Insider Threat and Privileged Misuse Procedure

Purpose

This procedure defines how the company should identify, escalate, investigate, and respond to suspected misuse of trusted access.

Insider threat includes more than deliberate malicious behavior. It can involve:

• Careless or negligent employees
• Compromised employee accounts
• Departing staff
• Contractors
• Vendors and MSP personnel
• Privileged administrators
• Shared accounts
• Service accounts
• Users with excessive permissions

The objective is to protect the company while treating sensitive employee matters carefully, fairly, and confidentially.

1. Situations That May Require Escalation

Potential warning signs include:

• Unusual access to sensitive information
• Large or unexpected downloads
• Mass copying or deletion of files
• Unexpected public or external sharing
• Access outside normal responsibilities
• Attempts to bypass approvals
• Creation of unauthorized administrator accounts
• Unexpected MFA or password changes
• Use of personal email or cloud storage for company data
• Vendor access outside expected scope
• Unusual access shortly before departure
• Attempts to disable logging or security controls
• Unauthorized changes to payments, payroll, customer information, or system configuration

A warning sign does not prove wrongdoing. Context must be considered.

2. Report the Concern

Concerns should be reported through an approved channel.

Reporter: ____________________

Date/time reported: ____________________

Concern reported: ____________________

System or data involved: ____________________

Immediate risk: ____________________

Do not encourage employees or managers to investigate suspected insiders themselves.

3. Assign Restricted Handling

Potential insider cases should be handled on a need-to-know basis.

Depending on the situation, involve:

• Cybersecurity or IT owner
• Leadership
• HR
• Legal counsel
• Compliance
• Incident response provider
• MSP
• Law enforcement where appropriate

The suspected person should not automatically be notified before access and evidence risks are considered.

4. Preserve Evidence

Before making unnecessary changes, preserve relevant evidence where practical.

This may include:

• Authentication logs
• Email logs
• File access records
• Download history
• Cloud audit logs
• Endpoint logs
• Administrator activity
• VPN and remote access records
• Security alerts
• Relevant communications
• Approval records
• Device information

Do not unnecessarily alter, delete, or overwrite evidence.

5. Assess Immediate Risk

Determine:

• Is activity still occurring?
• Can sensitive information still be accessed?
• Does the person or account have privileged access?
• Could evidence be deleted?
• Could backups be affected?
• Could payments or business processes be changed?
• Could other systems be affected?
• Is the account potentially compromised rather than deliberately misused?

6. Apply Proportionate Containment

Possible actions may include:

• Suspend an account
• Revoke active sessions
• Remove privileged access
• Restrict access to sensitive data
• Disable remote access
• Remove vendor access
• Restrict data exports
• Isolate a device
• Preserve a mailbox
• Increase monitoring

Containment should be approved by appropriate technical, management, HR, or legal owners based on the circumstances.

7. Investigate the Cause

Determine whether the situation resulted from:

• Malicious behavior
• Negligence
• Account compromise
• Excessive permissions
• Weak process controls
• Poor offboarding
• Unclear responsibilities
• Shared credentials
• Vendor misuse
• Misconfiguration
• Normal activity incorrectly interpreted as suspicious
• Avoid assuming intent before the facts are established

8. Record Decisions

Record:

• What was reported
• Who was informed
• Evidence preserved
• Actions taken
• Who approved actions
• Business impact
• Investigation findings
• Access changes
• Legal or HR involvement
• Final determination
• Follow-up actions

9. Correct the Control Failure

Following the investigation, review whether improvements are required.

Examples:

• Reduce excessive permissions
• Improve access reviews
• Eliminate shared accounts
• Strengthen offboarding
• Increase MFA coverage
• Improve logging
• Restrict data exports
• Introduce separation of duties
• Strengthen vendor access
• Improve manager training
• Improve secrets management

10. Maintain Confidentiality

Insider investigations can involve sensitive employee, legal, security, and business information.

Records should be restricted to people with a legitimate need to access them.

Practical Rule

Treat unusual trusted-access activity seriously, but investigate facts before assuming intent.

Protect the company, preserve evidence, and involve HR, legal, leadership, and technical owners where appropriate.