How to Implement ISO 27001 Annex A 8.2 Privileged Access Rights

Implementing ISO 27001 Annex A 8.2 is the rigorous restriction of Privileged Access Rights to ensure that administrative capabilities are only granted to authorised users for specific tasks. This control mandates the technical enforcement of Multi-Factor Authentication (MFA), the separation of standard and admin accounts, and the use of Just-In-Time (JIT) access to prevent lateral movement and privilege escalation attacks.

ISO 27001 Annex A Privileged Access Rights Implementation Checklist

Use this implementation checklist to achieve compliance with ISO 27001 Annex A 8.2 by enforcing strict technical controls over administrative accounts rather than relying on paper policies. Privileged access is the primary vector for ransomware lateral movement; therefore, compliance requires granular restrictions in Active Directory, PAM solutions, and server configurations.

1. Separate Standard and Administrative Accounts

Control Requirement: Users must not use privileged accounts for day-to-day activities. Required Implementation Step: Open Active Directory Users and Computers (ADUC). Create separate accounts for IT staff (e.g., `adm-jbloggs`) specifically for administrative tasks. Enforce a technical policy that blocks their standard email/web-browsing account (`jbloggs`) from having any local admin or server rights.

Minimum Requirement: Zero users possess “Domain Admin” rights on their primary “daily driver” accounts.

2. Implement Just-In-Time (JIT) Access

Control Requirement: Privileged access rights should be restricted to the time duration necessary for the activity. Required Implementation Step: Deploy a Privileged Access Management (PAM) solution or configure Azure AD Privileged Identity Management (PIM). Configure the system so that “Standing Access” is removed; administrators must request elevation for a specific window (e.g., 4 hours), requiring a ticket number and MFA verification to activate.

Minimum Requirement: Administrators have zero rights by default and must actively “check out” privileges.

3. Hardening Service Account Permissions

Control Requirement: Non-human privileged accounts must be restricted to their specific function. Required Implementation Step: Audit all Service Accounts using `Get-ADServiceAccount`. Configure “Log on To” restrictions to limit them to specific servers. Open Local Security Policy (`secpol.msc`) on target servers and grant “Log on as a service” rights, while explicitly denying “Log on locally” and “Log on through Remote Desktop Services”.

Minimum Requirement: Service accounts are technically incapable of interactive desktop logins.

4. Enforce Phishing-Resistant MFA for Admins

Control Requirement: Strong authentication is mandatory for privileged access. Required Implementation Step: Configure your Identity Provider’s Conditional Access policies. Create a rule that targets all roles with administrative privileges (Global Admin, Privileged Auth Admin) and enforce “Require Phishing-Resistant MFA” (e.g., FIDO2 security keys or Windows Hello for Business). SMS and standard push notifications are insufficient for this tier.

Minimum Requirement: Administrative logins are blocked unless a hardware token or biometric factor is present.

5. Establish a “Break Glass” Emergency Protocol

Control Requirement: A process must exist for emergency access when standard authentication fails. Required Implementation Step: Create two highly complex cloud-only administrative accounts excluded from MFA and Conditional Access policies (to prevent lockout during IdP outages). Write the credentials on paper, seal them in tamper-evident envelopes, and store them in a fireproof safe. Monitor these accounts for any logon activity; if they are used, it triggers a critical alert.

Minimum Requirement: Physical offline storage of emergency credentials that leaves forensic evidence (broken seal) if accessed.

6. Audit and Purge the “Domain Admins” Group

Control Requirement: The number of privileged accounts must be kept to an absolute minimum. Required Implementation Step: Export the member list of the “Domain Admins” and “Enterprise Admins” groups. Verify every single member. If the count exceeds 5 users (for a mid-sized org), immediately remove unnecessary accounts. Replace broad Domain Admin rights with delegated permissions (e.g., “Reset Password” rights on a specific OU) using the Delegation of Control Wizard.

Minimum Requirement: “Domain Admins” membership is restricted to less than 1% of the total IT staff.

7. Restrict Local Administrator Assignment

Control Requirement: Local administrative rights on endpoints must be controlled. Required Implementation Step: Use Microsoft Intune or Group Policy Preferences to wipe the local “Administrators” group on all workstations. Add a specific LAPS (Local Administrator Password Solution) account for support usage. Technically block users from making themselves local admins to install unapproved software.

Minimum Requirement: Standard users cannot install software or change system settings on their corporate laptops.

8. Implement Privileged Access Workstations (PAWs)

Control Requirement: The environment used to administer systems must be secure. Required Implementation Step: Designate specific, hardened laptops or virtual machines solely for high-risk administrative tasks. Block internet access, email, and productivity apps on these PAWs. Configure firewalls on critical servers to accept management traffic (RDP/SSH) only from the IP addresses of these PAWs.

Minimum Requirement: Tier 0 assets (Domain Controllers) are never managed from a standard user workstation.

9. Define Specific Lifecycle Procedures for Privileged Users

Control Requirement: Processes for registration and de-registration of privileged rights must be formalised. Required Implementation Step: Create a specific workflow in your ITSM (e.g., Jira/ServiceNow) for “Admin Rights Request”. This workflow must require approval from the Information Security Manager and the Asset Owner. Automate the provisioning so that rights are granted only after the ticket is fully approved, and set an automatic expiry date for the rights.

Minimum Requirement: No admin rights are granted based on verbal requests or Slack messages; an audit trail is mandatory.

10. Review Privileged Access Logs Weekly

Control Requirement: Use of privileged access rights must be reviewed at regular intervals. Required Implementation Step: Configure your SIEM or log aggregator to flag specific Event IDs (e.g., Windows Security Log Event 4672 “Special privileges assigned to new logon”). Schedule a mandatory weekly review where the Security Lead validates that every flagged privileged session corresponds to an approved Change Request or Incident Ticket.

Minimum Requirement: Uncorrelated privileged sessions (admin activity without a ticket) are treated as security incidents.

ISO 27001 Annex A 8.2 SaaS / GRC Platform Implementation Failure Checklist

Comparison of SaaS Compliance Claims vs. Real-World Privileged Access Security

Control Requirement	The ‘Checkbox Compliance’ Trap	The Reality Check
Segregation of Duties	GRC tool asks: “Do you separate admin accounts?” (Yes/No toggle).	Fails if the “Admin” account is just the user’s name added to the sudoers file. True compliance requires two distinct identities.
MFA for Admins	SaaS platform checks “MFA Enabled” setting in the dashboard.	Fails if SMS is used. SIM swapping makes SMS MFA insecure for admins. Auditors demand hardware keys or FIDO2 for privileged tiers.
Service Accounts	Tool ignores non-human accounts entirely.	Fails if a backup service account has “Domain Admin” rights and a non-expiring password, creating a massive backdoor.
Access Reviews	Automated email sent to managers: “Keep access?” (They click Yes to all).	Fails if managers rubber-stamp the list. Real compliance involves a forensic check of usage: “Why does Bob have Admin if he hasn’t used it in 6 months?”
Emergency Access	Document mentions a “Break Glass” procedure.	Fails if the password is stored in a password manager that requires MFA (which is broken in the emergency). Physical safes are required.
Local Admin Rights	Tool checks for a policy document.	Fails if developers have local admin “because they need it”. This is the #1 cause of malware infection. LAPS is the only technical answer.
Just-In-Time Access	Not supported by basic GRC questionnaires.	Fails if 20 admins have 24/7 standing access. If an admin gets phished at 3 AM, the attacker wins. JIT prevents this.

About the author