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Risks, Gaps, and Governance in User Lifecycle – CISO Perspective
September 15, 2025
Identity is no longer just human. From employees and contractors to IoT devices and AI agents, every identity brings risk if unmanaged. This blog examines the CISO’s view of user lifecycle governance, the biggest gaps organizations face, and how identity-aware policies can strengthen resilience.
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In the first three parts of this series, written by colleagues Cameron Fuller and Michael Leach, we explored the evolution of Microsoft’s user lifecycle solutions, the current capabilities with Entra ID, and how Quisitive augments those capabilities to close functional gaps.

Now we step into the security leader’s chair where technical execution meets business risk. Done well, identity governance is a business accelerator. Done poorly, it’s an open door to breach.

Identity is No Longer Just “Human”

Identity has become the new security perimeter, but the landscape now spans three distinct classes:

  1. Human Identities: Employees, contractors, partners.
  2. Non-Human Identities: Service accounts, IoT/OT devices, API keys.
  3. Agent Identities (AI): Autonomous or semi-autonomous software agents acting on behalf of humans or systems.

“The moment you design your governance model assuming all accounts are human, you’ve already lost.”

 HealthSec 2025 keynote presentation

Identity Management Practices and Governance is evolving rapidly and under legitimate pressure

As explored in my own recent blogs, The Rise of Agentic AI and Why OAuth Falls Short, identity has rapidly evolved beyond “human” users. We now operate in a multi-identity environment where human accounts, machine identities, and Agent IDs are all acting, sometimes autonomously, in critical business workflows.

This reality creates two pressure points:

  1. Increased Attack Surface: Every unmanaged account, misconfigured privilege, or orphaned identity is an opportunity for threat actors.
  2. Blurred Boundaries Between Humans and Agents: AI-powered agents and service accounts can act faster, at larger scale, and in ways that are harder to detect than traditional insider or external threats.

Without robust lifecycle governance, these risks scale exponentially.

Key Risk Areas in the Identity Lifecycle

Based on Quisitive’s field experience across regulated industries, here are the top governance challenges that organizations face. The challenge is governance parity: each identity type must have clear ownership, policies, monitoring, and lifecycle management. Controls will differ, but accountability must be the same.

  1. Joiner, Mover, Leaver (JML) Gaps
    • Delays in offboarding, or incomplete deprovisioning, leave accounts active well beyond an employee’s last day.
    • Role changes (“Movers”) without rights review lead to privilege creep.
  2. Non-Human Identity Sprawl
    • Service accounts, API keys, and Agent IDs often lack owners, expiration policies, or visibility in central identity tools.
    • OAuth grants proliferate without governance, creating shadow access pathways.
  3. Inconsistent Role-Based Access
    • Many organizations lack a unified role-to-access mapping that can be enforced across on-prem, cloud, and SaaS environments.
  4. Legacy / Non-SCIM Applications
    • Critical systems outside SCIM or SSO often require manual account management, introducing errors and delays.
    • Manual provisioning steps that bypass governance entirely.
      (SCIM means “System for Cross-domain Identity Management” which is the open standard for automated provisioning.   And SSO means “Single Sign On”)
  5. Compliance Blind Spots
    • Logging that can be altered, siloed reporting, or incomplete audit trails erode trust in incident response and compliance attestations.
  6. Weak Segmentation
    • Network boundaries (e.g., VLANs) without identity context allow devices and users to “wander” into systems they shouldn’t.

A CISO’s Non-Negotiables

If you want to materially reduce identity-driven risk, your program must ensure:

  • Every identity has an owner: whether human, device, or agent.
  • Provisioning/deprovisioning is policy-driven and automated: no manual lag points.
  • Segmentation is identity-aware, not location-aware: access follows the identity, not the IP address.

Identity Personas as a Governance Accelerator

Defining identity personas speeds access policy design, micro-segmentation, and review cycles.

PersonaExamplesGovernance Focus
Human EmployeeStaff, contractors, partnersHR-linked JML, role-based access, MFA, immutable logs
Non-Human DeviceMedical device, factory robot, kioskAsset inventory, micro-segmentation, cert/key rotation
Agent AICopilot extension, RPA bot, API agentConsent tracking, least privilege, just-in-time access

Micro-Segmentation: The Great Equalizer

Identity-aware segmentation enforces least privilege without breaking the business:

  • Human: Finance analyst can only reach ERP, reporting tools, and approved collaboration apps anywhere they connect.
  • Non-Human: Warehouse IoT scanner can only talk to inventory API and update server nothing else.
  • Agent: AI summarizer can only pull from one SharePoint library and only during an active workflow.

Policies travel with the identity, anomalies trigger isolation, and access scope is defined by persona.

From Risk to Readiness: The Quisitive Path

We help organizations operationalize these principles:

  • Role-Based Access Matrix: Enforced across cloud, SaaS, and legacy.
  • Custom Integration for Non-SCIM Apps: No more “manual exceptions.”
  • Immutable Logging: Tamper-proof trails for compliance and forensics.
  • Agent ID Governance: Classification, consent tracking, behavioral monitoring.
  • Micro-Segmentation Blueprint: Persona-based policy mapped to enforceable rules.

If identity is your perimeter, governance is the wall, then every unmanaged identity or unsegmented pathway is an open gate.

HealthSec 2025 keynote presentation

Action Items

  1. Inventory all identities: human, device, agent.
  2. Assign ownership and define lifecycle rules.
  3. Think Zero-Trust.
  4. Automate provisioning/deprovisioning across all systems.
  5. Implement identity-based segmentation tied to personas.
  6. Audit and adapt continuously.

Quisitive can help you get there faster, securely, and with measurable ROI.

Closing Thought

Security leaders are judged not on the absence of incidents, but on the presence of resilience. That resilience is built when governance spans every identity type, segmentation follows the identity, and every access path is justified and accountable.

Till next time,

Ed

Make sure to check out the other blogs in this series: