Access control encompasses a broad range of concepts and practices that can vary significantly depending on an organization’s industry, risk appetite, and compliance requirements. This blog focuses specifically on the post-implementation phase of access control. It discusses the critical questions: “Once access controls are in place, how do you make sure they remain effective? What does ongoing maintenance entail?”
What is Access Control?
The primary purpose of access controls is to restrict, monitor, and review user access across systems, applications, and the physical environment. This includes managing the types of access granted, for example, through the use of Role-Based Access Control (RBAC), and the methods used by users to authenticate into systems, such as identity access management (IAM). These controls are foundational to safeguarding data and system integrity, and they often intersect with compliance requirements, such as those often included in the scope of a SOC 2.
Access Controls vs. SOC 2 Controls
While SOC 2 access controls are scoped to the systems and services included in the audit, organizations may have additional access control practices that extend beyond the boundaries of the report. These broader controls may be critical for internal risk management, operational oversight, or industry-specific needs, even if they are not formally evaluated in a SOC 2 audit. Additionally, a SOC 2 report considers controls outside of access (change management, incident management, endpoint protection, etc.). Maintaining access controls involves more than just meeting compliance, it’s about continuous alignment with business objectives and emerging threats.
Access Control Maintenance through Policies, Role Review, & Activity Logging
As people change in the organization, a policy maintains the continuity of a process. When developing process documentation or control narratives, it is essential to establish a structured routine for regularly reviewing and updating access control policies. It is also important to keep the policy document in a familiar place where everyone can access it. These reviews determine that policies remain accurate, relevant, and aligned with evolving organizational needs and security requirements. Effective access control policies should comprehensively address:
- Maintenance of access controls, which include role matrices and segregation of duties to limit conflicts of interest
- IT Example: Users who provision access should not be able to approve or review that access.
- Finance Example: Users who set up and modify vendor information should not have the ability to process invoices.
- Data classification standards that identify what roles are authorized to access, modify, or delete sensitive information
- Example: Only administrative users of the system are allowed to delete sensitive data.
- Documentation requirements that cover the full lifecycle of access provisioning, modification, and deprovisioning
- Example: Access requests must be tracked in the ticketing system.
User access reviews revisit the appropriateness of access and offer the opportunity to realign roles and responsibilities. These reviews help validate that only authorized individuals have access to systems, networks, physical locations, and infrastructure components. The frequency of these reviews should be determined by management based on the sensitivity and risk level of the system, as well as the volume and volatility of user accounts. Reviews may be performed manually, by extracting and evaluating users’ names and their associated role(s), or through automated tools that streamline the process. After an appropriate user has reviewed the listing, be sure to document and follow up on requested access modifications.
Logging and monitoring user activity provides a trail to follow during investigations. Monitoring user access activity is a key component of detective controls. Logging both successful and failed access attempts enables security teams to investigate anomalies and support forensic analysis when suspicious activity occurs. For high-risk or privileged accounts, enhanced safeguards such as credential vaulting and session recording should be implemented to maintain oversight and accountability.
Access Control Maintenance Through Process Enhancements
Opportunities exist to strengthen access controls by automating segregation of duties (SoD) within key areas of the environment. For example, tools such as code repositories can be configured to systematically enforce role separation within the change management lifecycle. These enhancements help reduce the likelihood of fraud and human error by preventing the occurrence that a single individual could have end-to-end control over the change management process from developing a change to pushing it to production.
In addition to refining user roles and permissions, there is potential to improve authentication configurations to further secure system access. Organizations should assess whether the current sign-on process could be enhanced by implementing advanced authentication mechanisms, such as:
- Multi-Factor Authentication (MFA) for an added layer of identity verification
- Single Sign-On (SSO) to streamline and centralize access management
- Biometric Authentication to provide secure and user-friendly identity verification
Control Maintenance Through Training & Education
Educating users on secure access behavior is a foundational element of an effective access control strategy. Trainings can be tailored to align with departments or with roles (general users vs. managers and above) by delivering specific content that illustrates how their actions impact the security of systems and data.
For instance, employees and contractors should be trained on best practices for safeguarding credentials, recognizing phishing attempts, and adhering to acceptable use policies. More critically, managers and supervisors who are responsible for access approvals should receive targeted training on evaluating requests based on legitimate business needs and aligning permissions with defined job responsibilities. This helps prevent overprovisioning and supports the principle of least privilege.
Ongoing training and reinforcement build a strong security culture, and by incorporating interactive sessions, real-world examples, and regular refreshers, the training can further strengthen users’ ability to make informed and secure access decisions.
Vulnerabilities When Access Control is Not Maintained
As environments are continuously changing, there is always a risk of broken access control. Broken access control is a vulnerability that occurs when an application or system fails to enforce restrictions on what authenticated and unauthenticated users are authorized to do. This flaw allows users to access or modify data, systems, or functions beyond what they were allowed to perform. Common examples include accessing another user’s records by changing URL parameters, allowing access from unauthorized/untrusted origins, or not adhering to the deny by default principle.
These weaknesses can lead to serious consequences such as unauthorized exposure of sensitive information, unauthorized changes to data, or even the full system being compromised. For instance, if a regular user can access administrative functions by navigating to hidden endpoints or tampering with their session, it can result in a breach of security, confidentiality, and integrity. Broken access control is so common that it ranks as the number one risk in the OWASP Top 10 list.
Benefits When Access Control is Maintained
Properly maintained access control significantly strengthens an organization’s security posture by establishing processes that support only authorized individuals having the ability to access specific systems, data, and physical resources. By enforcing principles like least privilege and segregation of duties, access controls reduce the likelihood of unauthorized access, data breaches, and insider threats. Regular access reviews help identify outdated or excessive permissions, closing potential security gaps before they can be exploited.
From a compliance standpoint, effective access control supports adherence to compliance standards such as SOC 2, ISO 27001, HIPAA, GDPR, etc. Audit trails and user activity logs provide the necessary evidence by helping organizations investigate potential issues. Also, by implementing documented processes for access provisioning, deprovisioning, and review, organizations can achieve both operational efficiency and consistency of security policies.
Robust access controls promote accountability and transparency. When access is managed and monitored, users are more aware of their responsibilities and are more likely to follow security best practices. This fosters a culture of security awareness but also provides visibility into system usage, enabling faster detection and response to suspicious behavior or policy violations.
Next Steps for Effective Access Control Maintenance
Hopefully, this blog has helped increase your understanding of access control maintenance and how access controls can strengthen the security of your environment. Maintaining access controls isn’t a one-time task, it’s an ongoing, collective effort that requires commitment to maintain policies and processes, educate personnel, and enhance technologies.
If you are interested in learning more information about access control or would like assistance with an upcoming SOC report or HIPAA audit, please contact us and request a consultation.
Hilary has eight years of IT audit and assurance experience. Prior to starting at Linford & Co, Hilary worked for Deloitte managing audit readiness assessments, Sarbanes-Oxley 404 and SOC examinations, and complex remediation procedures. Hilary is a certified information systems auditor (CISA), holds a Master’s Degree in Accounting from the University of Colorado-Denver and a Bachelor’s in Business Administration from Colorado State University.