IAM-04 Separation of Duties
Split duties across separate identities so no single person can both perform and approve a sensitive action.
4
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Evidence of conflicts detected and resolved · Document repository
- Review records for the matrix · Policy repository / GRC workspace
governing documentDocuments that govern the control
- The documented separation of duties matrix for sensitive actions · Policy repository / GRC workspace
- Technical enforcement, such as approval workflows that exclude the requester · Document repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Separation defined on paper with the system permitting self-approval
- Break glass accounts that defeat separation with no compensating monitoring
- Matrix never reviewed as roles changed
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