If…, then how…
If the only IT administrator also manages the security logs, then how do we control that?
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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.
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureExample 2 — the only IT administrator also manages the security logs
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
- P02-A07 Segregation of Duties Conflict MatrixConflict Catalogue
- P02-A08 SoD Conflict Review & Compensating Control ProcedureEmergency and privileged access
- P02-A08 SoD Conflict Review & Compensating Control ProcedureConflict ratings
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.
- Yes: Can someone else take over the log review?
- No, or not known: Tell the risk owner and agree a stopgap now
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 2 — Rate
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.
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 2 — Rate
- P02-A08 SoD Conflict Review & Compensating Control ProcedureTiming targets
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.
- Yes: Move the log review, and confirm the administrator cannot alter logs
- No: Forward logs to a store the administrator can only read
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 3 — Separate if you can
- P02-A07 Segregation of Duties Conflict MatrixConflict Catalogue
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 3 — Separate if you can
- P02-A03 Exception Lifecycle Operating ProcedureStage 10 — Closure with evidence
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureExample 2 — the only IT administrator also manages the security logs
- P02-A08 SoD Conflict Review & Compensating Control ProcedureSmall organisations — separating duties with few people
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureCompensating control catalogue
- P02-A07 Segregation of Duties Conflict MatrixConflict Catalogue
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureCompensating control catalogue
- P02-A08 SoD Conflict Review & Compensating Control ProcedureEmergency and privileged access
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.
- No, or not known: Fix the alert rule and test again
- Yes: Does the administrator also hold the security role?
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 4 — Mitigate what cannot be separated (rule EX-07)
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.
- Then: Did a test alert reach every recipient? (back to an earlier step)
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureCompensating control catalogue
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.
- Yes, or not known: Name someone else to assess and approve it
- No: Raise the exception, scored with the tested controls
In the pack
- P02-A09 Exception & SoD Responsibility MatrixRole Combinations
- P02-A09 Exception & SoD Responsibility MatrixCombined Roles Check
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureExample 2 — the only IT administrator also manages the security logs
- P02-A02 Security Exception & Waiver StandardApproval authority and maximum duration (rule EX-05)
- P02-A09 Exception & SoD Responsibility MatrixRole Combinations
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureExample 2 — the only IT administrator also manages the security logs
- P02-A08 SoD Conflict Review & Compensating Control ProcedureConflict ratings
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.
- Yes: Could the log review now be moved to someone else?
- No: a check missed or self-run: Failed control: re-score without it and tell the risk owner
- Something unexplained: Handle signs of misuse through the incident route
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 5 — Review
- P02-A08 SoD Conflict Review & Compensating Control ProcedureExample 2 — the only IT administrator also manages the security logs
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.
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 5 — Review
- P02-A08 SoD Conflict Review & Compensating Control ProcedureEscalation
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.
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureEscalation
- P02-A07 Segregation of Duties Conflict MatrixConflict Catalogue
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.
- Yes: separate now: Can someone else take over the log review? (back to an earlier step)
- No: Covered and checked: renew the exception at expiry
In the pack
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 5 — Review
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
- P02-A08 SoD Conflict Review & Compensating Control ProcedureStage 4 — Mitigate what cannot be separated
- P02-A02 Security Exception & Waiver StandardRenewal (rule EX-08)
Practical checklist
- Record the conflict as High. If nobody else sees administrator activity today, tell the risk owner and line manager and agree a stopgap.
- Move the log review to another party if one can take it, and remove the administrator's rights to alter the logs.
- Otherwise forward the logs to a store where the administrator has read-only rights.
- Send alerts on administrator group changes, audit setting changes, cleared logs and stopped logging to someone other than the administrator.
- Have someone else review a monthly summary of administrator activity they pull themselves, signed and dated.
- Trigger a test alert and confirm every recipient received it before raising the exception.
- Raise the exception, with someone other than the administrator assessing and approving it.
- 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
- Separating duties in a small team more generally. That is “How do we separate duties when there are only a few people?”.
- How to review privileged access itself. That is “How do we review privileged and administrator access?”.
- Which cloud audit events must be kept for an investigation. That is “If our cloud audit logs are needed for an investigation, which events must still be there?”.
Related questions
- How do we separate duties when there are only a few people?
- How do we score an exception and set how long it lasts?
- Who approves a Critical exception in an organisation shaped like ours?
- How do we review privileged and administrator access?
- How do we decide whether something is an incident or just an event?
- If our cloud audit logs are needed for an investigation, which events must still be there?