Access Control Policy

Rules for who may reach the Organisation's information and systems, how access is granted, reviewed, logged and removed.

SXL-A04Policy3,376 words 15 min readOwner: Head of IT Security
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Template draft. Replace everything in [square brackets] with your own decision, delete what does not describe what you really do, and approve it through your own document control. It is not legal advice and does not make an organisation compliant or certified.

1. Purpose

This policy sets the rules that decide who may see, change or use the Organisation's information, systems, networks and premises, and under what conditions. Its aim is that every person and every system process gets the access needed for a defined business purpose, nothing more, for no longer than needed, and that each grant can be traced to an approval and each use can be traced to an identity.

The detailed steps are in the User Access Management Procedure. This policy states the rules those steps must satisfy and gives a short summary of the access lifecycle so that managers can see the whole picture in one place.

2. Scope

The policy applies to every user identity, human or non-human, that can reach information assets owned or held by the Organisation, wherever those assets sit.

  • In scope: employees, contractors, consultants, interns, temporary staff, suppliers' staff and customers' staff who are given an account, badge, key, token or certificate.
  • In scope: all information systems, applications, databases, operating systems, network devices, cloud services, code repositories, shared drives, collaboration tools and physical areas holding information.
  • In scope: service accounts, application programming interface keys, shared mailboxes, test accounts and any other non-human identity.
  • In scope: remote, on-site and cloud access, and access from personally owned devices that the Organisation permits.
  • Out of scope: public web content intended for anyone to read and customer-facing sign-in rules for the Organisation's own products, which follow the product security requirements. Customer data inside those products stays in scope for staff access.

3. Terms and definitions

TermMeaning
IdentityA unique record, such as a user ID, that stands for one person or one process in a system.
AccountThe set of credentials and permissions through which an identity uses a system.
Least privilegeGiving an identity only the permissions needed for its current duties.
Need to knowAccess to a piece of information only where the duty cannot be done without it.
Privileged accountAn account able to change system configuration, security settings, other accounts or other users' data, for example a domain administrator or database administrator.
Service accountA non-human account used by an application or script to talk to another system.
Break-glass accountA sealed emergency account used only when normal administrator access is unavailable.
System ownerThe named person accountable for a system and for approving who may use it.
Multi-factor authenticationSign-in that needs two or more independent proofs, such as a password plus a code from an approved device or a hardware key.
Access reviewA scheduled check by the system owner that each account and permission is still needed and correct.

4. Roles and Responsibilities

RoleResponsibilities
Top managementApproves this policy, provides resources for access control tooling, and receives the access review summary at management review.
Head of IT Security (document owner)Maintains this policy, sets technical standards for authentication and privileged access, reports on access control effectiveness, and approves exceptions with the risk owner.
System ownerDecides who may have access to the system and at what level, approves or rejects requests, and completes access reviews on time.
Line managerRequests access for team members for a stated purpose, confirms continuing need, and tells HR and IT at once when duties or employment change.
IT service deskCreates, changes, disables and deletes accounts only against an approved request, and records each action.
System administratorsApply the access model on the systems they run, keep privileged account use traceable, and report anomalies.
Human ResourcesProvides the authoritative joiner, mover and leaver feed and confirms dates of exit.
Facilities and securityIssue and recover badges and keys and keep the physical access list aligned with the logical one.
Every userProtects credentials, uses only the access granted, and reports lost devices, shared credentials and unexpected access.
ActivityResponsibleAccountableConsultedInformed
Approve this policyHead of IT SecurityTop managementSystem owners, HRAll staff
Approve an access requestSystem ownerSystem ownerLine manager, IT securityRequester
Create or change an accountIT service deskHead of ITSystem ownerLine manager
Remove access on exitIT service deskHead of ITHR, line managerSystem owner
Perform periodic access reviewSystem ownerHead of IT SecurityLine managersInternal audit
Manage privileged accountsSystem administratorsHead of IT SecuritySystem ownerTop management
Monitor and investigate access logsSecurity operationsHead of IT SecuritySystem ownerIncident manager
Grant an exceptionHead of IT SecurityRisk ownerSystem owner, complianceTop management

4.1 Accountability notes

The system owner, not IT, is accountable for who has access to a business system. IT is responsible for carrying out approved changes correctly. Where a system has no named owner, the Head of IT Security acts as owner until one is appointed, and the gap is recorded as an issue in the asset register.

5. Access Control Policy Statements

5.1 Principles

  • Access is granted on a need-to-know and least-privilege basis, tied to a role and a stated business purpose.
  • Everything is denied unless it is explicitly allowed. Default accounts and default permissions are removed or disabled on installation.
  • Every identity is unique to one person or process. Shared personal accounts are not permitted; where a shared function is unavoidable it uses a shared mailbox or a checked-out credential in a password vault with individual attribution.
  • Duties are separated so that no single person can request, approve and implement a sensitive change or payment alone.
  • Access follows the classification of the information as set in the Information Classification and Handling Policy: the higher the classification, the tighter the approval and review.
  • Role-based access is the default. Roles are defined by system owners and reviewed at least [every 12 months]; individual exceptions to a role are approved and recorded.

5.2 Authentication

  • Every account must authenticate before reaching any non-public resource.
  • Passwords must be at least [14 characters], not on a list of known breached passwords, and unique to the Organisation. Forced periodic change is not required unless compromise is suspected; the password must change at once on suspicion of compromise.
  • Multi-factor authentication is mandatory for remote access, for all administrator and privileged accounts, for email and collaboration tools, for code repositories and for any system holding [Confidential] or higher information.
  • Accounts lock after [5] failed attempts and unlock only through a verified process or after [15 minutes].
  • Credentials are stored only as salted hashes or in an approved password vault. They must never be sent in plain text, written down in an open place, or embedded in source code or documents.
  • Session timeouts: idle screens lock after [10 minutes]; remote and administrative sessions end after [30 minutes] of inactivity.

5.3 Network and remote access

  • Remote access to internal resources uses an approved secure channel with multi-factor authentication and a device that meets the Mobile Device and Teleworking Policy.
  • Administrative interfaces are not exposed to the internet. They are reachable only from management networks or through a bastion or equivalent controlled path.
  • Wireless networks for guests are separate from internal networks.

5.4 Third-party and customer access

  • Suppliers and customers receive named accounts with the minimum scope, a sponsor inside the Organisation, and an end date no later than [12 months], renewable on request.
  • Supplier access to production systems or customer data is granted only where the supplier agreement covers confidentiality and security obligations, as set out in the Supplier Relationship Management Policy.
  • Supplier support sessions are enabled for the time needed and observed or recorded where the system holds [Confidential] data.

5.5 Source code and development environments

  • Write access to production code branches is limited to approved maintainers and requires peer review before merge.
  • Developers do not hold standing access to production data. Production access for fault finding is time-limited and approved as an emergency or privileged request.
  • Secrets, keys and tokens live in a secrets management tool and are never committed to repositories.

5.6 Physical access

Physical access to offices, server rooms and storage is granted on the same least-privilege principle and is detailed in the Physical and Environmental Controls Policy. HR leaver notices trigger badge and key recovery in the same step as account removal.

6. User Access Lifecycle Summary

This section summarises how access is created, approved, recorded, logged, reviewed and removed. The numbered steps, forms and time targets are in the User Access Management Procedure. In any difference, the stricter rule applies until the owner of the document resolves it.

6.1 Creation of a user account

  • An account is created only against a request recorded in [the ticketing tool], raised by the line manager or HR for a named person, naming the systems, role and business reason.
  • The default for a new joiner is the standard access bundle for the role. Anything beyond the bundle needs the system owner's approval.
  • The service desk creates the account within [1 working day] of full approval, sets a one-time initial credential delivered separately from the user name, and forces change at first sign-in.
  • User names follow one naming convention, are never reused for another person, and do not reveal privilege level.
  • Pre-employment screening under the HR Security Policy must be complete before access to [Confidential] systems is given.

6.2 Approval of access

Approval is proportionate to the sensitivity of what is being reached. The approver must be someone other than the requester, and the person who implements the change must not be the sole approver.

Access typeApproverTarget timeExtra evidence
Standard role bundleLine manager[1 working day]HR joiner record
Additional business application accessSystem owner[2 working days]Business reason in the request
Access to Confidential or Restricted dataSystem owner and data owner[3 working days]Training completed, need-to-know note
Privileged or administrator accessSystem owner and Head of IT Security[3 working days]Named task or role, end date, multi-factor method
Supplier or external accessSponsor, system owner and Head of IT Security[5 working days]Signed agreement, end date
Emergency accessOn-call manager, ratified next working day[1 hour]Incident or change reference

6.3 Change of role and deletion of access

  • When a person moves role, the line manager raises a change request within [2 working days]. Access from the previous role is removed unless the new role needs it and the system owner confirms.
  • On exit, HR notifies the service desk before the last working day. Accounts are disabled at the agreed exit time, and no later than [end of the last working day], with immediate disablement for dismissal or any security concern.
  • Mailboxes and files are handed to the line manager as directed. Accounts are deleted after [90 days], unless a legal hold or investigation applies. Tokens, keys, badges, devices and vault entries known to that person are revoked or rotated the same day.
  • Dormant accounts with no sign-in for [60 days] are disabled and those inactive for [180 days] are removed after owner confirmation.

6.4 Recording of user IDs

  • A register of all accounts, whether kept in the directory, the identity tool or another source, records for each: unique ID, person or process, employer or sponsor, system, role, approver, start date, expiry date and status.
  • The register is reconciled with HR and supplier lists at least [monthly] and any orphan account is investigated within [5 working days].
  • Service accounts have a named human owner, a stated purpose, a rotation schedule for the secret and a record of every system they can reach.

6.5 Logging of access

  • Successful and failed sign-ins, privilege use, account changes, access to sensitive data stores and changes to permissions are logged on every in-scope system.
  • Logs are protected from alteration, synchronised to a common time source and kept for at least [12 months], and for ICT logs the period required by the CERT-In Directions of 28 April 2022 (180 days, held within Indian jurisdiction) [confirm the current requirement].
  • Alerts are defined for repeated failures, sign-ins from unusual places or at unusual times, creation of privileged accounts and use of break-glass accounts. Detail is in the Logging and Monitoring Policy.

6.6 Privileged user IDs

  • Administrators use a separate privileged account for administrative work and an ordinary account for email, browsing and documents. A privileged account is never used for daily tasks.
  • Privileged access is time-bound, approved per task or per period of no more than [90 days], and re-approved on expiry.
  • Where tooling permits, privileged access is obtained just in time, through a vault or privileged access tool that records the session.
  • Break-glass accounts are kept sealed, tested at least [every 6 months], monitored for any use, and the password is changed after each use. Every use is reviewed by the Head of IT Security within [1 working day].
  • The list of privileged accounts is reported to the Head of IT Security [monthly] and reviewed in full [every 3 months].

7. Access Requirements by Classification

The strength of control rises with the classification of the information reached. The table gives the minimum for each level; system owners may require more. Levels are defined in the Information Classification and Handling Policy.

LevelWho may be granted accessAuthenticationReview and logging
PublicAnyone, no sign-in needed for published materialNone for reading; staff sign-in to editEdit history kept
InternalStaff and approved contractors on a business needSingle sign-on with password policyAnnual review; sign-ins logged
ConfidentialNamed roles with need to know, approved by the system ownerMulti-factor authenticationSix-monthly review; reads and changes logged
RestrictedNamed individuals approved by the data owner and Head of IT SecurityMulti-factor authentication with a hardware or device-bound factorQuarterly review; every access logged and alerted on

8. Service Accounts and Machine Access

  • Service accounts and application keys are created only through a request that names the owner, purpose and systems reached, and are never used by a person to sign in interactively.
  • Secrets are held in a secrets management tool, not in code, scripts, tickets or chat messages, and are rotated at least [every 12 months] or at once when the owner leaves or compromise is suspected.
  • Each key or service account carries the minimum permission for its task and is scoped to the environment (development, test or production) it serves. Production credentials are never used in other environments.
  • Automated jobs that need production access run through the change process, and any change to their permissions follows the Change Management Policy and Procedure.

9. Emergency and Temporary Access

Emergency access may be given by the on-call manager when a service outage or a security incident cannot be handled without it. The grant is recorded at the time with the incident or change reference, expires automatically within [24 hours], and is ratified or reversed by the system owner on the next working day. Temporary access for projects, audits or investigations is limited to the dates stated in the request. Accounts without an expiry date are not permitted for external persons.

Note. An emergency grant never skips recording. A grant that is not recorded within one working day is treated as unauthorised access and handled through the incident process.

10. Handling Joiners, Movers and Leavers

The timeline below sets the maximum time between the trigger and the access action. HR is the authoritative source for starts, role moves and exits.

TriggerActionOwnerDeadline
Offer accepted and screening completeCreate account and standard bundle, held inactive until start dateIT service desk[Day before start]
Start dateActivate account, issue badge, hand over devices, confirm acceptable use acknowledgementIT service desk, Facilities[Day of start]
Role changeRemove old access, grant new bundle, update the registerIT service desk[2 working days]
Resignation noticeReview access to sensitive systems and plan handoverLine manager[Within 2 working days]
Last working dayDisable all accounts, recover devices and badge, revoke tokensIT service desk, Facilities[Same day]
Dismissal or security concernDisable at once, preserve logs and devicesHead of IT Security[Immediately]
Contract or sponsor expiryDisable external accounts unless renewedSponsor, service desk[Expiry date]

11. Access Review and Recertification

System owners confirm that access is still needed on the schedule below. Reviewers receive a list showing user, role, last sign-in and approval date. Access not confirmed within [10 working days] of the request is suspended until confirmed. Removals identified in a review are done within [2 working days].

PopulationFrequencyReviewerEvidence
Privileged and administrator accounts[Every 3 months]Head of IT SecuritySigned review sheet or tool report
Users of Confidential or Restricted systems[Every 6 months]System ownerReview sheet and removal tickets
All other business applications[Every 12 months]System ownerReview sheet
Supplier and external accounts[Every 3 months]SponsorConfirmation and expiry update
Service accounts and keys[Every 6 months]System ownerOwner, purpose and rotation check
Physical access lists for secure areas[Every 3 months]Facilities managerBadge list reconciliation

12. Segregation of Duties

Access must not let one person complete a risky sequence alone. System owners identify conflicting combinations for their systems and the Head of IT Security keeps the combined list. Where separation is impossible, for example in a small team, a compensating control such as independent review of logs or transactions is recorded and applied.

Conflicting combinationWhy it mattersRequired control
Request and approve own accessSelf-granting of rightsApprover must be a different person; tool blocks self-approval
Develop code and release it to productionUnreviewed change reaching customersSeparate release rights; peer review and approval before deployment
Create a supplier and approve its paymentFraud riskDifferent people in the finance system; monthly review of changes
Administer a system and administer its audit logsConcealment of actionsLogs sent to a store the administrator cannot alter
Create user accounts and approve access requestsUnauthorised accountsService desk creates accounts only on approved tickets
Hold both halves of an encryption keySingle-person decryption of dataSplit knowledge or dual control as the Cryptography Policy requires

13. Detection of Improper Access

Prevention is backed up by detection. Security operations maintain the alerts below, tune them at least [every 6 months], and investigate each alert within the target time.

AlertTriggerResponse target
Impossible travel or unusual location sign-inTwo sign-ins for one user from places that cannot be reached in the time[30 minutes] triage
Repeated failed sign-insMore than [10] failures in [10 minutes] for one or many accounts[30 minutes] triage
Privileged account created or elevatedAny addition to an administrator group[1 hour] to check ticket
Break-glass account usedAny sign-in[Immediate] page to on-call and Head of IT Security
Disabled or dormant account becomes activeSign-in on an account marked disabled or dormant[1 hour]
Mass download or unusual access to sensitive storesVolume above [3 times] the user's normal[4 hours]
Access outside approved hours for a restricted systemSign-in outside agreed window[4 hours]

14. Compliance and monitoring

The Head of IT Security checks adherence through the access review results, reconciliation of the account register with HR records, sampling of requests for complete approval evidence and log-based detection of improper use. Results are reported at least [quarterly] to top management and are an input to internal audit.

CheckFrequencyDone byAcceptable result
Orphan and leaver accounts still active[Monthly]IT security[0] older than [1 working day]
Requests approved before creation[Quarterly sample of 25]Internal audit[100%]
Privileged use outside approved window[Monthly]Security operations[0] unexplained
Access reviews completed on time[Per cycle]Head of IT Security[100%] completed, [95%] on time
Multi-factor coverage of required accounts[Monthly]IT security[100%]

15. Records and evidence

The following records are kept in [the document management system] and the ticketing tool for [3 years] unless the records schedule says otherwise:

  • Access requests with approvals, implementation and completion timestamps.
  • The account and privileged account registers, with monthly reconciliation outputs.
  • Access review sheets with removals and sign-off.
  • Break-glass use records, and supplier access and expiry records.
  • Exception approvals and the exceptions register.
  • Access logs for the period given in the Logging and Monitoring Policy.

Annexure A: Access request form

FieldEntry
Requester and date
Person who needs access (name, ID, employer)
System or area and level of access requested
Business reason and duration
Data classification touched
Line manager approval (name, date)
System owner approval (name, date)
Head of IT Security approval, if privileged or external
Implemented by and date
Confirmation to requester sent

16. Exception

Exceptions to this document are allowed only where compliance is not practicable and the risk has been assessed. A request must state what is to be excepted, why, the risk it creates, the compensating controls, and an end date no later than [6 months]. It is approved in writing by the document owner and the risk owner, recorded in the exceptions register, and reviewed at the end date. An exception does not change the document.

17. Enforcement

Compliance is monitored through internal audits, management review and routine checks by the document owner. Non-compliance is reported through the incident or non-conformity process and handled under the organisation's disciplinary procedure, and under the terms of any contract for people who are not employees. Serious or repeated non-compliance may lead to loss of access and, where the law is broken, to referral to the authorities.

18. Review

This document is reviewed at least every [12 months], and when there is a significant change to the organisation, its systems, its risks or the law, or after an incident that shows it was not effective. Each review is recorded in the revision history.

ISO/IEC 27001:2022 references

ReferenceTitle
A.5.15Access control
A.5.16Identity management
A.5.17Authentication information
A.5.18Access rights
A.8.2Privileged access rights
A.8.3Information access restriction
A.8.5Secure authentication
A.8.15Logging
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