), this framework provides a principles-based approach to internal controls, emphasizing governance and risk management for privileged access. Key principles include Control Environment (Principle 3) for establishing access policies, Control Activities (Principle 11) for implementing access controls and segregation of duties, and Monitoring Activities (Principle 16) for ongoing review of privileged access usage.

2. NIST SP 800-53: Published by the National Institute of Standards and Technology (NIST), this Special Publication (SP) focuses on Access Control (AC), with controls like AC-2 (Account Management) and AC-5 (Separation of Duties) to enforce least privilege and manage privileged accounts.

3. ISO/IEC 27001 & 27002: Developed by the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC), these standards address privileged access under A.9 (Access Control), emphasizing A.9.2 (User Access Management) and A.12.4 (Logging and Monitoring) for provisioning and oversight.

4. CIS Controls: Provided by the Center for Internet Security (CIS), these controls prescribe inventory, assignment, and review of privileged accounts in Control 6 (Access Control Management) and Control 16 (Account Monitoring and Control).

5. COBIT: Developed by the Information Systems Audit and Control Association (ISACA), Control Objectives for Information and Related Technologies (COBIT) defines governance processes for access management, outlining roles, procedures, and monitoring for privileged user activities.

6. ITIL Security Management: Part of the Information Technology Infrastructure Library (ITIL), this framework integrates PAM into Information Technology (IT) service management, emphasizing accountability and auditability through documented processes.

7. SOC 2 Trust Services Criteria (CC6): Defined by the American Institute of Certified Public Accountants (AICPA), Service Organization Control 2 (SOC 2) mandates logical and physical access controls, least privilege, and credential management for protected assets under the Security criteria (Common Criteria, CC).

Key Focus Areas of PAM Control Frameworks

The following focus areas highlight the critical components of effective PAM across these frameworks:

• Detailed Control Requirements: Implements technical and governance strategies for account management and preventing unauthorized privilege escalation to secure privileged access.

• Information Security Management System: Establishes requirements for provisioning, using, and auditing privileged access within the broader security management system.

• Prescriptive Security Actions: Provides prioritized steps for inventorying, assigning, reviewing, and limiting high-level accounts to minimize risks.

• Governance and Management: Defines processes, roles, and procedures for managing, monitoring, and reviewing privileged user activities within IT environments.

• Service Management Best Practices: Outlines setup and maintenance of access controls and audit trails to ensure secure and auditable service delivery.

Effective Business Privileged Access Management (BPAM)

Effective Business Privileged Access Management (BPAM), which focuses on managing privileged access for business-critical processes, is critical for maintaining operational agility and compliance, particularly during non-routine or emergency transactions. It blends robust control frameworks, detailed procedures, well-defined roles, and clear risk awareness with monitoring protocols to ensure secure and auditable privileged access.

Artificial Intelligence (AI) tools, which perform tasks such as data analysis, automation, and system management, require the same rigorous privileged user access management as human users to mitigate risks of unauthorized access or misuse. These tools often access sensitive data or critical systems, necessitating strict controls, including Role-Based Access Control (RBAC), immutable access logs, and real-time monitoring to ensure accountability and traceability. Current large and small Software as a Service (SaaS) solutions, such as Okta, SailPoint, or CyberArk for Identity Access Management (IAM), and BeyondTrust or OneLogin for BPAM, provide centralized platforms to manage user identities, enforce least privilege, and integrate with cloud and on-premises systems. These solutions support automated provisioning, deprovisioning, and audit logging, enabling organizations to align AI and human privileged access with frameworks like NIST SP 800-53 and SOC 2, ensuring compliance and operational security.

Best Practices for BPAM

• Pre-defined Exception Policies: Define who can approve, execute, and review privileged access, under what conditions, and for how long.

• Break-Glass Access: Grant time-bound, role-appropriate elevated access triggered by specific business needs.

• Immutable Logging: Automatically capture all privileged activities in real-time and store them tamper-proof.

• Real-Time Monitoring: Enable compliance or security teams to monitor activities with instant alerts for deviations or risky actions.

• Post-Event Reviews: Conduct structured reviews to validate the necessity and compliance of each privileged access use.

• Limit Duration and Scope: Grant the minimum access necessary for the shortest feasible window.

• Segregation of Duties: Ensure approvers, executors, and reviewers are distinct individuals.

• Periodic Reviews: Regularly review privileged access usage and processes for continuous improvement.

• Integration Across Platforms: Apply consistent BPAM procedures and centralized tracking across all Enterprise Resource Planning (ERP) systems and cloud platforms.

• Link to Tickets/Incidents: Tie all elevated access requests to a ticket or incident for transparency and context.

Control Framework Guidance for BPAM

• Role Definition: Clearly define BPAM roles (e.g., BPAM User, Owner, Log Reviewer, Administrator) with formal responsibilities.

• Approval and Traceability: Require approval, authentication, and end-to-end audit traceability for emergency access grants.

• Preventive and Detective Controls: Implement preventive controls (e.g., approval, owner notification) at workflow start and detective controls (e.g., session logging, alerts) throughout.

• Comprehensive Logging: Log all activities, from provisioning to emergency access, with immutable storage and automated audit reporting.

• Framework Alignment: Leverage COSO 2013, NIST SP 800-53 (AC-2, AC-5), ISO/IEC 27001/27002 (A.9.2, A.12.4), and ITIL security management processes.

• Centralized Administration: Manage privileged roles centrally and provide routine training for stakeholders.

• Governance and Monitoring: Conduct periodic internal audits and use Continuous Control Monitoring (CCM) principles.

Suggested User Roles for Approving Privileged Access

To ensure proper governance and segregation of duties, the following roles are recommended for approving privileged access requests:

• Information Security Manager: Oversees security policies and approves access to critical systems to ensure alignment with organizational security standards.

• IT Director/Manager: Approves access for IT-related systems, ensuring technical alignment and operational necessity.

• Compliance Officer: Validates access requests against regulatory and internal policy requirements, particularly for sensitive or regulated data.

• Business Unit Leader: Approves access for business-specific systems or processes, ensuring alignment with operational needs.

• CISO (Chief Information Security Officer): Provides high-level oversight and final approval for high-risk or cross-functional access requests, collaborating with Business Process Owners to support business goals.

These roles should be distinct from executors (e.g., BPAM Users) and reviewers (e.g., BPAM Log Reviewers) to maintain segregation of duties.

COSO and AICPA Business Processes Requiring PAM

PAM is integral to several COSO and AICPA business processes to ensure secure access, compliance, and operational integrity. Below are the key processes requiring PAM:

COSO 2013 Framework Processes

The COSO 2013 Internal Control—Integrated Framework outlines processes where PAM is critical:

• Control Environment: Establishing access control policies and roles (Principle 3) to enforce accountability and integrity in privileged access.

• Risk Assessment: Identifying and mitigating risks associated with privileged access to critical systems (Principle 7).

• Control Activities: Implementing access controls, segregation of duties, and monitoring for privileged accounts (Principle 11).

• Information and Communication: Ensuring secure handling and logging of privileged access activities for audit and reporting (Principle 13).

• Monitoring Activities: Conducting ongoing reviews and audits of privileged access usage to ensure compliance (Principle 16).

AICPA Trust Services Criteria (Relevant to SOC 2)

The AICPA Trust Services Criteria, used in SOC 2, have a number of common criteria that require well designed PAM Controls and PAM controls to be operating effectively:

• CC6.1 - Logical Access Controls: Managing privileged access to restrict unauthorized access to systems, data, and applications.

• CC6.2 - User Access Authentication: Enforcing strong authentication for privileged accounts to prevent unauthorized use.

• CC6.3 - Role-Based Access: Defining and restricting privileged roles to enforce least privilege and segregation of duties.

• CC6.6 - Monitoring of Access: Implementing real-time monitoring and logging of privileged access activities.

• CC6.7 - Control of Privileged Access: Managing the lifecycle of privileged accounts, including provisioning, deprovisioning, and periodic reviews.

• CC7.1 - Detection and Monitoring: Ensuring privileged access activities are logged and monitored for anomalies or unauthorized actions.

Well designed PAM controls ensure that PAM supports secure operations, financial reporting integrity, and regulatory compliance across critical business functions.

Risks Associated with Improper BPAM

Improper BPAM can lead to significant risks, including:

• Unauthorized access, which may result in fraud, data theft, or process manipulation in critical systems.

• Bypassed segregation of duties, causing a loss of accountability due to privilege elevation.

• Prolonged access, creating extended windows for abuse or error due to failure to terminate access.

• Inadequate logging, resulting in insufficient forensic evidence for incident investigations.

• Lack of oversight, allowing repeated or unjustified access due to poor post-event reviews.

• Over-reliance on manual controls, increasing the risk of human error or deliberate misuse.

• Noncompliance with regulatory requirements, such as those under the Health Insurance Portability and Accountability Act (HIPAA) or the General Data Protection Regulation (GDPR), exposing the organization to fines or legal action.

• Reputational and financial loss from unapproved changes or data breaches.

BPAM Roles and Workflow

The following roles are critical for BPAM workflows:

• BPAM User: This role is responsible for executing emergency activities with tightly scoped, time-bound access to ensure minimal risk and compliance with policies.

• BPAM Owner: This role reviews and approves access requests for privileged roles, ensuring alignment with business and security requirements.

• BPAM Log Reviewer: This role reviews and approves audit trails and activity logs to verify the legitimacy and compliance of privileged access activities.

• BPAM Administrator: This role manages role design, process governance, and coordination with audits to maintain a robust BPAM framework.

BPAM and PAM Policy Document

This policy establishes guidance rules for implementing and managing BPAM and PAM to ensure secure, compliant, and auditable privileged access across organizational systems and processes.

Policy Scope

This policy applies to all employees, contractors, and third parties who require privileged access to organizational IT systems, ERP platforms, cloud environments, or business-critical processes. It covers both routine PAM and emergency BPAM scenarios.

Policy Objectives

• Ensure least privilege and segregation of duties for all privileged access.

• Maintain compliance with regulatory requirements (e.g., HIPAA, GDPR) and internal policies.

• Enable operational agility while minimizing security risks.

• Provide clear audit trails for all privileged access activities.

Policy Requirements

1. Role-Based Access Control (RBAC):

   • Define and assign privileged roles (e.g., BPAM User, Owner, Log Reviewer, Administrator) based on job functions and business needs.

   • Ensure roles align with the principle of least privilege, granting only the access necessary for specific tasks.

2. Approval Process:

   2.1 All privileged access requests must be approved by at least one designated approver, such as the Information Security Manager, IT Director/Manager, Compliance Officer, Business Unit Leader, or CISO.

   2.2 Emergency "break-glass" access requires approval from two distinct approvers, one of whom must be the CISO or Compliance Officer.

   2.3 All requests must be linked to a documented ticket or incident in the organization’s IT service management system.

3. Time-Bound Access:

   3.1 Privileged access must be granted for the minimum duration necessary, with a maximum duration of 24 hours for emergency access unless extended with documented justification.

   3.2 Automated expiration of access must be enforced, with notifications sent to the BPAM Owner and Administrator.

4. Segregation of Duties:

   4.1 Approvers, executors (BPAM Users), and reviewers (BPAM Log Reviewers) must be distinct individuals to prevent conflicts of interest.

   4.2 BPAM Administrators must not execute or approve access requests.

5. Logging and Monitoring:

   5.1 All privileged access activities must be logged in real-time using immutable, tamper-proof storage.

   5.2 Enable real-time monitoring with automated alerts for unauthorized or anomalous activities, overseen by the Information Security Manager or Compliance Officer.

   5.3 Logs must include user identity, timestamp, system accessed, actions performed, and approval details.

6. Post-Event Review:

   6.1 Conduct structured post-event reviews within 48 hours of privileged access usage, led by the BPAM Log Reviewer.

   6.2 Validate the necessity, scope, and compliance of each access event, documenting findings for audit purposes.

7. Periodic Reviews and Audits:

   7.1 Conduct quarterly reviews of all privileged accounts, roles, and access policies, led by the BPAM Administrator.

   7.2 Perform annual internal audits aligned with COSO 2013, NIST SP 800-53, and SOC 2 requirements to ensure compliance.

8. Integration and Consistency:

   8.1 Implement consistent PAM and BPAM procedures across all ERP systems, cloud platforms, and on-premises infrastructure.

   8.2 Use centralized tools for access management, logging, and monitoring to ensure uniformity and traceability.

9. Training and Awareness:

   9.1 Provide mandatory annual training for all privileged users, approvers, and administrators on PAM/BPAM policies, risks, and best practices.

   9.2 Conduct regular awareness campaigns to reinforce the importance of secure privileged access.

10. Compliance with Frameworks:

    10.1 Align PAM and BPAM processes with COSO 2013 (Principles 3, 7, 11, 13, 16), NIST SP 800-53 (AC-2, AC-5), ISO/IEC 27001/27002 (A.9.2, A.12.4), ITIL Security Management, and SOC 2 Trust Services Criteria (CC6.1, CC6.2, CC6.3, CC6.6, CC6.7, CC7.1).

    10.2 Ensure adherence to regulatory requirements, including HIPAA and GDPR, as applicable.

Policy Enforcement

• Non-Compliance: Violations of this policy, including unauthorized access or failure to follow approval processes, may result in disciplinary action, up to and including termination, and potential legal consequences.

• Monitoring: The Information Security Manager and Compliance Officer will oversee policy compliance, supported by CCM tools.

• Updates: This policy will be reviewed and updated annually or as needed to reflect changes in regulatory requirements, organizational needs, or industry best practices.

Policy Approval

This policy must be approved by Business Process Owners, who are responsible for the processes impacted by privileged access controls, to ensure alignment with business objectives. The CISO, in a supportive role, collaborates with Business Process Owners to design and enforce security measures that align with organizational goals. Additional approvers include the Chief Compliance Officer and the IT Director, with input from Business Unit Leaders and the BPAM Administrator, to ensure comprehensive oversight and alignment with both security and business requirements.

Business Objectives Supported

These frameworks, focus areas, BPAM practices, aligned COSO/AICPA processes, and the BPAM/PAM policy support three core business objectives:

1. Effectiveness and Efficiency of Operations: Ensures reliable, secure, and timely management of privileged access to support IT and business processes.

2. Reliability of Financial Reporting: Provides robust controls to ensure the integrity and accuracy of financial data and reporting.

3. Compliance with Applicable Laws and Regulations: Aligns PAM and BPAM practices with statutory regulations (e.g., HIPAA, GDPR) and internal policies.

By adhering to these best practices, roles, risk-aware approaches, and the formalized BPAM/PAM policy within control frameworks, organizations can ensure both business agility and a strong audit posture during privileged operations.

References

• American Institute of Certified Public Accountants. (2018). Trust services criteria for security, availability, processing integrity, confidentiality, and privacy. AICPA.

• American Institute of Certified Public Accountants. (2018). SOC 2® reporting on an examination of controls relevant to security, availability, processing integrity, confidentiality, or privacy. AICPA.

• AXELOS. (2019). ITIL 4 foundation: IT service management framework. The Stationery Office.

• Center for Internet Security. (2021). CIS critical security controls for effective cyber defense, version 8. CIS.

• Committee of Sponsoring Organizations of the Treadway Commission. (2013). Internal control—Integrated framework. COSO.

• European Union. (2016). Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation). Official Journal of the European Union.

• Gartner. (2021). Best practices for privileged access management. Gartner Research.

• Institute of Internal Auditors. (2015). GTAG-3: Continuous auditing and monitoring. The Institute of Internal Auditors.

• International Organization for Standardization & International Electrotechnical Commission. (2022). ISO/IEC 27001:2022 information security, cybersecurity and privacy protection—Information security management systems requirements. ISO.

• International Organization for Standardization & International Electrotechnical Commission. (2022). ISO/IEC 27002:2022 information security, cybersecurity and privacy protection—Code of practice for information security controls. ISO.

• Information Systems Audit and Control Association. (2019). COBIT 2019 framework: Governance and management objectives. ISACA.

• National Institute of Standards and Technology. (2020). Security and privacy controls for information systems and organizations (NIST SP 800-53 Rev. 5). U.S. Department of Commerce.

• U.S. Department of Health & Human Services. (2013). The HIPAA security rule. HHS.gov.