Safeguard 6.7: Centralize Access Control

Safeguard 6.7 requires you to centralize access control so user and system permissions are administered through a consistent, authoritative mechanism rather than scattered across individual systems. To operationalize it quickly, pick your “source of truth” for identities and roles, integrate key systems into centralized authentication/authorization, and prove it works through change records, access reviews, and exception handling evidence. ¹

Key takeaways:

• Centralization means fewer local accounts, fewer one-off permission models, and one governed way to grant, change, and revoke access. ¹
• Scope is broader than IAM tooling; it includes process, integration coverage, and evidence that access decisions are consistently controlled. ¹
• Your audit success hinges on artifacts: integration inventories, role models, joiner/mover/leaver records, and exception registers. ¹

Centralized access control is a governance requirement disguised as an IAM project. If access is managed differently across SaaS apps, cloud consoles, on-prem directories, databases, and endpoints, you will struggle to answer basic assurance questions: Who has access, why do they have it, who approved it, and when does it expire?

Safeguard 6.7 focuses your program on one operational outcome: consistent control over authentication and authorization decisions across the environment. In practice, this usually means establishing a primary identity provider and directory service, standardizing role-based access patterns, and reducing “local” or ad hoc access administration that bypasses governance. ¹

This page is written for a Compliance Officer, CCO, or GRC lead who needs to translate the safeguard into an implementable control statement, clear ownership, and a repeatable evidence routine. You will find step-by-step execution guidance, an evidence checklist, common audit questions, and a practical execution plan that avoids tool-driven detours while still meeting the safeguard’s intent. ¹

Requirement title (target keyword)

Safeguard 6.7: centralize access control requirement

Regulatory text

Framework requirement (excerpt): “CIS Controls v8 safeguard 6.7 implementation expectation (Centralize Access Control).” ¹

Operator interpretation: You must run access control through centralized mechanisms so access decisions are consistent, reviewable, and enforceable across systems. That includes (a) a defined authoritative identity source, (b) standardized access assignment (roles/groups), (c) reduced reliance on unmanaged local accounts, and (d) documented operation with recurring evidence capture. ¹

What an assessor will look for: proof that access administration is not fragmented. If teams can grant access “locally” in ways that bypass your approvals, provisioning workflow, logging, or termination process, you will have a control gap even if you own good IAM tools. ¹

Plain-English meaning

Centralize access control means you can confidently say: “Access starts in one place, follows one process, and ends in one process.” Users authenticate through a consistent identity layer, and permissions are assigned using defined groups/roles that are administered under governance rather than improvised per system.

A practical definition that works for most programs:

• Centralized authentication: Your primary apps and admin consoles rely on a shared identity provider (SSO/federation where feasible).
• Centralized authorization administration: Access is granted via centrally managed groups/roles (even if enforcement happens inside each target system).
• Centralized lifecycle control: joiner/mover/leaver actions are executed through a controlled workflow, including deprovisioning.
• Centralized oversight: you can review access at the identity layer and reconcile exceptions. ¹

Who it applies to

Entities: Enterprises and technology organizations implementing CIS Controls v8. ¹

Operational contexts where this safeguard matters most:

• Hybrid environments (on-prem directory plus cloud identity plus many SaaS apps)
• High-privilege administration (cloud consoles, security tools, CI/CD, production databases)
• Third-party access (MSPs, contractors, vendors) where unmanaged accounts often persist
• M&A and business unit autonomy where local directories and app-native accounts multiply

Typical owners:

• IAM/Identity engineering for technical implementation
• Security/GRC for control definition, exceptions, and evidence
• IT operations / app owners for application onboarding and local account reduction
• HR (or equivalent system of record) for lifecycle triggers ¹

What you actually need to do (step-by-step)

Step 1: Define your “central authority” for identity and access

Document:

• Your authoritative identity source(s) (workforce identities, privileged identities, service accounts)
• Your standard access assignment mechanism (groups, roles, entitlements)
• Your approved exceptions (systems that cannot integrate yet, emergency access paths)

Output: Access Control Centralization Standard (a short policy/standard that states what “centralized” means in your environment). ¹

Step 2: Build an application and system access inventory (with integration status)

Create an inventory list that includes:

• System name, owner, data sensitivity/criticality
• Authentication method (SSO/federation, directory bind, local accounts)
• Authorization method (roles/groups, local permissions, shared accounts)
• Current gaps and planned remediation path

This inventory becomes your control scope statement and your roadmap. It is also a primary audit artifact. ¹

Step 3: Standardize role/group design

Pick a simple, defensible model:

• Define baseline roles (employee, contractor, admin, break-glass)
• Define privileged access roles separately from standard user roles
• Require ticket/approval mapping for role assignment

Deliverable: Role Catalog with role descriptions, criteria, approvers, and recertification expectations. ¹

Step 4: Onboard systems to centralized authentication first, then tighten authorization

Execution sequence that works in practice:

1. Enable centralized authentication (SSO/federation/directory integration) for high-value systems first.
2. Disable or restrict local authentication paths where feasible (or enforce compensating controls and log monitoring where not feasible).
3. Migrate permissions to centrally managed groups/roles (even if the system still stores the mapping locally).
4. For systems that cannot integrate, require documented exceptions and a manual control procedure (e.g., periodic local account review + termination workflow). ¹

Step 5: Implement lifecycle controls (joiner/mover/leaver) that actually drive deprovisioning

Centralization fails if termination is inconsistent. Align:

• HR or identity trigger events (hire, role change, termination)
• Provisioning workflow (who approves what)
• Deprovisioning workflow (how quickly access is removed, how you validate removal)
• Third-party offboarding (contract end dates, sponsor ownership, access expiration)

Evidence focus: show that identity state changes drive access changes across integrated systems, and that non-integrated systems are handled via tracked exceptions. ¹

Step 6: Put an exception process in place (and treat it as part of the control)

Centralization is rarely universal. Make exceptions auditable:

• Define what qualifies (technical limitation, contractual constraints, legacy tech)
• Require a compensating control set (local account review, stronger logging, shorter access duration, dedicated approval)
• Record owner, rationale, and planned remediation target

Artifact: Access Control Exception Register with approvals and review cadence. ¹

Step 7: Operationalize recurring evidence capture

Map the safeguard to a control that you can “run”:

• Monthly/quarterly export of group membership for privileged roles
• Access review sign-offs for critical systems
• Tickets for access changes (request/approve/implement)
• Termination samples showing deprovision completion
• System onboarding checklist with proof of SSO integration and local account restrictions ¹

Where Daydream fits naturally: Daydream becomes the place you map Safeguard 6.7 to the control narrative, assign owners, schedule recurring evidence, and store artifacts (exports, screenshots, tickets, and exception approvals) so assessments don’t turn into a scramble.

Required evidence and artifacts to retain (exam-ready checklist)

Retain artifacts that prove both design and operation:

Design artifacts

• Access Control Centralization Standard (definition of centralized control in your environment) ¹
• System/application access inventory with integration status ¹
• Role/Group catalog and approval matrix ¹
• Exception register template and workflow description ¹

Operating artifacts

• Samples of access requests with approvals and fulfillment evidence (tickets/workflows)
• SSO configuration evidence for key systems (configuration screenshots/exports)
• Group membership exports for privileged groups and review sign-offs
• Joiner/mover/leaver samples that show deprovisioning completion
• Exception approvals plus compensating control evidence (local account reviews, logs, attestations) ¹

Common exam/audit questions and hangups

Expect these questions, and prepare artifacts to answer them cleanly:

• “What is your centralized access control mechanism, and what systems are in scope?” ¹
• “Which systems still use local accounts, and who approved that exception?” ¹
• “Show evidence that terminated users lose access across SaaS, cloud, and on-prem systems.” ¹
• “How do you control privileged access differently from standard access?” ¹
• “How do you validate that access matches job responsibilities?” (role mapping + access reviews) ¹

Hangups that stall audits:

• No authoritative system inventory (you cannot prove coverage).
• “SSO enabled” but local sign-in still allowed with weak oversight.
• Access reviews exist, but they exclude the systems with the highest risk. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	What to do instead
Treating centralization as “we bought an IAM tool”	Tools don’t prove consistent administration	Write a standard, build an inventory, and run evidence cycles tied to key systems. 1
Leaving app-native admins unmanaged	Admin access becomes invisible to central oversight	Require SSO for admin consoles; move admin grants into centrally governed groups where feasible. 1
No exception discipline	Local accounts proliferate silently	Maintain an exception register with compensating controls and periodic review. 1
Service accounts handled ad hoc	Hard to attribute, rotate, or revoke	Define service account ownership, approval, and lifecycle rules under the same centralized governance. 1
Evidence captured “at audit time”	High effort, high miss rate	Schedule recurring exports/reviews and store them centrally (Daydream or equivalent). 1

Enforcement context and risk implications

No public enforcement cases were provided for this safeguard in the provided source catalog, so this page does not cite enforcement outcomes.

Risk-wise, fragmented access control increases the likelihood of unauthorized access persisting after role changes or terminations, inconsistent privileged access assignments, and delayed detection of inappropriate access. Centralization reduces those failure modes by making access changes repeatable and reviewable across systems. ¹

A practical 30/60/90-day execution plan

Time-bound plans work best when they are deliverable-driven. Use these phases as a checklist and adapt to your environment.

First 30 days (stabilize and define)

• Publish the Access Control Centralization Standard (what must be centralized, acceptable exceptions). ¹
• Build the system/application access inventory and identify the highest-risk systems (admin consoles, sensitive data systems). ¹
• Define the role/group model for standard and privileged access; document approvers. ¹
• Stand up the exception register and approval workflow; require every local-account system to be recorded. ¹

Days 31–60 (integrate and control the biggest risks)

• Onboard priority systems to centralized authentication (SSO/directory integration) and validate sign-in paths. ¹
• Migrate privileged access grants into centrally managed groups/roles where feasible. ¹
• Implement joiner/mover/leaver workflows that trigger provisioning and deprovisioning actions across integrated systems; collect samples as evidence. ¹
• Start your first recurring evidence cycle: group membership export + review sign-off for privileged groups. ¹

Days 61–90 (operationalize and make it auditable)

• Expand integration coverage to the next tier of systems; update the inventory and roadmap. ¹
• Reduce local access paths: disable local auth where possible; where not possible, require compensating controls and document them in the exception register. ¹
• Run an access review for a set of critical systems; document findings and remediation tickets. ¹
• Centralize evidence storage and control mapping (Daydream is a practical choice) so the control can be re-performed and re-proven without rework. ¹

Frequently Asked Questions

Does “centralize access control” mean every system must use SSO?

Centralization is the goal, but some systems may not support SSO or federation. Treat those as formal exceptions with compensating controls and a plan to reduce scope over time. ¹

Can we meet Safeguard 6.7 if authorization still happens inside each application?

Yes, if the administration of roles/groups is centrally governed and you can evidence consistent approvals, reviews, and deprovisioning. The key is that access decisions are controlled and reviewable, not improvised per system. ¹

How should we handle third-party access (contractors, vendors, MSPs)?

Give third parties named identities in your central identity system where feasible, assign access through defined roles, and require a sponsor plus expiration/offboarding workflow. Track any app-native third-party accounts as exceptions with periodic review. ¹

What counts as acceptable evidence for auditors?

Auditors typically want a combination of design documents (standard, inventory, role catalog) and operating proof (access tickets, group exports with sign-offs, deprovision samples, exception approvals). Store evidence in a consistent location and tie it back to the safeguard. ¹

We have multiple identity providers due to acquisitions. Is that automatically non-compliant?

Not automatically, but it raises the bar on governance. Document which provider is authoritative for which population, show consistent lifecycle controls, and maintain a consolidation roadmap with exceptions tracked and reviewed. ¹

What is the quickest win that reduces risk without a long integration project?

Start with privileged access: move admin assignments into centrally governed groups, require approvals, and run recurring membership reviews. Even partial centralization in the highest-risk area improves control quality and auditability. ¹

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8