Security & Compliance

  • 12 min read

How User Access Reviews Help Adhere To SOX Compliance

Chinmay Panda

8th February, 2024

SHARE ON:

The Sarbanes-Oxley Act, also widely referred to as SOX. It is a regulatory standard that aims to safeguard investors against fraudulent financial reporting by corporations. 

However, meeting this compliance can be challenging without an appropriate solution. But by opting for a solution that offers user access review functionality can help adhere to this compliance standard. In this article, we’ll learn how user access review helps meet SoX compliance seamlessly.

Ensuring compliance holds the utmost importance for most organizations. Other than safeguarding an organization's valuable data, adhering to compliance helps protect against potential fines/penalties, legal actions, and the mishandling of data. However, the cost of not complying with regulations can be substantial, depending on the industry and organization size.

But the ultimate question arises is where should one possibly start in order to meet compliance? Well, to begin, your IT team needs to understand the key aspects involved in managing access rights in accordance to SOX; this way, it will become much easier for them to adhere to SOX compliance. 

So, managing access rights under SOX includes the following: 

• Monitoring access rights during the onboarding of new employees, as existing employees transition to new roles, and when their tenure comes to an end, and they depart from the organization.

• Enforcing Segregation of Duties (SoD) protocols to prevent conflicts of interest.

• Establishing and maintaining an access control matrix to clearly define authorization levels.

• Conducting regular access audits to ensure compliance and security.

Now, your IT team just needs to keep these points as their primary focus, which will significantly streamline the process of achieving the SOX compliance standard. So, let's proceed further and dive into detail on how to effectively meet SOX compliance.

How Is SOX Compliance Met?

Though adhering to SOX compliance can be a little difficult, but your IT team can streamline the process of meeting these regulatory standards by emphasizing on monitoring, logging, and auditing the following areas: Internal controls, network activity, database activity, login activity (both successful and failed attempts), account activity, user activity, information access. 

In short, all of these aspects revolve around user access within organizations. This access holds pivotal significance, not only for compliance but for data security as well. 

A single mismanaged access point can create a gap for unauthorized users or hackers to infiltrate a considerably larger system filled with highly-valued assets and data. As outlined above, neglecting to manage, control, monitor, and audit access could expose an organization to compliance penalties and a major security breach.

Now that you know your IT team needs to emphasize on user access, let's see how an automated IGA's user access review functionality helps your team control, manage, and govern user access.   

How Does User Access Review Help Achieve SOX Compliance?

User access reviews play a pivotal role in addressing the visibility gaps that organizations may encounter concerning their user access landscape. With an automated IGA solution, your IT team can conduct user access reviews and gain complete insights into who is accessing what, what level of access they have, and whether they have valid reasons for access rights. 

This is a very crucial step to perform because if your team is not aware of who is able to access what, they will further face difficulty in setting proper access policies and enforcing access control. 

Furthermore, when it comes to meeting SOX compliance, user access reviews fulfill the crucial functions of monitoring, auditing, and logging access activities. Also, from a cybersecurity point of view, such reviews act as a proactive measure to prevent potential breaches. 

Such as conducting user access reviews helps mitigate insider threats, including instances of privilege abuse, access creep, or gaps in termination procedures. Moreover, they highlight anomalies that might indicate unauthorized user/bad actor movement within a system. 

Apart from that, user access reviews also function as a safety net, ensuring that the access controls an organization has put in place are operating effectively. However, to effectively manage user access, your IT team also needs to implement certain user access review strategies, so let's find out what these strategies are.   

Best User Access Review Practices For Ensuring SOX Compliance

To effectively adhere to SOX compliance standards, your IT team needs to follow these user access review best practices:

1. Create User Access Review Policies 

Creating user access review policies involves a structured set of guidelines and procedures that your IT team follows to effectively monitor user access rights. By implementing these policies, your team can gather precise and up-to-date information about individuals who are accessing various resources within your organization's systems, networks, data, and applications. 

Also, by enforcing user access policies, your team can ensure appropriate access levels that different users should possess, aligned with their specific job roles and responsibilities.

For instance, a junior accountant might need access to basic financial records for data entry, while a senior financial analyst would require access to more complex financial models and reports. 

By adhering to the user access review policy, the IT team can ensure that the junior accountant doesn't have access to sensitive financial data beyond their job scope and that the senior financial analyst has the necessary access to perform their tasks effectively. 

2. Implement Role-Based Access Controls And Least Privilege Access Principle 

Your IT team can enforce role-based access controls and the least privileged access principle to mitigate the risks associated with breaches, access creep, and other potential insider threats effectively. This approach strategically minimizes the likelihood of any single user being given excessive privileged access.

For example, by implementing RBAC, your IT team can assign users to specific roles, granting them access according to their job functions to reduce the chances of unauthorized users accessing sensitive SaaS app data. And the least privilege principle ensures users have only the minimum access required, to avoid over-provisioning or granting excessive access permissions. 

3. Grant Temporary (For a Specific Time Period) Access 

• Your IT team can implement the practice of granting your employees temporary access to SaaS apps, systems, and data. So, instead of providing permanent access, your IT team can assign temporary access, ensuring that access is granted solely on a necessity basis pertaining to a specific function, task, or predefined time frame. 

• Also, your IT team needs to make sure that the access rights are promptly revoked after the completion of the specific task to mitigate potential security risks. 

• For instance, a marketing team is working on a new product launch. They require access to specific marketing analytics software for a limited time to analyze how the product is performing. 

• By practicing assigning temporary access, your IT team can grant them access exclusively for the duration of the campaign analysis. Once the analysis is complete and the access rights can be promptly revoked by your IT team, minimize security breaches. 

4. Segregate Duties To Avoid Conflict Of Interest 

• To ensure the accurate provisioning and deprovisioning of access privileges, it's crucial to involve relevant teams with distinct responsibilities. For example, there are two critical tasks involved in reviewing user access rights: granting access permissions and evaluating the changes in access permissions.

• By assigning two separate reviewers—one responsible for granting access permissions and another for evaluating the changes in access permissions, by doing so your IT team can create a system of checks and balances. 

• This segregation ensures that no single individual has the authority to both grant and review access, reducing the potential for bias or manipulation. 

5. Have A Single Source Of Trust 

Establishing a centralized, trustworthy source for access review data is pivotal. By bringing down all the user access-related data to a single location, your team can easily determine who is accountable for what and also, with the help of centralized data reviewers, efficiently review user access. This further helps in building zero trust across the organization. 

For instance, large organizations have multiple departments, users, and systems, which makes it quite challenging for IT teams to gather user access data. 

But with an automated IGA solution, your IT team can gain all the user access-related data in a centralized dashboard, and reviewers can effortlessly identify which users have access to specific resources and who is responsible for granting or revoking such access. This comprehensive view enhances the accuracy of access reviews and ensures that user permissions align with their roles and responsibilities.

Now that you are familiar with the user access review strategies, it's time you shift your attention towards considering opting for a modern IGA solution. Because manually managing and governing user access reviews can be challenging to carry out for IT teams, particularly in large companies. 

Although there exists a range of IGA solutions that can automate this process, but one that stands out from the rest is - Zuri. What is Zluri? How does it help your organization to stay compliant with regulatory standards? Here's a quick read-through. 

Zluri: An Access Review Solution That Helps You Stay Compliant With Evolving Regulatory Standards

Is your GRC team facing challenges to effectively meet SOX compliance requirements? If yes, you no longer have to worry, as Zluri, a modern, automated, and autonomous IGA platform, emerges as a solution to mitigate this concerning issue. 

Zluri IGA is designed to simplify the complex task of adhering to SOX compliance for your GRC/IT team. With its wide range of exclusive features, such as automated access certification, auto-remediation, activity and alerts capabilities, and more, your GRC team ensures that your organization meets the stringent requirements set forth by the Sarbanes-Oxley Act. 

From streamlining user access reviews to enhancing data security, Zluri IGA plays a pivotal role in guiding your organization toward regulatory compliance with remarkable efficiency. 

To help you gain more clarity on how Zluri IGA works, let's take an example, an IT admin has permission to "grant, revoke, and modify access" and also has permission to "review the user access." While this might seem efficient in a way, but there is a high chance of manipulation during the decision-making process and the occurrence of conflict of interest. Such situations can jeopardize data security and compliance to an extent that you couldn't even imagine.  

So what Zluri IGA does to prevent such a situation is, it implements segregation of duty (SoD) policy. With this policy in place, your IT team can prohibit a single user from holding both "assigning, modifying, and revoking access" and "reviewing access" roles simultaneously. This prohibition eliminates the possibility of a conflict of interest, where an individual could manipulate decisions, posing a risk to data security. 

Furthermore, whenever an attempt is made to assign conflicting roles to a single user, Zluri's automated system generates alerts and notifications to your IT team. This enables them to take immediate action to resolve the conflict and ensure compliance with SOX requirements.

This example was to just showcase how Zluri's innovative capabilities help your IT team maintain effective control over access and adhere to critical regulations like SOX. However, there is more to it, so let's dive deeper into how Zluri IGA's features help in maintaining data security and achieving SOX compliance seamlessly.

• Discover User Access Data Without Any Hassle With Zluri’s Data Discovery Engine 

The manual process of collecting insights regarding user access to SaaS apps is susceptible to errors and inaccuracies. Moreover, not to mention the repetitive back-and-forth that IT teams go through to cross-check each data point. 

So, this is where Zluri's data discovery engine capability steps in as the solution, providing full visibility into user access data. This advanced feature enables your IT team conduct a thorough analysis of how your organization’s users interact with SaaS apps, data, and critical systems and gather insights based on it, saving your IT team's productive time while ensuring accuracy. 

Furthermore, Zluri utilizes five discovery methods: SSO or IDP, finance systems, direct integrations, browser extensions (optional), and desktop agents (optional). These methods enable IT teams to obtain in-depth insights into user access contexts. 

They can easily identify which user has access to which applications, their login/logout time, whether the user status is active or inactive, which department the user belongs to, the level of access permissions they possess, and more.

Furthermore, with the help of these detailed data points, your IT team can proactively monitor user activities and detect any anomalies or suspicious user behaviors. By identifying potential insider threats early, your IT team can take corrective measures to prevent security breaches, data leaks, and other risks that could impact SOX compliance.

Not only that, it also automates the process of identification of managed, unmanaged, and shadow IT apps. This automation eliminates the need for manual efforts in categorizing SaaS apps and documenting user access information, significantly saving time and resources.

Also, identifying user access data allows your IT team to have a view of who has access to what. This transparency ensures that access is granted based on defined roles and responsibilities, minimizing the risk of unauthorized access or misuse of privileges. In order to meet SOX compliance, this transparency is important to maintain as it helps to prevent potential conflicts of interest and ensure data security. 

• Simplify The Complex Process Of Adhering To Compliance Standards With Zluri’s Access Review Capabilities 

Staying compliant with changing regulatory standards can be a hectic task to maintain for the GRC/IT team. But not with Zluri IGA, it offers remarkable access review capabilities to help your GRC/IT team simplify the process of adhering to SOX compliance. With this feature, your IT team ensures every employee has the right access to the right SaaS apps, data, and system with the right level of access permission at the required time while maintaining data security. 

It conducts periodic access reviews to ensure access rights align with employees' roles and responsibilities and prevent unauthorized access by evaluating access patterns and user behavior. Also, with Zluri, your IT can ensure all the compliance requirements are met and become ready for upcoming audits. 

Not only that, Zluri takes it a step further by offering unique capabilities to help your IT streamline the entire access review. So, let's understand in detail how Zluri's access review capabilities function.   

• Unified Access Review

Zluri's unified access review feature enables your IT team to determine which users have access to particular SaaS apps and data. To gain this insight, Zluri utilizes an access directory that centralizes all user access-related data in one centralized place.

With the valuable data points provided by the access directory, such as what access permissions the user has (admins, users, or others), which department or position they are from, and more, your IT team can thoroughly examine users' access privileges and ensure they align with their designated roles.

Furthermore, to keep the operation running smoothly, Zluri's activity & alerts capabilities come as a great help. This feature provides real-time data on users' recent activities and notifies IT teams about new logins or any suspicious actions attempted by unauthorized users. 

Armed with all these data points, reviewers can quickly make decisions during access reviews, ensuring that the right users continue to have the right access privileges until the end of their tenure. 

• Automated Access Review 

With Zluri, your IT team can automate the entire access review process; they create a certification, select the apps and users you want to review, and the rest of the reviewers will review and update you about the compilation via email. 

So, by automating this process, you get 10 x better results than manual methods and save your IT team's efforts by 70%. Now let's move ahead and see how it works. 

• Once you gain access to contextual data through Zluri's unified access feature, you can create access rules around these insights. For example, if someone is an admin on Salesforce, you can easily set up a review policy specifically tailored to that scenario.

• Next comes the schedule certification feature, where you can create certifications based on the gathered information. This allows you to take action based on the insights you've gained. For instance, you can use data like last login, departments, user status (active or inactive), and more to make informed decisions during the review process, such as whether the user can carry on with the existing access or need any modification.

With Zluri's context-rich insights, your team can proactively take actions that align with the organization's set access management policies. It's a more efficient approach to ensure the right user has the right access, all while keeping your data secure. 

So let's see how you can create an access certification in Zluri:

Your IT/GRC team needs to follow the steps below to automate the access certification process:

Step 1: From Zluri’s main interface, click on the ‘Access Certification’ module.

Step 2: Now select the option ‘create new certification.’ You have to assign a certification name and designate a responsive owner to oversee the review. 

Step 3: Under Set Up Certification, choose the  ‘Application’ option. Proceed further by selecting the desired application for which you want to conduct the review and choose a reviewer (generally, the primary reviewers are the app owners) accountable for reviewing access to that particular application. 

After that, you need to select the fallback owner/reviewer, if the primary reviewer is unavailable, the fallback owner can review the user access (you can select anyone for the fallback reviewer, whom you think is responsible enough). Also, the reviewers will get notified through the mail that they will conduct a review. 

Once you are done selecting the reviewers, you can click on Next. 

Step 4: Select Users for Review, choose the users whom you want to review for the selected application. Once you are done selecting the users click on next. You will be able to view all the information related to the users. Then you need to specify the criteria or parameters such as user department, job title, usage, and more. Now click on update and then click on next.

Note: Select those relevant data points only that you wish your reviewers to see while reviewing the access. By filtering the criteria appropriately, you enable your reviewers to make swift and well-informed decisions, streamlining the review process and ensuring efficiency.

Step 5: Now the Configure Action page will appear, basically, here you have to choose actions. These actions will run post the review. 

There are three actions:

Approved- once reviewers approve the user access, Zluri won't run any action, and the users can continue with their same access without any interruption.

Rejected- when the reviewer declines or doesn’t approve the user access, you have to run a deprovisioning playbook to revoke the access of that application from the user. If the user has access to critical apps then you can request the assigned reviewer to manually deprovision the user access or else Zluri will auto-remediate if it’s not critical access. 

Modify- In this last case; you again need to create a playbook to modify the user access. However, you need to state whether the access permission needs to be upgraded or degraded. 

Step 6: Additionally, you can even schedule the actions by setting up the start date and within what time span you want the review to be completed. 

Step 7: Lastly you can keep track of the automated access review process by clicking on the ‘Review Status’ and view whether the review is still pending, modified, declined, or approved.

Also, you can add multiple applications and follow the same process for each selected application.

Zluri also provides the owner access to a snapshot view of the entire certification process status. Also, they can get an overview of the pending reviews and monitor the status of each app’s review, including their assigned reviewers and their completion status.

You can even send reviewers reminders who are yet to complete their reviews.   

Further to streamline the process for reviewers, Zluri provides reviewers with all the user access data in a single screen, i.e. reviewer screen. For the same screen, reviewers can approve, modify, and decline access by verifying the data, and also they have to add relevant comments on the same.

Now, you will be able to view the entire status of the review process on the chart and once the process is completed and the owner (assigned reviewer of the certification process) is fine with the review. You can click on conclude and it will straight away send the reports to the reviewers' email. 

So, don't wait any longer! Book a demo now and see for yourself how Zluri can help your IT team control, manage, and govern user access effectively while ensuring data security and adhering to evolving compliance standards. 

Also Read: PCI DSS Compliance Checklist for 2023

About the author

Chinmay Panda

Chinmay, an IIM Bangalore alum, leads Product Management at Zluri. Before Zluri, Chinmay has worked in the product team of Media.net, and in engineering roles in Bharat Heavey Electricals Limited & Tata Consultancy Services. He is a technology enthusiast.