How do you perform quarterly access reviews?
Savvy organizations usually deploy some type of identity and access management (IAM) solution. IAM solutions leverage the principle of least privilege (POLP), role-based access control (RBAC), or other such mechanisms to manage access to data, applications, and IT infrastructure.
However, every organization's structure and human resources capacity typically change over time as new employees are brought on board and existing ones quit. For large organizations, this can result in hundreds, or even thousands, of employees changing roles or leaving every year.
Without some form of periodic user access review in place, there's a very real risk that former employees may still retain access to sensitive corporate data and systems after being terminated. The same applies to current employees who accumulate user privilege access over time as they move through different roles and departments.
User access reviews are a great way to prevent these security risks from occurring and transforming into full-blown threats.
What is a user access review?
Access reviews describe the process of monitoring the rights and privileges of everyone who can interact with data and applications. This includes management personnel, employees, vendors, service providers, and other third parties. Also known as entitlement review, account attestation, or account recertification, access reviews are essential to the management, monitoring, and auditing of user account lifecycles.
Access reviews ensure that the access rights to an organization's information system (granted to a user) are authorized and appropriate for that user's role and functions. This review applies to all existing access rights to a company's data, applications, and infrastructure. Reviews pinpoint:
- which access rights are authorized and approved
- what level of access each user has
- who has access to what within the organization
In addition to protecting an organization's data and IT assets, a user access review is an essential prerequisite for the thorough implementation of security and compliance frameworks.
It is a mandatory control mechanism used by companies in industries and verticals subject to the following standards: HIPAA, CRBF, Solvency, CMMC, SOC 1 and 2, SOX, ISAE 3402, ISO 27002, and ISO 27001, among others. It also helps companies adhere to security best practices and risk management by facilitating the separation of duties, the principle of need-to-know, and the principle of least privilege.
How often do you perform access reviews?
Providing unauthorized users with access rights to sensitive corporate data and IT assets can result in risks, inadvertent mistakes, or malicious attacks that are detrimental to an organization's reputation and bottom line. Other risks include:
- Outdated user access policies
- Account misconfiguration
- Internal threats, malicious and accidental
- Access abuse
- Inappropriate or unauthorized access
- Privilege creep
To prevent these risks from becoming full-blown security incidents, access reviews must be undertaken at regular intervals. Smaller companies may find it easier to frequently review user access due to a manageable number of employees and systems. However, such companies typically don't have high employee turnover, and as such, can afford to review their user access once or twice a year.
Conversely, larger corporations often have a slew of employees that are constantly leaving, changing roles/departments, or being onboarded as new hires. While frequent access reviews are beneficial from a security standpoint, the vast array of systems, IT assets, and data makes it a challenging task.
For such organizations, it's a good idea to audit high-risk assets more often than lower-risk systems and then perform biannual access reviews. For best results (regardless of company size or industry), access reviews should be performed quarterly to stay on top of constantly changing access rights and prevent potential security problems.
Who should perform access reviews?
The first step in performing a quarterly access review is the creation of a report which lists all systems, applications and databases, in addition to users and their access rights. This includes employees, management personnel, and third parties such as consultants, service providers, and vendors.
This report is sent to asset owners who will determine each department's needs and either approve or reject the access rights of that department. Department managers can then determine if users should be allowed access to the approved data and applications based on their functions.
Although this sounds counterintuitive, performing access reviews and recertifying access rights doesn't automatically fall within the purview of the IT department. Ideally, your organization should have a security lead or asset owner who manages, oversees, and supervises system access across all infrastructure and applications.
There should also be a dedicated admin to manage access for individual users for any given application and infrastructure. This can be a team lead or departmental manager because they are conversant with employee roles and responsibilities
How automated compliance platforms can help
Access rights and privileges are implicated in an organization's data, servers, applications, and infrastructure. The nature of these rights can change and the type of processes and tools needed to perform quarterly access reviews depends on a myriad of factors, including logic and access delivery mechanisms, reporting requirements, the nature and number of protected assets, and compliance objectives.
Although manual user access reviews can be done through the use of Excel spreadsheets, this adds a layer of complexity and difficulty to an already tedious process. Manually retracing and verifying all assigned access rights is time-consuming and prone to errors. It can quickly become a nightmare if the volume of data and the number of users involved is substantial. In fact, without the right solution to provide an overview of existing permissions, performing quarterly access reviews may seem impossible.
This is why savvy companies leverage robust compliance platforms to automate the access review process. The best automation solutions:
- come with reporting tools that provide you with a view of all existing access rights and privileges across your entire IT infrastructure.
- have an intuitive user interface that enables reviewers to easily confirm or reject access rights.
- come with predefined responses to be triggered when data owners don't perform required actions.
- save time by automating the procedures required in quarterly user access review campaigns.
- provide auditors with ready-to-use reports at the click of a button.
- automatically identify and correlate the responsibility of each user with the permissions needed to access specific resources.
- provide comprehensive mapping of the access rights within the targeted scope.
- enforce security and compliance policies within your organization by simplifying the performance of quarterly access reviews.
The right compliance platform can easily implement a single, comprehensive process to meet access review requirements of all major standards, such as ISO, SOC 2, PCI, and HIPAA. The platform should be highly flexible and customizable and provide you with the option to build out access review procedures with custom policies and controls. You should also receive alerts when users, individual departments, or the entire organization is due for user access review.
Vanta’s Access Review
Vanta’s Access Review solution reduces the need for spreadsheets by using automated, pre-built content and intuitive workflows to guide you through the quarterly access review process. With Access Reviews, your team can pass audits and accelerate revenue by gaining attestations and certifications faster.
Reduce the time and cost of an access review up to 90% with continuous, automated management. Our enhanced solution allows you to proactively reduce the risk of both employees (the main surface area of risk within an organization) and external threats.
Learn more about Vanta’s enhanced Access Review solution.
Determine whether the GDPR applies to you and if so, if you are a processor or controller (or both)
Do you sell goods or service in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Create a Data Map by taking the following actions
Identify and document every system (i.e. database, application, or vendor) which stores or processes EU or UK based personally identifiable information (PII)
Document the retention periods for PII in each system
Determine whether you collect, store, or process “special categories” of data
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
Determine your grounds for processing data
For each category of data and system/application have you determined the lawful basis for processing based on one of the following conditions?
Take inventory of current customer and vendor contracts to confirm new GDPR-required flow-down provisions are included
Review all customer contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Review all in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Have you performed a risk assessment on vendors who are processing your PII?
Determine if you need to do a Data Protection Impact Assessment
Is your data processing taking into account the nature, scope, context, and purposes of the processing, likely to result in a high risk to the rights and freedoms of natural persons?
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Does the notice to the data subject include the following items?
Does the notice also include the following items?
Do you have a mechanism for persons to change or withdraw consent?
Update internal privacy policies to comply with notification obligations
Update internal privacy notices for EU employees
Determine if you need to appoint a Data Protection Officer, and appoint one if needed
Have you determined whether or not you must designate a Data Protection Officer (DPO) based on one of the following conditions (Art. 37)?
If you export data from the EU, consider if you need a compliance mechanism to cover the data transfer, such as model clauses
If you transfer, store, or process data outside the EU or UK, have you identified your legal basis for the data transfer (note: most likely covered by the Standard Contractual Clauses)
Have you performed and documented a Transfer Impact Assessment (TIA)?
Confirm you are complying with other data subject rights (i.e. aside from notification)
Do you have a defined process for timely response to Data Subject Access Requests (DSAR) (i.e. requests for information, modification or deletion of PII)?
Are you able to provide the subject information in a concise, transparent, intelligible and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need to appoint an EU-based representative, and appoint one if needed
Have you appointed an EU Representative or determined that an EU Representative is not needed based on one of the following conditions?
If operating in more than one EU state, identify a lead Data Protection Authority (DPA)
Do you operate in more than one EU state?
If so, have you designated the Supervisory Authority of the main establishment to act as your Lead Supervisory Authority?
Implement Employee Trainings to Demonstrate Compliance with GDPR Principles and Data Subject Rights
Have you provided appropriate Security Awareness and Privacy training to your staff?
Update internal procedures and policies to ensure you can comply with data breach response requirements
Have you created and implemented an Incident Response Plan which included procedures for reporting a breach to EU and UK Data Subjects as well as appropriate Data Authorities?
Do breach reporting policies comply with all prescribed timelines and include all recipients i.e. authorities, controllers, and data subjects?
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measure ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed?
Consider streamlining GDPR compliance with automation
Transform manual data collection and observation processes into continuous monitoring
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Develop a roadmap for successful implementation of an ISMS and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider ISO 27001 certification costs relative to org size and number of employees
Clearly define scope of work to plan certification time to completion
Select an ISO 27001 auditor
Set the scope of your organization’s ISMS
Decide which business areas are covered by the ISMS and which are out of scope
Consider additional security controls for business processes that are required to pass ISMS-protected information across the trust boundary
Inform stakeholders regarding scope of the ISMS
Establish an ISMS governing body
Build a governance team with management oversight
Incorporate key members of top management, e.g. senior leadership and executive management with responsibility for strategy and resource allocation
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Execute a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks
Summarize each identified risk
Indicate the impact and likelihood of each risk
Document a risk treatment plan
Design a response for each risk (Risk Treatment)
Assign an accountable owner to each identified risk
Assign risk mitigation activity owners
Establish target dates for completion of risk treatment activities
Complete the Statement of Applicability worksheet
Review 114 controls of Annex A of ISO 27001 standard
Select controls to address identified risks
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in the ISMS implementation
Continuously assess and manage risk
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
Assemble required documents and records
Review ISO 27001 Required Documents and Records list
Customize policy templates with organization-specific policies, process, and language
Establish employee training and awareness programs
Conduct regular trainings to ensure awareness of new policies and procedures
Define expectations for personnel regarding their role in ISMS maintenance
Train personnel on common threats facing your organization and how to respond
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements
Perform an internal audit
Allocate internal resources with necessary competencies who are independent of ISMS development and maintenance, or engage an independent third party
Verify conformance with requirements from Annex A deemed applicable in your ISMS's Statement of Applicability
Share internal audit results, including nonconformities, with the ISMS governing body and senior management
Address identified issues before proceeding with the external audit
Undergo external audit of ISMS to obtain ISO 27001 certification
Engage an independent ISO 27001 auditor
Conduct Stage 1 Audit consisting of an extensive documentation review; obtain feedback regarding readiness to move to Stage 2 Audit
Conduct Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls
Address any nonconformities
Ensure that all requirements of the ISO 27001 standard are being addressed
Ensure org is following processes that it has specified and documented
Ensure org is upholding contractual requirements with third parties
Address specific nonconformities identified by the ISO 27001 auditor
Receive auditor’s formal validation following resolution of nonconformities
Conduct regular management reviews
Plan reviews at least once per year; consider a quarterly review cycle
Ensure the ISMS and its objectives continue to remain appropriate and effective
Ensure that senior management remains informed
Ensure adjustments to address risks or deficiencies can be promptly implemented
Calendar ISO 27001 audit schedule and surveillance audit schedules
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
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Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
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