ISO 27001 Access Control Policy Explained + Template

ISO 27001 Access Control Policy

In this guide, you will learn what an ISO 27001 Access Control Policy is, how to write it yourself and I give you a template you can download and use right away.

Key Takeaways

• Confidentiality Protection: Implementing access control is the most critical measure for safeguarding the confidentiality of organisational information assets.
• Compliance Alignment: Access control frameworks must be strictly aligned with legal, regulatory, and contractual obligations, as well as internal information classification policies.
• Technical and Educational Hybrid: Effective access security is achieved through a robust combination of technical system controls and comprehensive user education.

What is an ISO 27001 Access Control Policy?

The ISO 27001 access control policy outlines how to manage and control access to organisational resources including data and systems. The policy covers the entire user access lifecycle and it ensures the correct access to the correct information and resources by the correct people. The objective is to limit access to information and systems based on need, the principle of least privilege and need to know.

Access Control Principles

Access control is based on 4 simple principles:

Fundamental ISO 27001 Access Control Principles

Principle	Description
Need to Know	Users are only provided access to the information and systems they require to perform their tasks and role.
Least Privilege	The level of access provided to users is the minimum they need to perform their tasks, minimising the impact of a compromised account.
Segregation of Duty	Processes and functions are divided among different individuals to prevent unchecked access and ensure critical tasks cannot be compromised without detection.
Role Based Access (RBAC)	System access is restricted based on individual roles, simplifying management and enforcing security protocols across the organisation.

Access Control Methods

There are 3 primary methods to control access. They are

Primary ISO 27001 Access Control Methods

Method	Description and Examples
1. Authentication	Granting access based on identity verification via something a person is, knows, or possesses. Multi-Factor Authentication (MFA) combines these, using biometrics, passwords, or security tokens.
2. Authorisation	The formal process where a system or information owner grants specific access rights based on an individual’s verified identity and organisational role.
3. Physical Access Control	Security measures and physical barriers designed to restrict or prevent unauthorised access to sensitive locations and systems, such as locks, gates, fences, and walls.

Access Control Considerations

When defining the policy and processes of access control the following considerations should be taken into account:

Key Considerations for Defining an ISO 27001 Access Control Policy

Consideration	Requirement and Implementation Details
Business Requirements	Access control must remain strictly in line with the specific requirements of the organisation and its defined information security objectives.
Compliance	Policies must ensure that access control fully meets all relevant legal, regulatory, and customer contractual requirements.
Information Classification	Access control implementation should be directly mapped to the organisation’s Information Classification Policy to ensure appropriate protection levels.
Remote Access	The policy must define secure methods for remote access, including the use of Virtual Private Networks (VPNs), multi-factor authentication (MFA), and secure remote desktop protocols, while specifying approved devices.
Cloud and Third Party Services	Security controls must extend to cover third-party services, cloud platforms, and outsourced systems, ensuring contractual agreements reflect organisational security standards.

Access Management Lifecycle

The lifecycle of user access is

The ISO 27001 User Access Management Lifecycle

Stage	Description and Technical Requirements
1. Requesting Access	Identification of access requirements for systems or data by an individual or a manager on behalf of their team.
2. Approving Access	Formal approval by the system or data owner. Implementation of segregation of duty ensures the requester cannot approve their own access.
3. Implementing Access	Technical provisioning by IT professionals. Focuses on Role-Based Access Control (RBAC) rather than cloning existing users to prevent unauthorised privilege creep.
4. Managing Changes	Revision of access rights necessitated by role changes or internal transfers, triggering a new request and approval cycle.
5. Reviewing Access	Regular audits (typically monthly) conducted by system owners to evidence that access remains relevant and catching instances of “stale” accounts.
6. Logging and Monitoring	Continuous recording of successful and failed access attempts. Logs must be reviewed monthly with incidents escalated via the formal incident management process.
7. Revoking Access	Prompt removal of access rights upon role change or termination of employment, documented through a formal approval and action trail for audit purposes.

ISO 27001 Access Control Policy Example

This is an example ISO 27001 Access Control Policy:

How to write an ISO 27001 Access Control Policy

The ISO 27001 Access Control Policy is required to be presented in a certain way. What we mean by that is that the policy is expected to have certain document markup. Document mark up is just a fancy words for having certain information on the policy. It will need version control, a version number, an owner, an information security classification.

To implement an ISO 27001 Access Control Policy, you must define clear access requirements based on business needs, formalise a “least privilege” framework, and implement robust identity management including MFA. This ensures only authorised users access specific data, satisfying Annex A security controls and reducing the risk of data breaches.

ISO 27001 Access Control Policy Walkthrough Video

ISO 27001 Access Control Policy Template

The ISO 27001 Access Control Policy template is pre written and ready to go. It is one of the required ISO 27001 policies that sets out the organisations approach to access control.

Why is the ISO 27001 Access Control Policy Important?

A cornerstone of information security is confidentiality and providing the right access to the right people at the right time. We want to ensure that people have access to do their job but no more. We want to protect the information and data that we have.

People will talk about preventing unauthorised access which is a fancy way of saying getting access to data they should not have. By protecting the access to the data we can reduce the risk of information security incidents and data breaches.

The ISO 27001 Access Control Policy is important as it sets out clearly and in written form what you expect to happen. If you don’t tell people what you expect of them then how can you expect them to do it? Communicating what is expected is a key step in any HR disciplinary process with many not being enforceable or actionable if you have not told people what to do and got them to accept that they understand what is being asked.

The ISO 27001 standard wants you to have the access control policy in place, communicated, and accepted by staff as part of your ISO 27001 certification. It actually forms part of a wider set of required information security policies that are all included in the ISO 27001 toolkit.

Benefits of implementing an ISO 27001 Access Control Policy

The main benefit is that it allows you to mitigate the risk of access to systems and data. Access poses unique challenges as it is the primary way people gain entry to systems and data to perform their role so the risks need to be assessed and appropriate controls implemented. The benefits of implementing an ISO 27001 Access Control Policy include:

• Unauthorised Access Mitigation: Access to data is restricted exclusively to approved individuals with a verified business need, significantly reducing the risk of data breaches.
• Regulatory Compliance: Formal access controls ensure the organisation meets stringent legal and regulatory requirements concerning data protection and information security.
• Confidential Information Protection: Robust policy frameworks safeguard sensitive information assets by enforcing strict “Need to Know” and “Least Privilege” principles.
• Stakeholder Trust: Implementing transparent and secure access management builds confidence with employees, clients, and third-party partners.
• Reputation Protection: Effective controls reduce the likelihood of security incidents, minimising potential fines and protecting the brand’s public image during an event.

Access Control in Practice

The ISO 27001 Access Control Policy is all about access to systems and data. When looking at access we are looking at the different types of access. We differentiate between normal users and administrators.

First things first we want to ensure that we have confidentiality agreements in place and being required to access systems. This may form part of employment contracts. It makes sense to grant access to systems based on roles where the role defines the level of access that is allowed. We want to ensure that we can track actions back to individuals so the concept of one user and one ID is introduced. If we have shared accounts it can be nearly impossible to track back who exactly did what. This can become critical if incidents occur and we need to conduct investigations. Users of systems are responsible for their actions.

System access is not a one time deal. We will have a start, leaver, mover process that covers the provision of access, the changes to access as roles change and the removal of access when someone leaves. To ensure that all is working as planned we are going to conduct regular access reviews. An access review is as simple as seeing who has access to systems, what level of access they have and confirming that they still need it. If they don’t, or they have changed role, or they have left and the normal processes hasn’t caught it then we handle it at that point.

Our most powerful users are administrators. They hold the keys to the kingdom. There are special considerations when it comes these administrative accounts. How they are allocated, when they are allocated, how they are used, how they are monitored is addressed.

We all use passwords and the rules for passwords are set. How passwords are created, how complex do they need to be, how often if at all are they changed, how are they communicated to users. Passwords are the keys to the doors of our systems and data so we are clear on their management and use.

Often times we rely on third parties or suppliers to help support and run our systems. We want to grant them the access that they need, when they need it to help us. We set out the policy and rules for their access. We also address remote access of all users.

How the ISO 27001 toolkit can help

An ISO 27001 toolkit is like a toolbox full of pre-made documents and guides. It gives you a head start on creating your policy and other important security documents, saving you a ton of time and effort. It’s a great way to make sure you don’t miss anything.

ISO 27001 Toolkit vs. Online SaaS Platforms: Implementing Access Control

Feature	ISO 27001 Toolkit (Templates)	Online SaaS Platforms
Ownership	Lifetime Ownership: You keep your policy files forever on your own infrastructure. You don’t rent your compliance.	Temporary Access: Your documentation lives on their servers. If you stop paying, you lose access to your data.
Simplicity	No Learning Curve: Uses familiar Microsoft Word and Excel formats. No need to train your team on complex new software.	High Complexity: Requires significant time for staff onboarding, technical training, and software configuration.
Cost	One-Off Fee: A single, transparent payment with no recurring costs or hidden “per-user” charges.	Ongoing Subscription: Expensive monthly or annual fees that increase as your organisation grows.
Freedom	No Vendor Lock-in: Complete control over your documentation. Easily portable and fully customisable to your needs.	Proprietary Lock-in: Extremely difficult to migrate your data out of the platform once you are embedded.

Applicability of an ISO 27001 Access Control Policy to Small Businesses, Tech Startups, and AI Companies

Applicability and Examples of ISO 27001 Access Control Policy by Business Type

Business Type	Strategic Value	Practical Implementation Examples
Small Business	Protects critical customer data (contact info, payment details) to prevent business-ending data breaches.	Restricting financial data access exclusively to the owner and accountant. Segmenting user accounts so sales staff cannot access sensitive payroll records.
Tech Startups	Safeguards intellectual property and “secret sauce” (source code) from internal and external unauthorised access.	Limiting main code repository access to senior developers while providing juniors with sandboxed environments. Enforcing universal Multi-Factor Authentication (MFA) across all work accounts.
AI Companies	Manages risks associated with massive, sensitive datasets used for training and inference.	Limiting raw training data access to specific data scientists assigned to a project. Implementing comprehensive logging to track and audit every instance of sensitive dataset access.

Information security standards that need an ISO 27001 Access Control Policy

This access control policy is a key part of ISO 27001, which is an international standard for managing information security. Other standards that need it include:

Global Information Security Standards Requiring an Access Control Policy

Standard / Regulation	Relevance to Access Control
ISO 27001	The primary international standard requiring a formal policy to manage and audit user access rights.
GDPR	Mandates strict controls over who can access personal data to ensure privacy and prevent unauthorised processing.
CCPA	Requires businesses to implement reasonable security procedures, including access restrictions, to protect consumer data.
DORA	Demands digital operational resilience in the financial sector through robust identity and access management (IAM).
NIS2	Focuses on the security of network and information systems, necessitating strict access protocols for critical infrastructure.
SOC 2	A framework for service organisations where ‘Access Control’ is a core Trust Services Criterion (TSC).
NIST	The Cybersecurity Framework (CSF) emphasizes ‘Identify’ and ‘Protect’ functions through granular access management.
HIPAA	Requires technical safeguards to ensure only authorised personnel access Protected Health Information (PHI).

List of relevant ISO 27001:2022 controls

The ISO 27001:2022 standard has specific controls that relate to access control. Some of the most important ones include:

Key ISO 27001:2022 Annex A Controls for Access Control

Control Reference	Control Name and Implementation Context
Annex A 5.15	Access Control: Establishes the rules for granting access to information and other associated assets based on business and security requirements.
Annex A 5.16	Identity Management: Managing the full lifecycle of digital identities to ensure users are uniquely identified and accountable.
Annex A 5.17	Authentication Information: Ensuring that authentication information (passwords, tokens, biometrics) is managed securely through a formal process.
Annex A 5.18	Access Rights: Provisioning, reviewing, modifying, and revoking access rights to ensure they remain appropriate and authorised.
Annex A 8.4	Access to Source Code: Restricting access to program source code and associated items to prevent unauthorised modification or disclosure.
Annex A 8.5	Secure Authentication: Implementing strong authentication controls, such as MFA, based on the classification of information and risk assessment.
Annex A 8.11	Data Masking: Using techniques like pseudonymisation or anonymisation to restrict the visibility of sensitive data to unauthorised users.

ISO 27001 Access Control Policy FAQ