AC-5 Separation of Duties
Identify and document duties requiring separation; define access authorizations to support.
5
artefacts
2
held by a system
1
at each review
moderate
to go live
Identity provider / directory
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Account provisioning and deprovisioning workflow tickets with manager approvals · Identity provider / directory
- Joiner mover leaver workflow evidence integrated with HR · Identity provider / directory
periodic reviewEvidence produced at each review
- Quarterly privileged access review attestations · Identity provider / directory
governing documentDocuments that govern the control
- Control implementation statement for AC-5 citing the system mission and inheritance from common controls · Policy repository / GRC workspace
- System access request forms with business justification · Policy repository / GRC workspace
First move
Start with the 2 of 5 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Privileged accounts shared across administrators without individual accountability
- Access reviews performed but exceptions never remediated
- Role definitions drift from documented matrix without change control
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 sheetAC-4(21) Physical or Logical Separation of Information Flows · AC-6 Least Privilege