Millicent,
IAM is huge, and I'm not sure of your detailed scope. Here are some quick thoughts. I assumed your scope is not PAM.
- You have many different types of users (students, staff, faculty, alumni, emeritus, external researchers/participants, potential students, etc.). You may need to break it down according to the type of user. Normally, requirements and processes differ a lot....
- Central IAM process versus Distributed IT IAM. What is your scope and coverage of IAM within the institution?
- AD group management. AD groups are usually key in IAM.
- Azure/Entra AD Integration
- Link to good practices (CIS Access control 6.1-6.8, Cobit, NIST CSF PR.AA)
- Ensure you cover the specific legal access control requirements: 800-171 (3.1, 3.3, etc.), GLBA, FERPA, and the new proposed HIPAA access controls as applicable
- Make sure you assess the IAM program. Usually, the root cause.
Let me know if you have any questions.
This is a fun audit with a lot of value.
See you all in Oklahoma City on March 9th. I will cover Access control as part of my CMMC session.
Johan Lidros CISA, CISM, CGEIT, CRISC, CDPSE, HITRUST CCSFP, ITIL-F
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Johan Lidros | President | Eminere Group LLC
(813) 832-6672 |
johan.lidros@emineregroup.com------------------------------