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ITSP.10.17198
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98 controls

03.01.04Separation of dutiesITSP.10.171Access control

Official Requirement

A. Identify the duties of individuals requiring separation. B. Define system access authorizations to support separation of duties.

Source: Canadian Centre for Cyber Security ITSP.10.171 (2025), adapted from NIST SP 800-171 Rev. 3

In Plain English

Your organization must ensure that no single person can perform all steps of a critical process alone. For example, the person who approves access should not be the same person who provisions it, and the person who writes code should not be the one who deploys it to production. This reduces the risk of fraud and errors.

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The Trust Services Criteria referenced in this tool are published by the American Institute of Certified Public Accountants (AICPA) and incorporate principles from the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Criteria descriptions are reproduced for reference purposes. All implementation guidance, evidence recommendations, and control language are original work by Truvo Cyber. ISO 27001 and ISO 42001 are standards published by the International Organization for Standardization (ISO). Framework and standard names are the property of their respective owners. This tool is not affiliated with, endorsed by, or certified by AICPA, COSO, or ISO.

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On-premises implementation and evidence

Separation of duties enforcement

Implementation steps

  1. Create a separation of duties matrix listing incompatible roles and functions
  2. Configure Active Directory groups so that users cannot hold conflicting administrative roles simultaneously
  3. Implement dual-approval workflows for critical changes (e.g., firewall rule changes, privileged account creation)
  4. Review role assignments quarterly against the separation of duties matrix and document any exceptions with compensating controls

Tools / systems

Evidence artifacts

Evidence frequency: Quarterly role review; annual separation of duties matrix update