They should bring shadow IT and locally managed permissions into the same control model as centrally administered access. That means identifying departmental tools, local accounts, and infrastructure-level permissions, then deciding whether each one can be integrated, mapped, or remediated into certification scope. If it cannot be seen, it cannot be governed.
How to Pull Shadow IT and Local Access into One Review Model
Identity reviews only work when the review scope matches where access actually exists. Shadow IT creates unmanaged systems outside central administration, while local access often lives in folders, devices, servers, admin consoles, or application settings that never pass through the main IAM workflow. The review model has to inventory those paths first, then decide what is certifiable, what must be mapped, and what must be retired.
For many organisations, the practical starting point is an inventory of departmental tools, local accounts, shared admin credentials, and infrastructure-level permissions that support the business but sit outside standard recertification. Once those are visible, the review can treat them as governed access rather than tolerated exceptions.
The key governance question is not whether the access is central or local, it is whether someone can attest to it, remediate it, and keep it in scope over time. That is why shadow IT and local permissions should be folded into the same control model as centrally administered access.
What Belongs in Certification Scope, and What Must Be Remediated First?
Not every local permission can be reviewed in the same way, but every access path should be classified. Some items can be integrated into existing review cycles by mapping the local entitlement to an owner, a system, and a business purpose. Others need remediation before certification because the access is too opaque, too broad, or too detached from an accountable owner.
Local administrator rights, service accounts, shared folders, vendor-managed consoles, and application-specific roles are common examples of access that is technically real but administratively invisible. Where the access can be connected to an identified person or function, it belongs in review scope. Where it cannot, the right response is usually discovery, rationalisation, or decommissioning, not a cosmetic attestation.
A useful rule is to ask whether the access can be described in a control statement that a reviewer can validate. If the answer is yes, it can be certified. If the answer is no, the access likely needs mapping, ownership assignment, or removal before it should be considered governed.
Why Shadow IT and Local Permissions Fail Governance
Shadow IT and local access fail governance for the same reason, they bypass the control plane that creates visibility, evidence, and accountability. That does not always mean they are malicious or even poorly run, but it does mean they often lack the lifecycle controls needed for reliable review. NHIMG’s IAM and IGA Basics is useful here because the same entitlement logic used for centrally managed access should be extended to local and departmental access paths.
Once shadow systems and local permissions exist outside the normal joiner-mover-leaver flow, review teams tend to inherit several failure modes: stale access, duplicate accounts, shared ownership, and unclear business justification. The control weakness is usually not the existence of the access itself, but the absence of a durable mapping between the access, the owner, and the approved business need.
That is why access review design should treat these items as governance exceptions only if the exception is temporary and actively remediated. If the exception has become the operating model, it is no longer an exception, it is unmanaged access.
Risk and Threat Considerations
Shadow IT and locally administered access create blind spots that attackers and insiders can exploit because they are often weaker on logging, review, and revocation than centrally managed access. They also increase the chance that old or overprivileged permissions persist after a role change, project closure, or system decommissioning.
Failure mechanism: Access exists outside the central identity control plane, so it is not consistently inventoried, certified, or removed; that allows stale permissions, shared accounts, and unowned privileges to survive review cycles.
Impact: The organisation loses the ability to prove least privilege, detect inappropriate access early, or revoke risky permissions quickly, which raises both security exposure and audit failure risk.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
NIST CSF 2.0 and NIST SP 800-53 Rev 5 set the technical controls, while ISO/IEC 27001:2022 defines the regulatory obligations.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | GV.RM-01 — Risk Management Strategy | Shadow IT and local access create governance risk that must be managed across review scope. |
| Recommendation — Define a risk-based scope for non-central access paths and track them to remediation or certification. | ||
| NIST SP 800-53 Rev 5 | AC-2 — Account Management | Local accounts and shadow access need inventory, review, and revocation controls. |
| AC-6 — Least Privilege | Local permissions often become overbroad and require privilege reduction. | |
| AU-6 — Audit Review, Analysis, and Reporting | Governed review of shadow access depends on audit evidence and exception follow-up. | |
| Recommendation — Inventory local and shadow accounts, then review and disable accounts that lack an approved owner. Reduce local permissions to the minimum required and remove unnecessary administrative rights. Correlate access review findings with audit evidence to confirm revocation and ownership changes. | ||
| ISO/IEC 27001:2022 | A.5.15 — Access control | Shadow IT and local access must be brought under access control policy and review. |
| A.5.18 — Access rights | Local permissions need assignment, review, and removal under formal access-rights control. | |
| Recommendation — Extend access control policy to cover departmental tools and locally managed permissions. Review access rights for local and shadow systems on the same schedule as central systems. | ||
Practitioner Guidance
What to prioritise: Start with access paths that can create the largest blast radius, local admin rights, shared operational accounts, privileged application roles, and any departmental tool that can reach sensitive data or production systems. Those are the items most likely to hide material risk behind a small number of visible users.
What to verify: For each non-central access path, confirm three things: who owns it, what business function it supports, and how it will be removed or recertified if the owner changes. If any of those three are missing, the item is not ready for routine certification.
Decision rule: If the access can be mapped to a named system owner and an auditable entitlement, keep it in certification scope. If it cannot be mapped without guesswork, treat it as a remediation case and do not rely on a reviewer to bless it as-is.
Practitioner takeaway: The control objective is not to force every local permission into the same workflow, but to ensure no access path sits outside ownership, evidence, and removal authority for long.
Related resources from NHI Mgmt Group
- How should organisations govern SaaS licenses alongside identity access reviews?
- How should security teams run access reviews for non-human identities?
- How should security teams govern non-human identities that have persistent access?
- When do NHI access reviews create more value than a one-time cleanup?