Controls Intelligence in the Greater Whole

I was talking to a long time competitor/colleague/client/friend this week about identity governance and a variety of other identity topics. We were commenting that in some regards access certification and access policies have been stuck in bubble of amber: not a lot of innovation save the addition of some cluster analysis (marketed as AI.) In the course of the conversation I remember that a long time ago I had written a piece on the use of negative policy spaces for access governance. My buddy thought it would be fun to dig it up a repost it. So of I went to find this…

What’s funny (at least to me) is that what follows is a writing sample I used as part of the interview process to get my first analyst job at Burton Group. And that brought back a lot of memories…

So without further adieu, straight out of 2008, I bring you:

Controls Intelligence in the Greater Whole – Using Negative Authorizations to satisfy Audit Requirements and strengthen Positive Authorization Policies

Executive Summary

Whether conscious of it or not, no enterprise embarks on a controls exercise, be it controls definition, management, monitoring, or rationalization, unless that exercise addresses audit requirements.   Auditors and regulators have defined the backdrop against which a variety of corporate stakeholders must perform an ever-changing array of maneuvers to prove compliance.  Within this context, controls intelligence platforms and processes have developed to directly satisfy audit requirements.  In contrast, identity management technologies and other “compliance” tools are not truly aware of the constraints and requirements that auditors inflict upon organizations and are fundamentally not designed to meet those needs.  This piece will contrast the difference between controls intelligence platforms and their associated negative authorization policies against identity management technologies and their positive authorization policies, illustrating the appropriate use of both in the eyes of the auditors as well as the enterprise.

The Auditors rise to Power

It sometimes seems as if there were no audit regulations before Sarbanes-Oxley, but of course there were.  Various industries had their own set of regulations and subsequent audit requirements to meet.  SOX, however, does not discriminate among industries and with its introduction all manner of enterprise turned to their auditors for guidance.  The power and importance of the external auditor grew significantly; on one side, their clients were asking for guidance and on the other government and regulators were looking for results.  This put auditors in control and control they did; they defined stringent audit requirements and testing procedures.  They design the obstacle course that their clients have had to maneuver year after year.

Being Negative Never Seemed So Good

Simply put, auditors are interested in what people cannot do.  They want to verify that people who can execute out one task cannot execute another task that is in opposition to the first.  For example, an auditor will examine business systems to validate that the collection of capabilities granted to an inventory clerk does not enable the clerk to see the pay grades of her coworkers, as well as authorize payment for goods she ordered.  Auditors require that the analysis of these collections of capabilities must be executed at the lowest level of the audited system, ensuring that no convoluted permutation of capability components result in conflicts that cannot be detected at higher levels and thus cannot be mitigated.  This analysis of complex systems and processes is expressed using negative authorizations – explicit statements about which capability components are in conflict with others.

Compliance to audit requirements is evidence that the organization has not allowed to transpire what, according to auditors, should not be allowed to happen.  This holds true for both automatable processes and manual ones.  The lack of evidence that the organization required all of its managers to attend sexual harassment training, and thus educated managers appropriately, can be sufficient to run afoul of audit and/or regulatory requirements.  Similarly, evidence that a business system allows the inventory clerk to see her coworkers’ pay grades as well as authorize payment for goods she ordered can be sufficient to violate an audit requirement.  Controls intelligence and controls documentation platforms are designed to discover the existence of such potential violations before the auditor discovers them.  These tools, from a testing and monitoring perspective, utilize negative authorizations to discover, on an on-going as well as episodic basis, potential violations in both manual and automatable processes.

The Downside of being Positive

Identity Management technologies deal with entitlement: what are people of a certain type allowed to, and subsequently enabled, to do.  This holds true for a variety of identity management technologies including user provisioning, bottom-up and top-down role management, as well as entitlement management.  All of these technologies use a form of an entitlement which groups people together and grants them a collection of capabilities.  The explicit granting nature of these entitlements is a form of positive authorizations.

The primary goal of entitlement-based identity management systems is to realize operational efficiencies by granting and managing people’s granted abilities faster with more automated control and finesse.  A secondary goal is the self-service enablement of users in order to reduce cost.  These tools are invaluable to IT and help reduce the overall cost of supporting the enterprise’s user population.  That being said these tools cannot truly meet the needs of auditors on their own.

Auditors are not ignorant to positive authorization-based systems.  They are well aware these systems help provide access to business systems and at the same time these systems can pollute critical business systems with audit exceptions.  One of the inherent reasons that these positive authorization systems can so easily generate problems is that these systems concern themselves with collections of capabilities at the highest level.  This allows entitlements to be built and managed quickly, helping to realize operational efficiencies, but does not allow for the detailed analysis that auditors require and that negative authorization platforms provide.

Using Negative Authorizations to satisfy Audit Requirements

While the efficiencies gained from positive authorization systems, like user provisioning, are great from a bottom-line perspective, those efficiencies are irrelevant to auditors – they don’t care how quickly an enterprise grants access to business applications.  To satisfy audit requirements, an enterprise must be able to demonstrate how people cannot execute certain tasks, how theirs capabilities are not in conflict and must be able to demonstrate this amongst the tiny pieces that comprise a capability.  To accomplish this, the enterprise must rely on negative authorizations and the depth of analysis that controls intelligence platforms provide.

Unaware of their choice, many enterprises choose to codify and modify negative authorizations through manual efforts.  They employ brute force spreadsheet-based analysis of both manual processes and business systems to demonstrate that they have an enforced, auditable collection of negative authorization policies.  Effective to a point and costly to an extreme, these efforts have been tolerably sufficient in the past but with changes to auditor guidance, such as  AS5, and financial and competitive pressures, enterprises are turning to automated solutions, eschewing these manual efforts.  Enterprises that chose controls intelligence platforms, those who automate controls management and monitoring, find benefits in reduced audit preparation costs, easier more predictable audits, and stronger deployments of their positive authorization systems.

Harmonizing of Negative and Positive Authorizations

As previously mentioned, positive authorization systems, like identity management technologies, provide a conduit along which potential exceptions and audit findings travel straight into business systems.  In order to intercept these potential audit exceptions and, in turn, meet audit requirements, enterprises must examine their positive authorization-based policies through the filter of negative authorizations.

There are two key points at which controls intelligence, negative authorizations, can filter positive authorization-based identity management technologies: runtime and design-time.  At runtime, proposed account changes, generated by user provisioning systems, derived from positive authorization-based entitlements, pass through the filter of a controls intelligence platform.  This negative authorization filter highlights potential exceptions that exist in the proposed account change and does so by using the language that the auditors speak at a level of detail that the auditors expect.  This process, known as compliant provisioning, provides a safety-net for critical business applications, preventing potential audit findings from finding their way into the business applications in the first place.

Although compliant provisioning is a highly effective method of preventing potential exceptions, design-time application of negative authorization filters is a superior long term approach.  This approach not only reduces potential audit exceptions, but also increases the value of enterprise identity management deployments.  Design-time application of negative authorizations works as follows: as entitlements are developed in positive authorization systems, they are passed through the filter of a controls intelligence platform.  The negative authorization analysis of these entitlements, episodically and/or continually, highlight flaws in these entitlements and help organizations prevent these “bad” entitlements from generating fundamentally flawed role definitions, provisioning policies and account changes, and access entitlements.  Further, by relying on the filter of negative authorizations at design-time, organizations can avoid costly and time consuming entitlement exercises in which subject matter experts on critical business systems attempt to translate what they know an auditor wants to see (negative authorizations) into convoluted positive authorizations.

Both the runtime and design-time approaches harmonize positive and negative authorizations.  This harmonizing of satisfies audit requirements for complete, detailed negative authorization analysis and reduces potential audit findings.  It also retains all of the operational benefits of identity management systems, reduces the cost of deploying these systems, and increases their time to value.

Recommendations

To satisfy both internal and external audit requirements, the enterprise must consolidate and rationalize its negative authorization policy stores.  This includes transitioning from manual-effort analysis and disjoint controls documentation to continuous, automated controls testing whose results flow into a consolidated controls documentation platform.  These efforts reduce enterprise risk and audit exposure and serves to directly meet audit requirements.

Meanwhile, the enterprise should continue deploying identity management technologies and their positive authorizations in order to realize operational gains.  That being said, the enterprise should not attempt to make these positive authorizations behave like negative authorization systems as the effort will be time consuming, costly, and fundamentally will not meet audit requirements.  

Finally, the enterprise should tie their negative authorizations to their positive authorization systems.  At the minimum the enterprise should deploy compliant provisioning, passing entitlement generated account changes through the filter of a controls intelligence platform for negative authorization analysis.  Ideally, during creation and on-going maintenance, identity management entitlements, in their various forms, should be examined through negative authorization filters weeding out potential audit findings long before they can find their way into business applications.

By using negative authorizations and thus gaining control intelligence, the enterprise can speak the language of the auditor and rise to the challenge of an ever-changing set of audit requirements.  By using negative and positive authorization in harmony, the enterprise can realize operational efficiencies without an increased risk of potential audit findings.

Thinking about Matt’s Simple Question: Correlating accounts and people

Matt Hamlin, over at Sun, mentioned a conversation we had last week about a topic in identity management which doesn’t usually get a lot of airtime: the correlation of accounts to people.  The exercise is the first step in answering Matt’s simple question of “Who has access to what?”  Matt writes:

This step is the foundation for Access Certification, Role Mining, Entitlements Management, Policy Evaluation, Identity Auditing, and numerous other custom services developed by our customers.

There were two major omissions in his list: password management and user provisioning.  The reality is the correlating of accounts to people is a requirement for all identity management exercises.  This correlation isn’t glamorous work and isn’t a one time affair.  None the less, it is crucial “Identity Gold” for identity management projects, but also as the foundation for risk mitigation exercises as well.

Here’s a tip to enterprises out there – ask your software vendors and deployment teams what capabilities they have to help facilitate this correlation.  Ask early and before you start down the path of an identity project.  Make it an on-going process governed by your overall identity management program.

I’ll be touching on this a bit in an upcoming Telebriefing I am doing.  On October 1st and 2nd, I’ll be giving a sneak peak of my research on access certification and will cover this and other topics.  If you are a Burton Group subscriber, you should check it out.  If you aren’t a BG customer, you should become one.  😉