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CISO Times

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The CISO Decision Brief

If…, then how…

If the only IT administrator also manages the security logs, then how do we control that?

6 decision pointsThe pack behind this answer: Security Exception, Waiver & Segregation of Duties

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The short answer

Recommendation
Treat it as a High conflict and take the logs out of the administrator's reach: forward them to a store the administrator can only read, and send alerts and a monthly activity review to someone else. Test the alerts, record the conflict as an approved exception with an expiry date, and check it every quarter.
Reasoning
The logs are how anyone would find out that administrator rights were misused, so when one person holds both, misuse and its record can disappear together. Separation is usually impossible with one administrator. The record can still be protected and watched. A read-only log store keeps the record, alerts to someone else show high-risk changes as they happen, and an independent monthly review covers the rest. Tested controls lower the exception's likelihood, so the conflict can stay High while the exception scores lower.
Considerations
  • Review frequencies, deadlines and approval levels are the defaults in the CISO Times exceptions pack. Your own standard may set different ones. In the pack's example the conflict is High and the exception scores Medium.
  • If the administrator also holds the security role, they cannot assess or approve their own exception. In the pack's example the standard names the managing director to approve, and the IT provider acts as information security at reviews.
  • Standing administrator rights that combine these duties are not emergency access. They follow the full conflict routine.
  • Unexplained activity, missing logs or logging that stopped may mean misuse. Use your incident route, and never ask the administrator to investigate their own activity.

The decision, step by step

Select any step for the reasoning behind it and where the pack covers it.

  • Start
  • Step
  • Decision
  • Outcome
  • Loop back

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. 19 steps.
  1. Start

    One IT administrator also controls the security logs

    The logs are how anyone would find out that administrator rights were misused. When the same person holds the rights and controls the logs, misuse and its record can disappear together. It is a common position in a company with one IT person, and it can be covered.

    In the pack

  2. Step

    Record it as a High conflict

    Administering a system and reviewing its logs is a High conflict in the pack's matrix: one person could misuse access and then change or delete the entries that record it. Standing administrator rights that combine the two are not emergency access. They follow the full conflict routine and are normally rated High.

    In the pack

  3. Decision

    Does anyone else see administrator activity today?

    Yes only if someone other than the administrator already receives alerts or reviews activity, from data the administrator cannot alter. A log the administrator can clear does not count. If you are not sure, answer no.

    In the pack

  4. Step

    Tell the risk owner and agree a stopgap now

    In the pack's defaults, a High conflict with no control is reported to the risk owner and the line manager within 2 working days, with an interim measure agreed straight away. Here that might be the provider checking the administrator group membership and logging settings until the full controls are running.

  5. Decision

    Can someone else take over the log review?

    Separation always comes first. A managed security service or the outsourced IT provider may be able to own log review outright, or a second administrator may be joining. With one administrator and no outside party to take the duty, the answer is no. Record the reason, usually headcount.

    In the pack

  6. Outcome

    Move the log review, and confirm the administrator cannot alter logs

    Give the review to the other party, and remove the administrator's rights to change or delete the logs. Confirm it with a fresh access listing. The conflict is then closed and needs no exception.

    In the pack

  7. Step

    Forward logs to a store the administrator can only read

    Send the logs to a central or cloud log service where the administrator has read-only rights. Misuse can then no longer be erased from the record. The alerts and the monthly review both read from this store.

    In the pack

  8. Step

    Alert someone else when admin groups change or logging stops

    Set alerts on changes to administrator groups, on audit settings changing, on logs being cleared and on logging stopping. Send them to someone other than the administrator, such as the IT provider and the managing director, where the administrator cannot switch them off.

    In the pack

  9. Step

    Have someone else review admin activity every month

    In the pack's example, the IT provider reviews a summary of administrator activity monthly. The reviewer pulls the report from the log service themselves, covers everything since the last review, signs and dates it, and follows up anything unexplained. Where the system allows, grant administrator rights for a limited time rather than permanently, so each use shows up.

    In the pack

  10. Decision

    Did a test alert reach every recipient?

    Trigger a harmless test, such as a change to a test administrator group, and confirm each recipient received it. An untested control is listed on the exception request but does not lower its score. If the test did not reach everyone, fix the rule and test again.

    In the pack

  11. Step

    Fix the alert rule and test again

    Check the rule, the recipients' addresses and that the administrator cannot silence it. Keep the test record: it is part of the control's evidence, with the rule's configuration and the alert history.

    In the pack

  12. Decision

    Does the administrator also hold the security role?

    In a small company the only IT person often also acts as information security, and so would assess and approve an exception for their own conflict. Nobody may decide an exception they requested or whose control they operate. If you are unsure whether they would be involved in the decision, answer yes.

    In the pack

  13. Step

    Name someone else to assess and approve it

    The decision passes to the next level up. In the pack's example, the standard names the managing director to approve in place of the administrator acting as information security, and the IT provider acts as information security at each review.

    In the pack

  14. Step

    Raise the exception, scored with the tested controls

    The conflict rating and the exception's score are different things. In the pack's example the conflict is High, but the exception scores Medium: severe impact, with likelihood lowered one step by the tested controls. In the pack's defaults a Medium exception is decided by the head of information security, or whoever stands in for them, for up to 180 days. Record it in your exception register with its review date.

    In the pack

  15. Decision

    At the quarterly review, did the checks run and find nothing odd?

    Each quarter, whoever acts as information security, here the provider, confirms that the alerts still fire and that every monthly review happened, done by someone other than the administrator. A missed month or a review the administrator prepared is a failed control. Anything unexplained in the activity summary is a separate answer.

    In the pack

  16. Outcome

    Failed control: re-score without it and tell the risk owner

    Score the exception again at once without the failed control. Without it the likelihood is not lowered, so the band and approver may rise. Report the conflict to the risk owner, and restore the control before the next review.

  17. Outcome

    Handle signs of misuse through the incident route

    Unexplained administrator activity, missing logs or logging that stopped without a reason may mean the conflict has been misused. Raise it under your incident procedure and, where money or fraud may be involved, your fraud or whistleblowing route. Do not ask the administrator to investigate their own activity.

  18. Decision

    Could the log review now be moved to someone else?

    Ask at every review. A second hire, a managed security service or a new feature in the log service may make separation possible. If so, separate it and close the exception.

    In the pack

  19. Outcome

    Covered and checked: renew the exception at expiry

    Record the review and the next date in your register. At expiry the exception is scored again and renewed, and once its renewals run out it goes to the next approval level up. Management should see, at least once a year, that this duty is combined and how it is watched.

    In the pack

Practical checklist

  1. Record the conflict as High. If nobody else sees administrator activity today, tell the risk owner and line manager and agree a stopgap.
  2. Move the log review to another party if one can take it, and remove the administrator's rights to alter the logs.
  3. Otherwise forward the logs to a store where the administrator has read-only rights.
  4. Send alerts on administrator group changes, audit setting changes, cleared logs and stopped logging to someone other than the administrator.
  5. Have someone else review a monthly summary of administrator activity they pull themselves, signed and dated.
  6. Trigger a test alert and confirm every recipient received it before raising the exception.
  7. Raise the exception, with someone other than the administrator assessing and approving it.
  8. Each quarter, confirm the alerts still fire and every monthly review happened, and ask whether separation is now possible.

Evidence to have ready

  • The log store's access settings, showing the administrator has read-only rights.
  • The alert rule configuration, the test alert record and the alert history.
  • The signed and dated monthly activity reviews, with notes of any follow-up.
  • The approved exception with its score, approver and expiry, and the quarterly review records.

Assumptions

  • The organisation has one person with full administrator rights, including control of the logging system, and at least one other person, such as a director or an outsourced IT provider, who can receive alerts and read reports.
  • Review frequencies, deadlines and approval levels shown are the defaults in the CISO Times exceptions pack. Your own standard may set different ones.

Not covered here