Policy on Use of Network Services

The HITRUST “Policy on Use of Network Services” requirement means you must (1) restrict access to network services to explicitly authorized users and (2) maintain a written policy that defines which networks/services are allowed and how access is approved, granted, reviewed, and removed ¹. Operationalize it by building a service access catalog, tying approvals to roles and tickets, and producing audit-ready evidence of enforcement.

Key takeaways:

• Your policy must name allowed network services and the authorization process, not just state “least privilege” ¹.
• “Authorization” has to be provable: tickets, approvals, technical controls, and review logs matter as much as the policy.
• Scope includes internal users, contractors, and third-party access paths that reach your networks and network services.

This requirement is easy to misunderstand because it sounds like generic access control. It is more specific. HITRUST expects you to govern and control network services (think VPN, Wi‑Fi, administrative network segments, remote access gateways, DNS, proxy, SMB file shares, SSH/RDP, privileged management planes, and cloud network entry points) so users can only reach what they are explicitly allowed to use ¹.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat “network services” as a managed portfolio: define what exists, decide what is allowed, document the approval path, and prove enforcement with system evidence. Auditors typically fail teams on gaps between policy and practice: a policy exists, but VPN access is granted informally; a “temporary” firewall rule never expires; a third party still has an active account; or network segmentation exists but isn’t tied to authorization.

This page gives requirement-level implementation guidance you can hand to IT/security operations and then verify through artifacts. It is written to help you pass a HITRUST assessment with minimal rework while reducing real operational risk ¹.

Regulatory text

HITRUST CSF v11 01.i states: “Users shall only be provided with access to services that they have been specifically authorized to use. A policy shall be formulated concerning the use of networks and network services, covering networks and network services that are allowed to be accessed and authorization procedures.” ¹

What the operator must do:

1. Enforce “specific authorization” for access to network services (not implied access).
2. Publish and maintain a policy that (a) identifies allowed networks and network services and (b) defines authorization procedures for granting access ¹.

Plain-English interpretation (what this really means)

• You cannot rely on “everyone on the corporate laptop can reach whatever the network allows.” Access must be intentionally granted.
• Your policy must be concrete enough that a reviewer can answer:
  • Which network services are permitted (and for whom)?
  • How does someone request access?
  • Who approves it, on what basis, and how is it implemented?
  • How is access reviewed and removed? ¹

In practice, this is where identity governance meets network engineering. You are connecting business authorization to technical enforcement (group membership, network access control, firewall rules, VPN profiles, segmentation, conditional access, and privileged access workflows).

Who it applies to (entity + operational context)

Entity scope: All organizations seeking alignment to HITRUST CSF requirements ¹.

Operational scope (typical):

• Workforce members: employees, interns, temps, and contractors.
• Third parties with any connectivity into your environment (support vendors, MSPs, billing partners, integration partners).
• Environments: corporate network, cloud networks, production and non-production, and remote access paths.
• Network services that commonly fall in scope:
  • Remote access (VPN/ZTNA), administrative access (RDP/SSH/bastion), Wi‑Fi (corp/guest), internal DNS, web proxy, file shares (SMB/NFS), privileged management interfaces, and any “jump box” or management subnet ¹.

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

Step 1: Define “network services” for your organization

Write a one-page definition in the policy or a referenced standard. Keep it operational:

• “Network services” = services that provide connectivity, routing, name resolution, remote access, or administrative access to systems and network segments.
• Include examples relevant to your stack (VPN, ZTNA, Wi‑Fi, RDP/SSH, proxy, DNS, management VLANs, cloud VPC/VNet peering, etc.).
  This definition prevents scope debates during assessment ¹.

Step 2: Build an allowed network services catalog

Create a table (spreadsheet or GRC system) that lists each service and its access rules. Minimum fields:

• Service name and owner (business + technical)
• Purpose / business justification
• Allowed user populations (roles or groups)
• Authentication method (SSO, MFA requirement where applicable)
• Authorization method (role-based group, ticket-based firewall change, PAM approval)
• Logging source (where evidence comes from)
• Review/recertification approach ¹

This catalog becomes the backbone of your policy and your audit evidence.

Step 3: Write (or update) the Policy on Use of Network Services

Your policy should be short, enforceable, and mapped to real processes. Include:

• Allowed networks and services: reference the catalog as the authoritative list.
• Prohibited access paths: examples: direct RDP from the internet, shared accounts, unmanaged devices on privileged Wi‑Fi, ad-hoc port openings without ticket.
• Authorization procedures: request, approval, implementation, verification, and removal steps.
• Third-party access requirements: sponsor, time-bounded access, and termination steps when engagement ends.
• Exceptions process: risk acceptance, compensating controls, expiration, and required approvals ¹.

Policy language should clearly require that access is granted only after approval, and it should name the systems of record (ITSM, IAM, PAM, firewall change workflow).

Step 4: Tie authorization to identity (roles/groups) and to change control

You need a consistent enforcement pattern:

• For user-to-service access (VPN, Wi‑Fi, proxy): assign access via identity groups mapped to roles.
• For network path changes (firewall rules, routing, security groups): require an approved change ticket with documented business need and scope.
• For privileged network services (bastion, admin VLAN): require PAM workflows and separate admin accounts where feasible ¹.

Your assessor will look for evidence that “specific authorization” is real and repeatable, not discretionary.

Step 5: Implement review and removal controls that actually work

Common operational minimums:

• Trigger deprovisioning on HR termination and contractor offboarding.
• Review high-risk network services (remote access, admin access, privileged segments) more often than low-risk ones; document your rationale.
• Ensure service owners review membership lists or entitlements and attest to continued need ¹.

Step 6: Make it auditable: logging, traceability, and sampling readiness

Prepare to show:

• The policy and service catalog are current.
• A sample of users with VPN/admin access and their approvals.
• A sample of firewall/security group changes with tickets and approvals.
• Evidence that access gets removed when no longer authorized ¹.

A practical tip: pre-build an “audit packet” folder for each critical network service with screenshots/exports and a short narrative of how access is authorized.

Required evidence and artifacts to retain

Keep artifacts that prove policy + enforcement + review:

• Approved Policy on Use of Network Services with version history and owner.
• Network services catalog (allowed services list) and ownership assignments.
• Access request/approval records (ITSM tickets, IAM approvals, PAM approvals).
• Group membership exports for services (VPN groups, Wi‑Fi NAC groups, bastion access lists).
• Firewall/security group/routing change tickets with approvals and implementation evidence.
• Access review/recertification records (attestations, review reports, remediation actions).
• Offboarding evidence showing removal of network service access ¹.

Common exam/audit questions and hangups

Auditors commonly probe:

• “Show me which network services are allowed and who can use them.”
• “Pick three users with VPN access. Where is their authorization?”
• “How do you authorize access to admin network segments or bastions?”
• “How do third parties connect, and how do you remove access when work ends?”
• “What’s your exception process for emergency access or urgent firewall changes?” ¹

Hangups that slow assessments:

• No single source of truth for allowed services (policy says one thing, network team does another).
• “Implicit access” via flat networks, shared Wi‑Fi keys, or unmanaged local admin paths.
• Tickets exist, but approvals don’t match the approver requirements in the policy.

Frequent implementation mistakes (and how to avoid them)

Mistake 1: A policy that lists principles but not allowed services

Fix: Maintain the allowed-services catalog and reference it from the policy. Update the catalog as part of change management ¹.

Mistake 2: Treating “network services” as only VPN and Wi‑Fi

Fix: Include administrative access paths (RDP/SSH/bastions), internal proxy/DNS, management networks, and cloud network entry points where users can reach systems they should not ¹.

Mistake 3: Approvals that are not tied to technical enforcement

Fix: Map approvals to specific groups, firewall objects, or PAM entitlements. If you can’t trace “approval → implementation,” you will struggle to prove “specifically authorized.”

Mistake 4: Third-party access handled as an exception forever

Fix: Create a standard third-party remote access pattern with sponsor, time bounds, and periodic re-approval.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions. Operationally, weak control over network services increases the blast radius of compromised credentials and makes unauthorized lateral movement easier. From a governance standpoint, the risk is assessment failure due to inability to prove authorization and enforcement ¹.

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and documentation)

• Assign a control owner and technical owners for major network services.
• Draft/update the Policy on Use of Network Services with clear authorization procedures.
• Build an initial allowed network services catalog for the highest-risk services (remote access and administrative access first).
• Identify where approvals live (ITSM/IAM/PAM) and standardize the request fields (business need, role, duration if applicable).

Days 31–60 (connect policy to enforcement)

• Map each critical network service to an authorization mechanism (group, entitlement, or change ticket type).
• Require tickets for firewall/security group changes and ensure approver roles align with the policy.
• Establish third-party access patterns (sponsor requirement, access method, removal trigger).
• Create an audit packet template per service (what evidence to export, from where).

Days 61–90 (prove it with reviews and sampling)

• Run an access review for at least one high-risk network service and document remediation actions.
• Test offboarding: confirm terminated users lose network service access and retain evidence.
• Perform an internal “mini-audit” sample: pick users and firewall changes and verify traceability from authorization to technical state.
• If you want to scale this, Daydream can help you centralize the service catalog, collect standardized evidence from system owners, and keep an assessor-ready trail without chasing screenshots across teams.

Frequently Asked Questions

What counts as a “network service” under this requirement?

Treat it as any service that enables connectivity or administrative reach into systems or network segments (VPN/ZTNA, Wi‑Fi, bastions, RDP/SSH paths, proxy, DNS, management networks). Document your definition and examples in the policy so scope stays consistent ¹.

Do we need to list every VLAN, subnet, and firewall rule in the policy?

No. Keep the policy readable and reference an “allowed network services catalog” as the system of record. Auditors usually want to see that the catalog exists, is owned, and is tied to authorization procedures ¹.

How do we prove “specifically authorized” for VPN access?

Show the approval record (ticket or IAM workflow), the user’s membership in the VPN access group, and logs/config evidence that the group is required for access. The key is traceability from authorization to enforcement ¹.

How should we handle third-party remote access?

Require a business sponsor, documented business need, and a defined access method (separate accounts, MFA, and scoped entitlements where applicable). Make removal part of the engagement closeout and keep evidence of deprovisioning ¹.

What if operations needs emergency network changes?

Permit emergency changes in the policy, but require retrospective approval, documentation of scope, and a defined rollback or expiration step. Exceptions should be time-bounded and tracked to closure ¹.

Can segmentation substitute for authorization?

Segmentation helps, but it does not replace authorization. You still need a defined process that determines who is allowed to access segmented services and proof that access was granted based on that authorization ¹.

Footnotes

1. HITRUST CSF v11 Control Reference