Auditing ISO 27001 Annex A 8.2 Privileged Access Rights is the technical verification of administrative permission restrictions and lifecycle management. The Primary Implementation Requirement demands Multi-Factor Authentication and Just-In-Time access controls, providing the Business Benefit of preventing lateral movement and mitigating high-impact internal or external security breaches.
ISO 27001 Annex A 8.2 Privileged Access Rights Audit Checklist
This technical verification tool is designed for lead auditors to confirm the restriction and management of elevated permissions. Use this checklist to validate compliance with ISO 27001 Annex A 8.2.
1. Privileged Access Allocation Formalisation Verified
Verification Criteria: A documented process exists that defines the specific roles requiring privileged access and the criteria for allocation based on the principle of least privilege.
Required Evidence: Approved Access Control Policy or Privileged Access Management (PAM) procedure document.
Pass/Fail Test: If privileged access is granted without a documented business justification or formal approval record, mark as Non-Compliant.
2. Privileged User Inventory Accuracy Confirmed
Verification Criteria: A current and accurate list of all users with privileged access rights across all systems (OS, Database, SaaS, Network) is maintained.
Required Evidence: Export of users in “Domain Admins,” “Global Admins,” or “Superuser” groups cross-referenced against the HR active employee list.
Pass/Fail Test: If the audit identifies active privileged accounts belonging to terminated employees or unrecognised service accounts, mark as Non-Compliant.
3. Multi-Factor Authentication (MFA) Enforcement Validated
Verification Criteria: All privileged access sessions are protected by robust multi-factor authentication, regardless of whether access is local or remote.
Required Evidence: MFA configuration screenshots for administrative portals (e.g., Azure AD, AWS Console, Google Workspace Admin).
Pass/Fail Test: If any administrative account can log in using only a username and password, mark as Non-Compliant.
4. Separate Administrative Account Usage Verified
Verification Criteria: Personnel with privileged rights use separate, dedicated accounts for administrative tasks, distinct from their standard user accounts used for email and web browsing.
Required Evidence: Sample of admin users showing two distinct UPNs (e.g., john.doe@org.com and admin.john.doe@org.com).
Pass/Fail Test: If administrators perform daily non-privileged tasks (email, document editing) using their privileged account, mark as Non-Compliant.
5. Privileged Access Review Cycle Records Present
Verification Criteria: Management performs a formal review of privileged access rights at high frequency (at least every 90 days) to ensure continued necessity.
Required Evidence: Signed Access Review reports or Jira/ServiceNow tickets showing the review and subsequent revocation of unnecessary rights.
Pass/Fail Test: If the last formal review of privileged users occurred more than 6 months ago, mark as Non-Compliant.
6. Just-In-Time (JIT) Access Implementation Validated
Verification Criteria: For high-risk systems, privileged access is granted on a temporary “Just-In-Time” basis rather than being permanently assigned (Standing Access).
Required Evidence: PIM (Privileged Identity Management) logs or PAM tool reports showing time-bound elevation requests and approvals.
Pass/Fail Test: If all administrators have permanent, 24/7 standing privileged rights to production environments without a JIT mechanism, mark as Non-Compliant.
7. Privileged Session Logging and Monitoring Confirmed
Verification Criteria: All activities performed using privileged access are logged, and alerts are configured for high-risk commands or unauthorised changes.
Required Evidence: SIEM or Audit Log exports showing “Administrative Action” logs and corresponding alert configuration for “Account Added to Admin Group.”
Pass/Fail Test: If privileged actions (e.g., changing firewall rules or deleting backups) are not captured in an immutable audit log, mark as Non-Compliant.
8. Default Password Neutralisation Verified
Verification Criteria: Default administrative passwords for all hardware, software, and appliances are changed immediately upon installation.
Required Evidence: Hardening guides or configuration checklists confirming the change of “admin/password” or “root” defaults.
Pass/Fail Test: If any network appliance or server is found to be accessible via factory-default credentials, mark as Non-Compliant.
9. Shared Account Usage Restrictions Confirmed
Verification Criteria: The use of generic shared administrative accounts (e.g., “Administrator,” “root,” “support”) is prohibited or restricted to emergency “Break Glass” scenarios.
Required Evidence: PAM vault logs showing check-out/check-in of emergency credentials with unique user attribution.
Pass/Fail Test: If multiple individuals share a single administrative password without a system to attribute actions to a specific person, mark as Non-Compliant.
10. Competency and Vetting for Privileged Users Verified
Verification Criteria: Individuals granted privileged access have undergone enhanced background screening and possess the technical competency to manage the systems.
Required Evidence: HR screening records cross-referenced against the privileged user list and relevant technical certifications.
Pass/Fail Test: If unvetted contractors or untrained personnel are found with “Superuser” access to the production environment, mark as Non-Compliant.
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Access Minimisation | Tool records “Yes” because an Admin Policy is uploaded. | Demand the Account Count. If 50% of the workforce are “Admins” in the SaaS tool, the control is a total failure despite the policy. |
| Account Separation | Platform identifies that a user “Has an Admin account”. | Verify Exclusivity. If the user’s admin account is also their primary email login, the separation control is bypassed. |
| MFA Integrity | SaaS API reports “MFA: Enabled” for the tenant. | Check the Exemptions. GRC tools often miss “Conditional Access” policies that exclude specific IP ranges or legacy protocols from MFA. |
| Privileged Logging | Tool confirms “Logging is On” in the cloud console. | Verify Immutability. Can an administrator delete the audit logs that record their own actions? If yes, the log is not evidence. |
| Review Frequency | Platform sets a task to “Review Admins” once a year. | Check the Delta. Privileged rights change weekly; an annual GRC task is “Checkbox Compliance” that ignores 11 months of risk. |
| JIT Access | Tool identifies “PIM” as a feature of the licence. | Demand the Activation History. If the PIM tool exists but is never used (users have standing access), the control is failed. |
| Generic Accounts | GRC tool ignores local “Administrator” accounts on servers. | Inspect Local SAM. Automated tools often only look at Cloud/AD, ignoring the “root” accounts on local hardware appliances. |
About the author
