Auditing ISO 27001 Annex A 8.3 Information Access Restriction is the technical evaluation of system-level controls that enforce data confidentiality across the enterprise. The Primary Implementation Requirement is the application of granular permissions based on the principle of least privilege, providing the Business Benefit of mitigating unauthorized data disclosure and internal privilege escalation.
ISO 27001 Annex A 8.3 Information Access Restriction Audit Checklist
This technical verification tool is designed for lead auditors to establish the technical enforcement of data confidentiality through system-level restrictions. Use this checklist to validate compliance with ISO 27001 Annex A 8.3.
1. Access Control Policy Enforcement Verified
Verification Criteria: A documented policy exists defining the rules for restricting access to information and system functions based on business and security requirements.
Required Evidence: Approved Access Control Policy with specific mentions of the “Need to Know” and “Need to Use” principles.
Pass/Fail Test: If there is no formalised policy governing the restriction of information access at the application or database level, mark as Non-Compliant.
2. Role-Based Access Control (RBAC) Alignment Confirmed
Verification Criteria: User access is assigned to logical roles rather than individuals, ensuring consistency and preventing “permission creep.”
Required Evidence: System role definitions and membership logs from Active Directory (AD) or IAM providers (e.g., Okta, Azure AD).
Pass/Fail Test: If users are found with direct, individual permissions that bypass established group roles, mark as Non-Compliant.
3. Database-Level Access Restrictions Validated
Verification Criteria: Access to sensitive databases is restricted to authorised applications or specific administrative users, preventing direct access by general personnel.
Required Evidence: Database user permission reports and firewall rules restricting SQL/NoSQL port access to authorised application IP ranges.
Pass/Fail Test: If general users or non-DBA IT staff possess direct “read” or “write” access to production database schemas, mark as Non-Compliant.
4. Sensitive System Function Segregation Verified
Verification Criteria: High-risk system functions (e.g., user deletion, log clearing, configuration changes) are restricted to a subset of privileged users.
Required Evidence: Application-level permission matrices showing the restriction of “Administrator” or “Superuser” functions.
Pass/Fail Test: If a standard business user account has the technical ability to modify system-level configurations or security logs, mark as Non-Compliant.
5. Dynamic Access Control (Conditional Access) Confirmed
Verification Criteria: Access is restricted based on dynamic factors such as geographic location, device health, and network origin.
Required Evidence: Configuration logs from Conditional Access policies (e.g., Microsoft Entra ID) showing blocks for non-compliant or unmanaged devices.
Pass/Fail Test: If sensitive systems are accessible from unmanaged personal devices or high-risk IP ranges without additional verification, mark as Non-Compliant.
6. Information Classification Masking Implementation Validated
Verification Criteria: Highly sensitive information (e.g., PII or card data) is masked or obscured for users who do not require the full data set for their role.
Required Evidence: System screenshots or API response logs demonstrating Data Masking (e.g., showing only the last 4 digits of a card or ID number).
Pass/Fail Test: If customer support staff can view unmasked sensitive PII (e.g., full SSN/Tax IDs) that is not required for identity verification, mark as Non-Compliant.
7. Source Code Access Restriction Verified
Verification Criteria: Access to program source code is restricted to authorised developers and protected against unauthorised modification or extraction.
Required Evidence: Repository access logs (GitHub/GitLab/Bitbucket) cross-referenced against the current developer list and active project teams.
Pass/Fail Test: If non-development personnel (e.g., Sales or Marketing) have “Read” access to production source code repositories, mark as Non-Compliant.
8. Physical Media Access Control Confirmed
Verification Criteria: Access to physical media containing sensitive information (e.g., backup tapes, removable drives) is restricted to authorised personnel only.
Required Evidence: Access logs for the media safe or off-site storage facility and a signed “Authorised Media Handler” list.
Pass/Fail Test: If sensitive physical media is stored in an unlocked or general-access cabinet, mark as Non-Compliant.
9. Shared Account Usage Restrictions Validated
Verification Criteria: Generic or shared accounts are prohibited or strictly controlled to ensure individual accountability for information access.
Required Evidence: Identity provider reports showing unique accounts for all human users; PAM (Privileged Access Management) logs for any required shared service accounts.
Pass/Fail Test: If multiple staff members share a single login for a sensitive application or server, mark as Non-Compliant.
10. Access Termination Timeliness Verified
Verification Criteria: Access to information and systems is revoked immediately upon termination of employment or change in role.
Required Evidence: HR leavers’ logs compared against IAM “Account Disabled” timestamps for the previous 90 days.
Pass/Fail Test: If a terminated employee retains active access to any sensitive system more than 24 hours post-exit, mark as Non-Compliant.
| Control Requirement | The “Checkbox Compliance” Trap | The Reality Check |
|---|---|---|
| Policy Enforcement | Tool checks if an “Access Control Policy” file is uploaded. | Auditor must verify that system settings (e.g., AD Group Nesting) actually mirror the written policy. |
| RBAC Integrity | Platform identifies “Users are in Groups.” | Verify Group Permissions. If a “Marketing” group has “Admin” rights on the production server, the GRC green tick is a lie. |
| Conditional Access | GRC tool identifies “MFA: Enabled” for the tenant. | Check the Exclusions. Real auditors look for “Legacy Auth” or “Bypass Groups” that GRC tools often ignore. |
| Need to Know | Platform assumes managers know what their team needs. | Perform a Deep Dive. Check if a junior dev has “Owner” rights on the entire AWS/Azure environment. |
| Leaver Revocation | Tool checks if the “Status” in HR software is ‘Inactive’. | Verify Downstream SaaS. Employees often remain logged into Slack, GitHub, or Figma long after the AD account is dead. |
| Data Masking | Platform ignores application-level UI controls. | Inspect the UI. Ensure sensitive fields are obscured in the production environment view. |
| Repo Security | Tool identifies that a “VCS is in use.” | Verify Personal Email Logins. Check if staff are using personal GitHub accounts to access corporate code. |
About the author
