What evidence do auditors commonly ask for on 3.3 Configure Data Access Control Lists?

Permission reports for file shares, databases and key applications; Access request approvals showing need-to-know justification; Results of periodic permission reviews.

What is the most common gap auditors find on 3.3?

Everyone or Domain Users groups with access to sensitive shares

CIS Controls v8.1 · CIS Control 3: Data Protection

`3.3` Configure Data Access Control Lists

Set access control lists on data according to need to know, and enforce those permissions on file systems (local or networked), on databases and inside applications. Implementation Groups: IG1, IG2 and IG3 (part of the IG1 essential cyber hygiene baseline, so every enterprise applies it). Asset type: Data. Security function: Protect.

Source: CIS Controls v8.1, 3.3. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CIS Controls v8.1 in the compliance library.

Scope: Implementation Groups: IG1, IG2, IG3. Security function: Protect; asset type: Data.

Each safeguard shows its Implementation Groups. IG1 is the essential baseline for every enterprise, IG2 adds to it, IG3 is all 153. Version 8.1 adds the Govern security function and asks for more processes to be documented; numbering is unchanged from v8.

artefacts

held by a system

at each review

hard

to go live

Identity provider / directory

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Permission reports for file shares, databases and key applications · Identity provider / directory
Access request approvals showing need-to-know justification · Identity provider / directory
Results of periodic permission reviews · Identity provider / directory

governing documentDocuments that govern the control

none for this control

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Everyone or Domain Users groups with access to sensitive shares
Database access granted at schema level for convenience
Cloud storage buckets with public or overly broad access

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

3.2 Establish and Maintain a Data Inventory · 3.4 Enforce Data Retention