Safeguard 6.8: Define and Maintain Role-Based Access Control

Safeguard 6.8 requires you to define role-based access control (RBAC) roles tied to job functions, assign access through those roles (not ad hoc user-by-user), and keep roles current as systems and responsibilities change. To operationalize it fast, build a role catalog, map roles to systems and permissions, enforce role-based provisioning in your IAM workflow, and run recurring reviews with evidence. ¹

Key takeaways:

• Build a documented RBAC model (roles, owners, entitlements, constraints) aligned to business functions, then make it the default way access is granted. ¹
• Treat “maintain” as a control operation: change control for roles, periodic access reviews, and prompt updates when org or application permissions change. ¹
• Evidence wins audits: role definitions, approval trails, provisioning logs, review results, and exceptions with compensating controls. ¹

RBAC is one of the highest-return access controls because it replaces informal, person-specific permissions with repeatable, auditable access patterns. Safeguard 6.8 focuses on two things operators often split across teams: (1) defining roles that match how work is actually performed, and (2) maintaining those roles so they don’t drift into “everyone gets everything.”

For a CCO or GRC lead, the operational goal is straightforward: you need a control design that limits access through job-aligned roles, and you need proof the design runs reliably. That proof usually fails in three places: roles aren’t documented, roles don’t map cleanly to entitlements in key systems, and “temporary” exceptions never expire.

This page gives requirement-level implementation guidance you can hand to IAM, IT, Security, and application owners. It prioritizes exam-ready artifacts: a role catalog, role-to-entitlement mapping, provisioning and deprovisioning workflows, a review cadence, and exception handling that produces clean evidence. The requirement here comes from CIS Controls v8, which is commonly used as a baseline for security programs and as supporting rationale in broader compliance programs. ¹

Requirement: safeguard 6.8: define and maintain role-based access control requirement

Objective: Access is granted based on defined roles tied to job responsibilities, with roles actively maintained as the organization, applications, and permission sets change. ¹

RBAC under Safeguard 6.8 should reduce:

• Excess privileges (users accumulate permissions over time)
• Inconsistent approvals (different approvers, different standards)
• Orphaned access (role changes, transfers, terminations)
• Audit friction (can’t explain why a person has a permission)

Regulatory text

Framework requirement excerpt: “CIS Controls v8 safeguard 6.8 implementation expectation (Define and Maintain Role-Based Access Control).” ¹

Operator interpretation: You must (a) define RBAC roles and their allowed access, (b) implement access assignment through those roles in practice, and (c) maintain the role model as a living control with governance, change management, and periodic validation. ¹

Plain-English interpretation

What “define” means in practice:

• A role exists as a documented object with a name, purpose, owner, eligibility criteria (who can be in it), and a list of entitlements it grants.
• Roles reflect job functions (e.g., AP Specialist, Tier 2 Support, Cloud Platform Admin), not just org chart titles.

What “maintain” means in practice:

• Roles have lifecycle governance: create, change, retire.
• Roles are reviewed for correctness and least privilege, especially after org changes and major application permission changes.
• Exceptions are time-bound and tracked to closure.

Who it applies to

Entities: Any organization adopting CIS Controls v8 as a framework baseline, including enterprises and technology organizations. ¹

Operational context (where auditors look first):

• Central identity providers (IdP), directories, and IAM tooling
• Core business apps with sensitive data (ERP, HRIS, finance, CRM)
• Admin consoles and infrastructure (cloud, endpoint management, databases)
• Third-party access paths (consultants, outsourced IT, SaaS support accounts)

Teams involved:

• IAM / IT Operations: provisioning mechanics, group management, joiner-mover-leaver
• Security: privileged access requirements, monitoring expectations
• Application owners: define entitlements and separation-of-duties constraints
• GRC/Compliance: control definition, evidence, exceptions, review governance

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

Step 1: Set RBAC scope and rule-of-engagement

1. Choose in-scope systems (start with systems that hold regulated or sensitive data, plus admin planes).
2. Define the RBAC standard: what a “role” must include (owner, description, entitlements, approval path, review cadence).
3. Decide how RBAC is implemented technically: directory groups, IdP app roles, IAM roles, or application-native roles.

Deliverable: RBAC standard + in-scope system list.

Step 2: Build a role catalog that maps jobs to access

1. Inventory current access patterns: pull current group memberships/roles for each system.
2. Cluster by job function: identify the smallest set of roles that covers real work without becoming “one role per person.”
3. Define each role with:
   • Role name and business function
   • System(s) covered
   • Entitlements granted (groups, permissions, app roles)
   • Role owner (business) and technical owner (system)
   • Approval requirement (manager + data/system owner as needed)
   • Constraints (segregation-of-duties notes, location/device requirements if you enforce them)

Deliverable: Role catalog (spreadsheet, GRC system, or IAM governance tool export).

Step 3: Convert provisioning to “role-first” access requests

1. Update access request forms so requesters select roles, not raw permissions.
2. Enforce approvals based on role risk:
   • Standard roles: manager approval
   • Sensitive roles: manager + system/data owner approval
   • Privileged roles: additional security approval and stronger authentication controls (aligned with your privileged access program)
3. Automate provisioning where possible (directory groups / IdP assignments / SCIM), and document manual steps where automation is not available.

Deliverable: Written workflow + ticket templates + system configuration screenshots/exports.

Step 4: Handle exceptions without breaking RBAC

You will have exceptions. Treat them as controlled deviations:

1. Create an “RBAC exception” record with business justification, exact access requested, approver, start date, and end condition.
2. Require compensating controls for high-risk exceptions (added monitoring, break-glass accounts, session recording if available).
3. Expire exceptions: access should be removed automatically or through a tracked task.

Deliverable: Exception register + samples of approved, time-bound exceptions.

Step 5: Maintain RBAC through governance and reviews

1. Role lifecycle governance
   • New role: requires owner, entitlement mapping, and review schedule
   • Change role: change ticket with impact analysis (who gains/loses access)
   • Retire role: migration plan for users, then remove entitlements
2. Access reviews
   • Review role membership (who is in each role) and role definitions (what the role grants)
   • Focus on privileged and sensitive roles first
3. Trigger-based updates
   • New application modules, new permissions, major org restructure, M&A, or outsourcing changes should trigger a role review.

Deliverable: Review logs, sign-offs, and completed remediation actions.

Step 6: Make evidence capture routine (so audits are easy)

A common failure for Safeguard 6.8 is “we do RBAC, but we can’t prove it.” Fix that by designing evidence capture into operations:

• Role catalog export on a schedule
• Provisioning and deprovisioning tickets tied to roles
• Periodic review reports with approvals and remediation tracking

Daydream can help by mapping Safeguard 6.8 to a documented control operation and recurring evidence capture, so you can show consistent execution instead of assembling artifacts during an audit scramble. ¹

Required evidence and artifacts to retain

Use this as your audit evidence checklist:

Artifact	What “good” looks like	Owner
RBAC policy/standard	Defines roles, required metadata, approval rules, and maintenance expectations	GRC + Security
Role catalog	Versioned list of roles, owners, entitlements, and systems	IAM + App owners
Role-to-entitlement mapping	Clear mapping to groups/permissions in each system	IAM
Access request/approval records	Requests are role-based; approvals match policy; timestamps preserved	ITSM/IAM
Provisioning logs	Shows role assignment completed; includes joiner/mover/leaver cases	IAM/IT
Access review records	Reviewer, date, scope, findings, and remediation tracking	GRC + App owners
Exception register	Business justification, approval, time-bound access, closure evidence	GRC
Change management tickets for roles	Role changes follow controlled workflow; includes testing/impact notes	IAM/IT

Common exam/audit questions and hangups

Auditors and assessors tend to press on these points:

1. “Show me your roles.” They want a role catalog, not tribal knowledge.
2. “Prove access is granted through roles.” They sample tickets and system logs; ad hoc grants are a red flag.
3. “Who approves role changes?” If owners are unclear, the control looks unmanaged.
4. “How do you know roles are still least privilege?” You need review evidence and remediation outcomes.
5. “What about privileged access?” RBAC must exist for admin access too, even if implemented via separate privileged access tooling.

Frequent implementation mistakes and how to avoid them

1. Roles built from org titles, not work. Titles change and hide real access needs. Build roles from tasks and system actions, then map titles to roles.
2. Over-broad “catch-all” roles. If a role becomes a dumping ground, it defeats least privilege. Split it or require exceptions for edge permissions.
3. No role owners. Without a named owner, roles never get reviewed. Assign a business owner per role and enforce review sign-off.
4. RBAC exists only in one system. Partial RBAC increases audit risk. Start with your highest-risk systems, but document the rollout plan for the rest.
5. Exceptions become permanent. Put an end condition on every exception and track closure like any other risk item.

Enforcement context and risk implications

No public enforcement cases were provided for this safeguard in the supplied source catalog. Practically, RBAC failures often surface as:

• Unauthorized access to sensitive data
• Privileged misuse or over-permissioned admin accounts
• Control breakdowns during employee moves and contractor onboarding

Even without a specific enforcement citation here, auditors commonly treat RBAC as foundational because it supports least privilege, separation of duties, and incident containment across many frameworks and internal control programs. ¹

Practical 30/60/90-day execution plan

Use this as an operator’s rollout sequence. Adjust scope based on system count and IAM maturity.

First 30 days (foundation and scoping)

• Name an RBAC control owner and define RACI across IAM, Security, GRC, and app owners.
• Select initial in-scope systems (prioritize identity provider, core business apps, and admin planes).
• Publish an RBAC standard (role metadata, approvals, exception handling, review expectations).
• Pull current access exports for in-scope systems and identify obvious over-privilege hotspots.

Next 60 days (build and enforce role-first provisioning)

• Create the initial role catalog for in-scope systems.
• Implement role-based request paths in ITSM/IAM (forms, approval routing, fulfillment steps).
• Migrate users from direct entitlements to role assignments where feasible.
• Stand up the exception register and require time-bound approvals for non-role access.

By 90 days (operate and prove)

• Run the first role membership review for sensitive and privileged roles, record sign-offs, and track remediation.
• Formalize role change management (new/change/retire) with ticketing and owner approvals.
• Create a repeatable evidence pack: role catalog export, sample tickets, review report, exception log.
• If you use Daydream, map Safeguard 6.8 to a documented control operation and automate recurring evidence capture to keep the audit trail current. ¹

Frequently Asked Questions

Do we need RBAC in every system to meet Safeguard 6.8?

You need RBAC defined and operating for the systems in scope for your CIS Controls implementation, with a defensible rationale. Start with highest-risk systems and document a rollout plan for the rest. ¹

How do we handle roles for contractors and other third parties?

Treat third-party users as first-class identities with the same role catalog and approval rules, and restrict them to roles designed for external access. Track sponsorship (an internal owner) and enforce time-bound access where the engagement has an end date.

What’s the minimum a “role definition” must include to satisfy auditors?

At minimum: role name, purpose/job function, systems covered, entitlements granted, role owner, and approval requirements. Add constraints and review expectations to reduce exception volume.

Our applications have messy permission sets. Can we still implement RBAC?

Yes, but you may need an interim layer: map roles to application permission bundles even if the bundles are imperfect. Document known gaps and use exceptions plus monitoring until the permission model is cleaned up.

How often should we review roles and role membership?

Set a recurring cadence based on risk, with more frequent reviews for privileged and sensitive roles. Also review on triggers like reorganizations, major application permission changes, and outsourcing changes.

What evidence is most persuasive during an audit?

A current role catalog, samples of role-based access requests with approvals, provisioning logs showing assignments, and completed review records with remediation actions. If exceptions exist, auditors expect a register with time bounds and closure evidence.

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8