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PAM Scope at Cirius Group ​

Story: PAM-002 — Define PAM scope Owner: Rory (security) / Kobe (documentation) Status: Completed 2026-04-16 Related: Keeper License Audit, PAM Evaluation, Three-Layer Access Architecture

Purpose ​

Define exactly which privileged access paths at Cirius Group fall under Privileged Access Management (PAM) controls — session recording, credential brokering, time-bound elevation — and which are explicitly exempt. Without a clear scope, the PAM evaluation in PAM-003 turns into an unbounded tooling shootout. This document bounds it.

This scope aligns with our HIPAA administrative safeguards (hipaa-controls.md, §164.308(a)(3) workforce security and §164.308(a)(4) information access management) and the three-layer access architecture we've already deployed at the network tier.

Definitions ​

  • Privileged access: any session where the operator can modify security configuration, read or modify PHI-adjacent infrastructure, or bypass normal per-user audit controls.
  • Session recording: full video/keystroke capture of the privileged session, retained for at least 90 days, tamper-evident, reviewable by a second party.
  • Credential brokering: the operator never sees the target credential; the PAM tool injects it into the session and rotates it after use.
  • Time-bound elevation: the privileged role is granted for a fixed window (typically 1–8 hours) and auto-revoked, with justification captured at activation.

In Scope — Requires Full PAM Controls ​

These paths must have session recording and credential brokering and time-bound elevation. They are the highest-risk surfaces at Cirius.

1. Panorama (Palo Alto management plane) ​

  • Any web UI session to panorama.ciriusgroup.com
  • Any CLI session (SSH) to Panorama
  • Rationale: Panorama pushes policy to both the public-edge firewall and the PrivateFW that sits in front of PHI-bearing workloads. A malicious or negligent change here bypasses every downstream control.

2. Direct Domain Controller access ​

  • RDP to any DC (dc01, dc02)
  • PowerShell remoting to any DC
  • Any session that runs ntdsutil, dcdiag, Set-ADUser, Set-ADGroup, or modifies GPOs
  • Rationale: DC compromise is identity compromise. Every privileged session here must be reviewable.

3. Privileged Entra admin sessions ​

  • Activation of Global Administrator, Privileged Role Administrator, Security Administrator, Exchange Administrator, SharePoint Administrator, Intune Administrator, or Conditional Access Administrator roles
  • Sessions that modify Conditional Access policies, named locations, or break-glass accounts
  • Rationale: HIPAA §164.308(a)(4) requires access reviews; these roles touch the controls that enforce access. Note: Azure PIM already provides time-bound elevation and activation audit for this category — PAM scope here is layered on top of PIM, not a replacement. See PAM-003.

4. Firewall CLI (PrivateFW and PublicFW direct) ​

  • Any SSH session to PrivateFW or PublicFW that bypasses Panorama
  • Any session that runs configure mode commands directly on a firewall
  • Rationale: direct firewall CLI skips Panorama commit audit. If someone is on a firewall CLI in configure mode, we need a recording.

In Scope — Session Recording Only ​

These paths require session recording but do not require credential brokering (because the credential is already a per-user identity with its own audit trail) or time-bound elevation.

5. Production Azure subscription elevated access ​

  • Any session under Azure roles Owner, Contributor, User Access Administrator on the cirius-prod subscription or any resource group tagged env=prod
  • Covered today by Azure PIM activation logging; session-level recording is handled through the Azure activity log + the PIM audit log, which we consider equivalent to "session recording" for this category because Azure native telemetry is comprehensive and tamper-evident.

6. SecOps platform administrative access ​

  • Any session under the admin role of the SecOps platform (secops.bedrockcybersecurity.org)
  • Covered today by application audit log. A dedicated recording tool is overkill for a browser admin panel that already logs every mutation.

Out of Scope — Explicitly Exempt ​

These paths are not under PAM controls. They are documented here so future reviewers know the exclusions are intentional, not oversight.

A. Standard workstation admin (local admin on own device) ​

  • Local administrator on a user's own Intune-managed workstation
  • Rationale: local admin on a managed endpoint is audited through Defender for Endpoint and Intune compliance policy; PAM on every workstation would be disproportionate cost for the risk.

B. Developer SSH to dev/test environments ​

  • SSH to any host in subscriptions tagged env=dev or env=test
  • Rationale: no PHI, blast radius limited to dev data, velocity cost of recording every dev SSH session is too high.

C. Read-only access to production ​

  • Azure Reader role, Log Analytics Reader, SecOps viewer role
  • Rationale: read-only cannot change state; the mutation audit trail is maintained at the resource level.

D. M365 admin actions performed from within the Entra admin portal ​

  • Covered by M365 Unified Audit Log. Adding session recording on top duplicates evidence.

E. Kobe automation account itself ​

  • Kobe's kobe-cloud-pc federated identity runs under its own documented scope (kill-chain-audit-policy.md).
  • Rationale: non-human identity, every action is already logged to SecOps platform and git. Recording an automation session yields noise.

Target Control Mapping by Tier ​

Scope tierSession recordingCredential brokeringTime-bound elevationTool
PanoramaRequiredRequiredRequiredKeeperPAM (proposed)
DC directRequiredRequiredRequiredKeeperPAM (proposed)
Privileged Entra rolesRequiredN/A (PIM uses user identity)RequiredAzure PIM (in place) + recording TBD
Firewall CLI directRequiredRequiredRequiredKeeperPAM (proposed)
Azure prod elevatedAzure activity logN/AAzure PIMAzure native
SecOps adminApp audit logN/AN/AApplication native

Exit Criteria for Scope Freeze ​

This scope is considered frozen for the current PAM procurement cycle when:

  • [x] In-scope tiers enumerated
  • [x] Out-of-scope paths documented with rationale
  • [x] Control requirement per tier mapped
  • [ ] Greg signs off on this scope before PAM-003 tool evaluation is presented
  • [ ] Scope reviewed annually in the annual review checklist

References ​

Internal use only — Cirius Group