In regulated industries, segregation of duties is often required either explicitly in the wording of the regulation (for instance, in the case of PCI DSS) or by auditors. However, implementing this control does not require the use of a CAB or separate operations team. There are two mechanisms which can be effectively used to satisfy both the letter and the spirit of this control. First, when any kind of change is committed, somebody who wasn’t involved in authoring the change should review it either before or immediately following commit to version control. This can be somebody on the same team. This person should approve the change by recording their approval in a system of record such as GitHub (by approving the pull request) or a deployment pipeline tool (by approving a manual stage immediately following commit). Second, changes should only be applied to production using a fully automated process that forms part of a deployment pipeline. 1 That is, no changes should be able to be made to production unless they have been committed to version control, validated by the standard build and test process, and then deployed through an automated process triggered through a deployment pipeline. As a result of implementing a deployment pipeline, auditors will have a complete record of which changes have been applied to which environments, where they come from in version control, what tests and validations have been run against them, and who approved them and when. A deployment pipeline is, thus, particularly valuable in the context of safety-critical or highly regulated industries.
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