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Policy template

Access Control Policy

Covers identity management, privileged access, and access reviews.

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Policy
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Access governance

Writing an access control policy that holds up in an audit

Access control is where policy and operations collide most visibly. Auditors do not stop at reading the policy; they pull a list of leavers and check whether accounts were disabled, pull an admin group and ask who approved each member, and compare the last access review against the date the policy promised. A usable access control policy is therefore specific about timings, approvals, and review cycles. This template gives you a starting structure to fill in with the rules your identity team can actually meet.

The principles the policy should establish

  • Least privilege. Users get the minimum access needed for their role, and nothing by default.
  • Need to know. Access to sensitive data is granted for a business reason, not because someone is senior.
  • Segregation of duties. Conflicting functions, such as requesting and approving access or developing and deploying to production, are split (ISO 27001 Annex A 5.3).
  • Unique identities. No shared accounts for humans; service accounts have named owners.
  • Role-based access where possible. Access is granted by role or group rather than individually, which makes reviews tractable.

Rules across the identity lifecycle

Most audit findings in this area come from the lifecycle, not from the principles. Write each stage as a rule with a trigger, an approver, and a time limit, so it can be tested. The timings below are illustrative starting points; pick values your HR and IT processes can reliably hit.

Joiner, mover, leaver: what to define

Joiner, mover, leaver: what to define
JoinerSigned offer or HR record createdAccess requested by the manager, approved by the system owner, provisioned by role; no access before the start dateTicket or workflow record with approval preceding provisioning
MoverRole or department change in HR systemNew access approved; access from the old role removed within a defined window, for example 5 business daysChange ticket plus before-and-after group membership
LeaverTermination date in HR systemPrimary identity disabled on or before the last working day; involuntary exits disabled immediatelyHR termination report reconciled against IdP disable timestamps
Dormant accountsNo login for a set periodAccounts disabled after inactivity, for example 90 days, which matches PCI DSS 8.2.6Automated report or job log
Third partiesContract start and endAccess sponsored by an employee, time-bound, and reviewed with the vendor relationshipSponsor record and expiry dates

Privileged access and authentication

Privileged accounts deserve their own section because they are where a compromise does the most damage. ISO 27001 Annex A 8.2 requires privileged access rights to be restricted and managed. Good policy language separates admin accounts from day-to-day accounts, requires multi-factor authentication for all privileged and remote access, prefers just-in-time elevation over standing admin rights, and logs privileged activity. Break-glass accounts should be documented, vaulted, alerted on use, and have their credentials rotated after each use.

For authentication, reference a separate standard for password and MFA settings rather than hard-coding them here. If you are in PCI DSS scope, Requirement 8 sets specific expectations, including MFA for all access into the cardholder data environment. The access control policy itself should sit beneath, and reference, your top-level information security policy.

Access review cadence

Access type, Suggested review frequency, Reviewer comparison
Production infrastructure and cloud admin rolesQuarterlySystem owner plus security
Systems holding customer or regulated dataQuarterly or semi-annuallyData or system owner
Cardholder data environment (PCI DSS 7.2.4)At least once every six monthsManagement
Business applications with standard dataSemi-annually or annuallyApplication owner
Service and API accountsAnnually, plus on owner departureNamed account owner

Where the policy maps across frameworks

Framework, References comparison
ISO/IEC 27001:2022Annex A 5.15 access control, 5.16 identity management, 5.17 authentication information, 5.18 access rights, 8.2 privileged access rights, 8.3 information access restriction, 8.5 secure authentication
SOC 2CC6.1 logical access security, CC6.2 user registration and removal, CC6.3 role-based authorization and least privilege
NIST CSF 2.0PR.AA identity management, authentication, and access control
HIPAA Security Rule§164.308(a)(4) information access management; §164.312(a)(1) access control; §164.312(d) person or entity authentication
PCI DSS 4.0.1Requirement 7 restrict access by business need to know; Requirement 8 identify users and authenticate access

Terms like control and Annex A are defined in the glossary if you are mapping this for the first time.

How auditors test access control

  1. Obtain a list of terminations for the period from HR and compare disable dates in the identity provider against the policy's deadline.
  2. Sample new hires and look for an approval recorded before access was granted.
  3. Pull membership of admin groups and ask for the justification and approver of each member.
  4. Inspect the most recent access reviews for completeness, reviewer identity, and follow-through on removals.
  5. Check MFA enforcement settings in the identity provider rather than relying on a screenshot of the policy.

Much of that evidence can come directly from systems of record. Identity integrations such as Okta, Entra ID, and SailPoint, alongside HR sources like Workday and BambooHR, are part of the integrations catalog, which lets leaver reconciliation become a continuous check rather than a scramble before fieldwork.

Mistakes to avoid

  • Promising same-day deprovisioning when HR notifies IT a week late.
  • Treating SaaS applications outside SSO as out of scope for reviews.
  • No owner for service accounts, so nobody can say whether they are still needed.
  • Access reviews that cover the identity provider but not the permissions inside each application.
  • Exceptions granted by email with no expiry date.

FAQ

Frequently asked questions

What should an access control policy include?

At minimum: the principles of least privilege and segregation of duties, rules for provisioning, changing, and removing access with timings and approvers, privileged access requirements, authentication expectations such as MFA, access review frequency and reviewers, third-party access rules, and how exceptions are approved and recorded.

How often should user access reviews happen?

It depends on risk. A common pattern is quarterly for privileged and production access, semi-annual or annual for lower-risk business applications. PCI DSS 4.0.1 Requirement 7.2.4 sets a minimum of once every six months for in-scope user accounts. Whatever you choose, write it in the policy and keep evidence of each review.

Which ISO 27001 controls cover access control?

In ISO/IEC 27001:2022 Annex A, the core controls are 5.15 access control, 5.16 identity management, 5.17 authentication information, and 5.18 access rights, supported by technological controls 8.2 privileged access rights, 8.3 information access restriction, and 8.5 secure authentication. Segregation of duties is covered separately in 5.3.

How quickly must leavers lose access?

No major framework sets a single universal deadline for all systems, so the policy must define it. Many organizations disable the primary identity on or before the last working day and immediately for involuntary terminations. The key audit test is whether actual disable times match what the policy says.

Should the policy specify password length and MFA settings?

It is usually better to state the requirement in the policy, for example that MFA is required for remote and privileged access, and place exact settings in a supporting authentication standard. That way technical parameters can be updated without re-approving the policy, while still being documented and controlled.

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