04 – Privileged Access Management (PAM) Policy

04 – Privileged Access Management (PAM) Policy

Prepared by: [Name ----------------]
Organization: [company name]

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1. Purpose

This policy establishes strict controls for the management of privileged accounts, ensuring elevated access is granted only, when necessary, monitored continuously, and revoked promptly. It enforces compliance with CMMC AC. L2‑3.1.4 and AC. L2‑3.1.7, while supporting secure, resilient, and compliant operations across cloud, hybrid, and on‑premises environments.

2. Scope

This policy applies to:

• All privileged accounts (e.g., Administrators, Security Admins, Compliance Admins, System Owners).
• All systems processing or storing Controlled Unclassified Information (CUI).
• All administrative workstations and remote privileged sessions conducted by authorized personnel.

3. Roles & Responsibilities

• Policy Owner: Oversees privileged access workflows, ensures audit readiness, and reports compliance status to leadership.
• IT Security Team: Configure Privileged Identity Management (PIM) or equivalent, enforce separation of duties, monitor privileged sessions, and remediate anomalies.
• System Owners: Approve privileged access requests for their systems and validate business justification.
• Managers: Validate elevated access requests based on role necessity and operational requirements.
• Privileged Users: Use admin accounts only for approved tasks and comply with session monitoring requirements.

4. Policy Statements

• Privileged accounts must be explicitly defined and documented in the compliance repository.
• Separation of duties must be enforced to prevent conflicts of interest.
• Privileged sessions must be conducted from Privileged Access Workstations (PAWs) or secure environments.
• Just‑In‑Time (JIT) and Just‑Enough‑Access (JEA) must be used for elevated access.
• Privileged access must be approved through a documented workflow with manager and system owner sign‑off.
• Privileged sessions must be logged, monitored, and reviewed quarterly.

5. Privileged Session Requirements

• Privileged access must be requested via PIM activation or equivalent workflow.
• Sessions must be time‑bound and automatically revoked after expiration.
• Administrative tasks must not be performed from non‑compliant devices.
• Remote privileged commands must use encrypted channels (TLS 1.2+ or higher).

6. Enforcement

• Privileged Identity Management (PIM or equivalent): JIT access, approval workflows, session monitoring.
• IAM Identity Protection: Detect risky sign‑ins and enforce MFA.
• Endpoint/Identity Monitoring Tools: Track privileged account activity.
• Conditional Access / IAM Policies: Restrict privileged access to compliant devices and approved networks.

7. Monitoring

• Privileged access alerts must be generated for unusual activity.
• Quarterly review of privileged user lists conducted by compliance and IT security teams.
• Automated detection of dormant privileged accounts with remediation documented in the compliance repository.

8. References

• CMMC AC. L2‑3.1.4, AC. L2‑3.1.7
• NIST SP 800‑171 Rev. 2
• DFARS 252.204‑7012
• Vendor technical reference guides (Microsoft, Google, AWS, etc.)

9. SSP, SOP, and Evidence Mapping

• SSP Mapping: Directly maps to CMMC AC. L2‑3.1.4 and AC. L2‑3.1.7 under Privileged Access Controls.
• SOP Mapping: Supporting SOPs include Privileged Access Request SOP, Privileged Session SOP, and Privileged Account Review SOP.
• Evidence Required:
  • Privileged user list maintained in compliance repository.
  • PIM activation logs showing elevated access requests and approvals.
  • JIT/JEA access records.
  • Privileged access alerts and remediation logs.
  • Quarterly privileged account review reports signed by compliance leadership.

End of Policy – AC 04
Date Created: [  /  /   ]