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A.5.16 ISO 27001

ISO 27001 A.5.16: Identity management

What This Control Requires

The full lifecycle of identities shall be managed.

In Plain Language

If someone left your company six months ago and their account is still active, you have an identity management problem. Auditors will check, and this is one of the most common findings. Identity management covers the full lifecycle: creating identities when people join or new services are deployed, keeping them accurate as roles change, and disabling or deleting them when they are no longer needed. Every stage needs a defined process. The point is accountability. Every action on your systems should trace back to a unique individual - no shared logins, no anonymous access. And the lifecycle must be tightly integrated with HR processes so that when someone's employment status changes, their access changes with it.

How to Implement

Set up a centralised identity provider (Active Directory, Azure AD, Okta, or similar) as the single authoritative source for all identities. Integrate it with your applications through SAML or OIDC. Define your lifecycle processes clearly. Registration needs identity verification before any account is created. Use a consistent naming convention. Link every identity to a real individual and track attributes like department, role, manager, and employment status. For service accounts, document purpose, owner, and review schedule. Tie provisioning to HR onboarding. When HR creates a new employee record, that should trigger account creation, role assignment, and notifications. Automate this with identity governance tooling if you can - manual processes create delays and errors. Handle changes proactively. Role changes, transfers, and promotions should trigger identity updates. Run regular reviews to catch dormant accounts and excessive privileges that have crept in. Make deprovisioning fast and thorough. Disable accounts on or before the last working day. Set a retention period before permanent deletion (check your legal requirements). For contractors and temps, set expiry dates at provisioning time so they do not slip through the cracks. Prevent identity duplication by keeping a single authoritative source. Never allow shared accounts where individual accountability is required. Make sure service and system accounts are inventoried, owned, and reviewed regularly.

Evidence Your Auditor Will Request

  • Documented identity lifecycle management procedures covering creation, modification, and deactivation
  • Evidence of integration between HR systems and identity provisioning processes
  • Records of timely identity deactivation for recent departures
  • Inventory of service and system accounts with documented owners
  • Regular identity review and cleanup records showing removal of dormant accounts

Common Mistakes

  • Identity provisioning is not linked to HR processes causing delays in creation and deprovisioning
  • Dormant accounts remain active long after users have departed the organization
  • Shared accounts are used without individual accountability
  • Service accounts have no documented owner or regular review schedule
  • No standardized process for identity lifecycle management across all systems

Related Controls Across Frameworks

Framework Control ID Relationship
SOC 2 CC6.1 Related
SOC 2 CC6.2 Equivalent
GDPR Art.32 Partial overlap
NIS2 Art.21(2)(i) Related

Frequently Asked Questions

How quickly should accounts be disabled when someone leaves?
Same day, ideally by end of their last shift. For involuntary departures or terminations for cause, disable immediately - sometimes before the person is even notified. The key is having pre-arranged procedures with HR so IT gets the heads-up in time. This is one of those things auditors will specifically sample, so make sure you have evidence of timely deactivation.
How should we manage service accounts?
Treat them like real accounts that happen not to belong to a person. Inventory all of them, document what each one does and why it exists, and assign a human owner who is responsible for its security. Use strong unique passwords or certificate-based auth. Review them quarterly. Put privileged service accounts under PAM controls. And never repurpose a personal account for automated services - it creates an accountability mess.

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