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 called | logical access policy, user access policy |
|---|---|
| Family | Access and identity |
| Document type | Policy. 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 owner | The information security lead (CISO or ISMS manager). |
| Review cadence | Annual (the register's default: the clauses say planned intervals and on significant change, and do not fix a period). |
| On the gap list when | ISO 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). |
| Template | Access control policy. |
Which standards require it, and what each expects it to contain
5 requiring clauses, 4 regimesShown 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 controlSet 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.
Common gap: Infrequent review of access rights
Source: ISO/IEC 27001:2022; guidance ISO/IEC 27002:2022
ISO 27001 5.18 Access rightsProvision, 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.
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 rightsThe 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.
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 preventionFinancial 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).
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 managementThree 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.
Common gap: Leaver process that covers directory accounts but not federated or cloud services
Source: NIS2 Directive
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