What evidence do auditors commonly ask for on IAM-09 Segregation of Privileged Access Roles?

Privileged role catalogue showing separate roles for data administration, key management, encryption and logging; Identity provider or cloud IAM configuration enforcing the split; Report of accounts holding more than one segregated privileged role, with justification; Periodic evaluation records of the segregation.

What is the most common gap auditors find on IAM-09?

One break-glass or super-administrator role holding every capability in daily use

CSA CCM v4.1 · IAM - Identity & Access Management

`IAM-09` Segregation of Privileged Access Roles

Define, put in place and assess processes, procedures and technical measures that keep privileged access roles segregated from one another.

Source: CSA CCM v4.1, IAM-09. 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 CSA CCM v4.1 in the compliance library.

Version 4.1 adds 11 controls (among them API security, log sanitisation and a service bill of materials) and renumbers several domains. CSA accepts v4.0.x during its transition; if your STAR assessment is still on v4.0.1, check the numbering against it.

artefacts

held by a system

at each review

moderate

to go live

Cloud console / configuration management

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

Identity provider or cloud IAM configuration enforcing the split · Cloud console / configuration management

periodic reviewEvidence produced at each review

Report of accounts holding more than one segregated privileged role, with justification · Identity provider / directory
Periodic evaluation records of the segregation · Document repository

governing documentDocuments that govern the control

Privileged role catalogue showing separate roles for data administration, key management, encryption and logging · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

One break-glass or super-administrator role holding every capability in daily use
Logging administrators able to alter or disable the logs of their own actions
Key management rights held by the same people who administer the data

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

IAM-08 Access Review · IAM-10 Management of Privileged Access Roles