164.308(a)(4)(ii)(C) Access Establishment and Modification (Addressable)
Implement policies that document, review, and modify a user's right of access. NIST recommends periodic recertification and just-in-time elevation for privileged tasks.
4
artefacts
1
held by a system
3
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
- Privileged access management logs · Identity provider / directory
periodic reviewEvidence produced at each review
- Quarterly access recertification reports · Identity provider / directory
- Modification approval records · Identity provider / directory
- Manager attestations · Identity provider / directory
governing documentDocuments that govern the control
none for this control
First move
Start with the 1 of 4 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
- Recertification not performed
- Privileged accounts not reviewed
- No tracking of access changes over time
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 sheet164.308(a)(4)(ii)(B) Access Authorization (Addressable) · 164.308(a)(5)(i) Security Awareness and Training (Standard)