Policy Register

Access control policy

Who may access which information and systems, on what basis, how access is granted, reviewed and removed.

How the register reads it

Also calledlogical access policy, user access policy
FamilyAccess and identity
Document typePolicy. The regimes ask for the content, not the label; a line pasted as a standard, procedure, plan or schedule is placed here with the label noted.
Expected ownerThe information security lead (CISO or ISMS manager).
Review cadenceAnnual (the register's default: the clauses say planned intervals and on significant change, and do not fix a period).
On the gap list whenISO 27001 or NIS2 or DORA is ticked and no line resolves to it (ISO 27701 requires it too, inside a parent document, so it does not list it separately).
TemplateAccess control policy.

Which standards require it, and what each expects it to contain

5 requiring clauses, 4 regimes

Shown on a register for the regimes you tick; with none ticked, ISO 27001 is applied. Requirement text drawn from a human-verified compliance corpus under licence: the corpus statement of each clause, not the instrument verbatim.

ISO/IEC 27001:2022

ISO 27001 5.15 Access control

Set rules for physical and logical access based on business and security requirements.

What the ISO 27002 guidance expects the document to say: Requires rules governing access to information and the assets tied to it, covering both physical entry and logical access, to be established and implemented on the basis of business need and security requirements.

Evidence an auditor accepts: The access control policy and the specific rules derived from it, expressed per information asset or asset group; evidence the rules reflect business need and the classification of the information rather than convenience; the mapping from rules to enforcement points, covering logical systems and physical areas
Common gap: Infrequent review of access rights
Source: ISO/IEC 27001:2022; guidance ISO/IEC 27002:2022
ISO 27001 5.18 Access rights

Provision, review, modify and remove access rights in line with the access control policy.

What the ISO 27002 guidance expects the document to say: Requires access rights to information and other associated assets to be provisioned, reviewed, modified and removed in accordance with the organisation's topic specific policy and rules on access control.

Evidence an auditor accepts: Provisioning records showing the authorisation behind each access grant, tied to the access control rules; modification records where access changed after a role change, showing removal of the previous entitlements; removal records on termination, with the date of removal against the date of departure
Common gap: Reviews lack documented corrective actions
Source: ISO/IEC 27001:2022; guidance ISO/IEC 27002:2022

ISO/IEC 27701:2025

ISO 27701 A.3.9 Access rights

The organization shall maintain an accurate, up-to-date record of the user profiles created for users authorised to access information systems and the PII they contain, the profile comprising the data about the user, including the user identifier, needed to implement the technical controls that provide authorised access. Individual user identifiers shall be used so that appropriately configured systems can identify who accessed PII and what additions, deletions or changes they made, which protects users as well as the organization. Where the organization provides PII processing as a service and the customer is responsible for some or all access management, the organization shall where appropriate provide the customer the means to perform it, such as administrative rights to manage or terminate access, and document such cases.

Evidence an auditor accepts: Current user profile record supporting attribution of access and change; individual identifiers enforced on systems processing PII, with shared accounts prohibited; administrative means provided to customers to manage access, and the responsibility split documented
Common gap: Shared or generic accounts on systems holding PII
Source: ISO/IEC 27701:2025

DORA (Regulation (EU) 2022/2554)

DORA Art. 9 Protection and prevention

Financial entities shall continuously monitor and control the security and functioning of ICT systems and tools, and minimise ICT risk through appropriate ICT security policies, procedures, protocols and tools ensuring resilience, continuity and availability, and preserving confidentiality, integrity and authenticity of data (incl access management, encryption, secure configuration, network security).

Evidence an auditor accepts: ICT security policies and protective controls (access, encryption, configuration, network); evidence preserving CIA of data
Common gap: Weak or absent protective controls
Source: DORA (Regulation (EU) 2022/2554)

The NIS2 Directive

NIS2 Art. 21(2)(i) Human resources security, access control policies and asset management

Three linked disciplines sit in one point because they fail together. Human resources security covers screening proportionate to the role, security terms in employment, and the leaver process. Access control policy covers how identities are created, what rights they carry, how privileged access is granted and reviewed, and how rights change when a person moves internally. Asset management covers knowing what the entity has, who owns it, how it is classified and what happens at disposal. The join between them is where evidence is usually thin: a leaver process that reclaims the laptop but not the cloud account, or an access review run against a directory that does not include the systems that matter. Internal movers are a sharper test than leavers, because accumulated rights are rarely removed.

Evidence an auditor accepts: Screening policy and records proportionate to role sensitivity; joiner, mover and leaver procedure with timed evidence of access removal; access control policy plus periodic access review results, including privileged accounts
Common gap: Leaver process that covers directory accounts but not federated or cloud services
Source: NIS2 Directive

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