How do we…
How do we control administrator access without a PAM platform?
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The short answer
- Recommendation
- Build the privileged access rules with tools you already have: a separate administrator account per tier, security keys or passkeys, Tier 0 and Tier 1 rights that end by themselves, a vault for shared credentials, and logs administrators cannot change, reviewed by someone with no rights in the tier.
- Reasoning
- Privileged accounts are what an attacker looks for first, because one is worth more than every ordinary account together. The rules make a privileged credential hard to steal, short-lived in use and useless where it is most likely to be captured. Each can be built from the directory, group policy, the identity provider, a business password manager and a central log store. A platform automates the vault, the time limits and session recording later; the rules stay the same.
- Considerations
- The 4-hour Tier 0 and 8-hour Tier 1 limits, the 12-month log retention and the review cadences are the pack's defaults. Your own standard may set others.
- Treat a time limit you have not tested as missing. Where the directory cannot time-limit membership, a scheduled task removes the right; the daily report only shows when that failed.
- Any departure from the standard is an exception approved for its band. At Critical that is the board, or a board risk committee it has delegated to; the management board in a two-tier structure; or executive management where there is no board.
- In a small team, the Head of Information Security approves the Head of IT's own elevations. Where nobody inside can review independently, use an outside reviewer and record it as an exception. A provider never reviews its own engineers' sessions.
The decision, step by step
Select any step for the reasoning behind it and where the pack covers it.
- Start
- Step
- Decision
- Outcome
Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.
Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.
Read as text
The same flow written out: each step, its reasoning and where the pack covers it. 20 steps.
Start
Control administrator access with the tools you have
Privileged accounts are what an attacker looks for first, because one is worth more than every ordinary account together. The pack's rules make a privileged credential hard to steal, short-lived when in use, and useless where it is most likely to be captured. Each one can be built from the directory, group policy, the identity provider, a business password manager and a central log store. A platform automates the vault, the time limits and session recording; it is not a precondition.
In the pack
- P14-A02 Privileged Access StandardPurpose
- P14-A02 Privileged Access StandardBuilt-in controls
Step
List every privileged account and give each an owner
Build the list from each system's own records: administrator groups and roles, accounts whose password never expires, accounts that run a service or task, built-in administrators and supplier accounts. Record each one's owner, tier, purpose, where its credential is kept and when it last changed. An account found that nobody claims within 5 working days is disabled.
- Then: Give every system a tier
In the pack
- P14-A04 Privileged & Service Account InventoryInstructions
- P14-A02 Privileged Access StandardInventory and ownership (rule PA-01)
- P14-A04 Privileged & Service Account InventoryAccount types
Step
Give every system a tier
Tier 0 is the identity and control plane: the directory, the cloud identity tenant, the backup and device management consoles, the vault and whatever hosts them. Tier 1 is servers, applications and cloud workloads; Tier 2 is end-user devices and user support. A system takes the tier of the most important thing it can control. A system without a tier has no separation rule, and that is where tier breaches happen.
In the pack
- P14-A02 Privileged Access StandardAdministrative tiers (rule PA-13)
- P14-A08 Administrative Tier Model & Separation MatrixSystem tiers
- P14-A02 Privileged Access StandardScope
Step
Give each administrator a separate account per tier
Create a second account per person per tier in the directory, named by tier (for example a0-, a1-, a2-), with no mailbox and no office licence. Remove every daily account from local and directory administrator groups through device management or group policy. Support uses the local administrator password solution instead, which gives each device its own password, changed after use, with every opening logged.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls (rules PA-02, PA-03)
- P14-A02 Privileged Access StandardSeparate accounts and devices
- P14-A08 Administrative Tier Model & Separation MatrixSeparation rules (rules SR-1, SR-6)
Decision
Does any account hold rights in more than one tier?
An account belongs to one tier and administers only that tier; a person who works in two tiers holds one account for each. An account that spans tiers carries its highest-tier credential onto lower-tier systems. In the pack's example, one account held Tier 0 backup rights and Tier 1 server rights, and signed in to a file server while its Tier 0 elevation was active.
- Yes, or not known: Split it into one account per tier
- No: Deny higher-tier accounts sign-in on lower-tier systems
In the pack
- P14-A08 Administrative Tier Model & Separation MatrixAccount assignments (rule SR-1)
- P14-A02 Privileged Access StandardTier separation
Step
Split it into one account per tier
Give the person a separate account for each tier, and move each right to the account of its tier. The inventory's checks flag each account it lists that spans tiers. Until an account is split, the pack's example checks it by name in each weekly session review.
In the pack
- P14-A08 Administrative Tier Model & Separation MatrixAccount assignments
- P14-A04 Privileged & Service Account InventorySummary
- P14-A07 Privileged Session Review RecordWorked example: the first weekly Tier 0 review
Step
Deny higher-tier accounts sign-in on lower-tier systems
Use group policy to deny sign-in by higher-tier administrator groups on lower-tier systems, for console, Remote Desktop, batch and service logon, and add Tier 0 accounts to the directory's protected users group. Administrators work from an administration device of their tier: a dedicated workstation, a hardened jump host reached from one, or at the least a hardened virtual machine with no email and browsing limited to administration portals.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls (rules PA-04, PA-13)
- P14-A08 Administrative Tier Model & Separation MatrixSeparation rules (rules SR-2, SR-4)
- P14-A02 Privileged Access StandardWhat an account may do on each tier
Step
Require security keys or passkeys for administrator accounts
Register security keys or passkeys in the identity provider you already have, and require them for administrator accounts by sign-in policy. Text message codes, app codes and push approvals are not accepted for any privileged account. An application that offers neither single sign-on nor such a method uses the strongest it has, recorded in the inventory with the date it will move.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls (rule PA-05)
- P14-A02 Privileged Access StandardPhishing-resistant sign-in
Decision
Can the directory or tenant time-limit group or role membership?
Rights in Tier 0 and Tier 1 must be just-in-time: eligible, switched on for one task, and ended by the system after no more than 4 hours in Tier 0 and 8 hours in Tier 1. Most directories offer time-limited group membership, and cloud tenants offer time-limited role assignment where the licence includes it. Not known counts as no until you have tested that a right really ends.
- Yes: Make Tier 0 and Tier 1 rights eligible, ending by themselves
- No, or not known: Add rights by ticket, with a scheduled task to remove them
In the pack
- P14-A02 Privileged Access StandardJust-in-time rights and approval (rule PA-06)
- P14-A02 Privileged Access StandardBuilt-in controls
- P14-A02 Privileged Access StandardAdapting this template
Step
Make Tier 0 and Tier 1 rights eligible, ending by themselves
Remove standing membership of the Tier 0 and Tier 1 groups and roles, and make each one eligible, with the tier's maximum configured. The rights end at the earlier of the approved end and the tier's maximum, switched off by the system, never by someone remembering. An unfinished task needs a new approval; the window is never extended on the same ticket.
In the pack
- P14-A03 Privileged Access Request, Elevation & Revocation ProcedureSetting the end time
- P14-A03 Privileged Access Request, Elevation & Revocation ProcedureInputs and prerequisites
- P14-A03 Privileged Access Request, Elevation & Revocation ProcedureRequest to removal
Step
Add rights by ticket, with a scheduled task to remove them
Where the directory cannot time-limit a membership, add the right by ticket with an end time. A scheduled task removes it at that time, and a daily report lists any right older than its ticket, so a failed removal shows the next day. The report alone is not enough: noticing an expired right is not the same as ending it.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls (rule PA-06)
- P14-A03 Privileged Access Request, Elevation & Revocation ProcedureSetting the end time
Decision
Does anyone still hold standing Tier 0 or Tier 1 rights?
Standing rights are allowed only for break-glass and service accounts, Tier 2 support on separate Tier 2 accounts, read-only monitoring, and application roles the application cannot assign for a time, each recorded in the inventory. Any other standing right is a departure from the standard. Check the directory and tenant themselves, since the inventory only flags the accounts it lists.
- Yes, or not known: Move them, or cover them with a dated plan or an exception
- No: Keep shared, service and break-glass credentials in a vault
In the pack
- P14-A02 Privileged Access StandardJust-in-time rights and approval (rule PA-06)
- P14-A04 Privileged & Service Account InventorySummary
Step
Move them, or cover them with a dated plan or an exception
A rule adopted with a later start date on an approved plan is a transition, not an exception, while the plan holds; if the plan slips, it becomes an exception that day. Anything a plan does not cover is an exception, approved by the approver its band sets. In the pack's example, a managed IT provider's two engineers kept standing server rights between windows under a Medium exception, approved by the Head of Information Security until Tier 1 moves to just-in-time.
In the pack
- P14-A02 Privileged Access StandardExceptions (rule PA-18)
- P14-A02 Privileged Access StandardJust-in-time access and approval
- P02-A02 Security Exception & Waiver StandardApproval authority and maximum duration (rule EX-05)
Step
Keep shared, service and break-glass credentials in a vault
Use the organisation's business password manager, in a shared vault open only to named administrators, with its access log kept. Break-glass credentials are also sealed in a safe. Each credential changes as the rotation table sets: a shared account in the vault at least every 3 months and after every use, and any credential at once on suspicion of compromise.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls (rules PA-10, PA-12)
- P14-A02 Privileged Access StandardCredential rotation
- P14-A02 Privileged Access StandardShared, service and emergency accounts
Step
Send privileged events where administrators cannot change them
Forward the directory's security events, the cloud tenant's audit and sign-in logs and servers' administrator command logs to a central log store, such as one your monitoring provider keeps. Every privileged sign-in, elevation, change to a privileged group or role, and vault opening is kept there for at least 12 months. The pack's control test looks for a test event in the store.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls (rule PA-08)
- P14-A02 Privileged Access StandardLogging and review
- P14-A06 Privileged Access Control Review WorkbookTest guide (rule CT-07)
Decision
Can any administrator change or delete those records?
The people whose actions are checked must not control the record of them: administering a system and reviewing its audit logs is a High conflict in the segregation-of-duties matrix. If the only administrator also runs the log store, the records prove nothing. Not known counts as yes.
- Yes, or not known: Move the records out of the administrators' reach
- No: Is someone with no administrator rights in the tier free to review?
In the pack
- P14-A02 Privileged Access StandardDuties kept apart (rule SOD-IT-03)
- P02-A07 Segregation of Duties Conflict MatrixConflict Catalogue
Step
Move the records out of the administrators' reach
Send them to a store run by someone else, such as your security monitoring provider, and give the administrators no right to change or delete there. Then check that privileged events still arrive. Where one person runs all of IT, the logs are only half the answer; the independent review below is the other half.
In the pack
- P14-A02 Privileged Access StandardBuilt-in controls
- P14-A02 Privileged Access StandardLogging and review (rule PA-08)
Decision
Is someone with no administrator rights in the tier free to review?
Session reviews and the control review are done by someone with no administrator rights in the tier reviewed. In a small IT team the Head of IT may be the only Tier 0 administrator, so their own elevations are approved by the Head of Information Security and their sessions reviewed by someone with no Tier 0 rights. Not known counts as no.
- Yes: Review sessions and controls at the pack's cadence
- No, or not known: Use an outside reviewer and record it as an exception
In the pack
- P14-A02 Privileged Access StandardDuties kept apart
- P14-A07 Privileged Session Review RecordWho reviews
Step
Use an outside reviewer and record it as an exception
Where nobody inside qualifies, the pack suggests your security monitoring provider, an outside adviser, the internal auditor or a peer from another organisation, who does the review and signs the record. It records the arrangement as an exception, so it is approved and expires rather than becoming a habit. A provider never reviews its own engineers' sessions.
In the pack
- P14-A02 Privileged Access StandardDuties kept apart
- P14-A07 Privileged Session Review RecordAdapting this template
- P14-A06 Privileged Access Control Review WorkbookInstructions
Outcome
Review sessions and controls at the pack's cadence
Tier 0 activity is reviewed weekly, every event, within 2 working days; Tier 1 monthly, every event without a ticket plus a sample; Tier 2 quarterly by sample; supplier sessions monthly; every break-glass use within 1 working day. The system owner and information security review privileged access every 3 months, and the controls are tested system by system yearly, every 6 months for Tier 0.
In the pack
- P14-A02 Privileged Access StandardSession review cadence (rule PA-09)
- P14-A02 Privileged Access StandardControl review (rule PA-16)
- P14-A07 Privileged Session Review RecordReview schedule
Practical checklist
- List every privileged account from each system's own records, with its owner, tier, purpose, credential location and last change. Disable any nobody claims within 5 working days (PA-01).
- Give every system a tier. Give each administrator a separate account per tier with no mailbox, and take administrator rights off daily accounts.
- Deny higher-tier accounts sign-in on lower-tier systems, and have administrators work only from an administration device of their tier.
- Require security keys or passkeys for every administrator account by sign-in policy (PA-05).
- Make Tier 0 and Tier 1 rights eligible and time-limited, or add them by ticket with a scheduled removal task. Move remaining standing rights, or cover them with a dated plan or an exception.
- Keep shared, service and break-glass credentials in the vault, seal break-glass credentials in a safe as well, and change them as the rotation table sets (PA-10).
- Send privileged events to a log store administrators cannot change or delete, and check that they arrive (PA-08).
- Have someone with no administrator rights in the tier review sessions at the set cadence, using an outside reviewer where nobody inside qualifies (PA-09).
Evidence to have ready
- The inventory, matched to each system's export of privileged accounts, with the owner, tier, purpose, credential location and last change for every account.
- The eligible Tier 0 and Tier 1 assignments with their maximum durations, the last 30 days of elevations with start and end, and each standing right recorded in the inventory.
- For a sample of elevations and new privileged accounts, the approval by someone other than the user, given before the start.
- The vault's list of shared, service and break-glass credentials with their last change, and its access log.
- Privileged events arriving in the central log store, the store's access rights and its retention setting.
- The session review records, each on time and by a reviewer without rights in the tier, with every anomaly followed up.
Assumptions
- Your directory or identity provider can hold separate administrator accounts, apply group policy or sign-in policies, and register security keys or passkeys.
- You have, or can get, a business password manager with an access log, a safe, and a central log store that someone other than your administrators runs, such as your monitoring provider.
- Someone with no administrator rights in each tier can review privileged activity, or you can bring in an outside reviewer.
- The timings shown are the CISO Times privileged access pack's defaults. Your own standard may set others.
Not covered here
- Choosing or buying a PAM platform. Use your own procurement procedure; the rules stay the same with one.
- Who approves each elevation, and for how long. That is “Who approves temporary administrator rights, and for how long?”.
- Finding and controlling service accounts nobody owns. That is “How do we find and control service accounts nobody owns?”.
- Reviewing who holds privileged access each quarter. That is “How do we review privileged and administrator access?”.
Related questions
- Who approves temporary administrator rights, and for how long?
- How do we find and control service accounts nobody owns?
- How do we roll out phishing-resistant MFA, and in what order?
- If an administrator uses their admin account for email or browsing, then what?
- How do we review privileged and administrator access?