SOC 2 CC6.3: Logical and Physical Access - Role-Based Access and Least Privilege
What This Control Requires
The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consideration to the concepts of least privilege and segregation of duties, to meet the entity's objectives.
In Plain Language
Auditors see access creep in almost every organisation they examine. People join, change teams, pick up side projects - and their access just keeps growing. CC6.3 exists because unmanaged access is one of the fastest paths to a material finding. The core idea is straightforward: give people only the access they need for their current role, and make sure no single person can both initiate and approve sensitive actions. In practice, that means role-based access control (RBAC), regular access reviews that actually mean something, and a clear process for stripping old permissions when someone moves to a new team. Access creep - where users accumulate excessive permissions over time - is one of the most common audit findings. If you can show a clean joiner-mover-leaver process and genuine periodic reviews, you're already ahead of most organisations going through SOC 2.
How to Implement
Start by defining and documenting access roles for every in-scope application and system. Each role should map to a job function and spell out exactly what permissions it grants. Get system owners to sign off on these role definitions. Default to the minimum access required for each role. When someone requests access beyond their standard role, require a written business justification and approval from the relevant data or system owner. Track every exception. Map out your segregation of duties requirements. Identify which combinations of access could enable fraud or significant errors - think creating and approving transactions, modifying code and deploying to production, or setting up vendor records and processing payments. Enforce these separations in your systems where possible. Where you can't enforce them technically, put detective controls in place (monitoring, review logs, management sign-off). Run regular access reviews - quarterly for privileged access, semi-annually for everything else at minimum. Have managers or system owners validate whether each person's access still matches their current role. Document the review, any changes made, and who signed off. Build a process for role changes specifically. When someone moves teams, that should trigger a full review - not just adding new permissions on top of old ones. Remove access that's no longer relevant. Monitor for anomalous access patterns. Log privileged operations and review those logs. Automated tooling that flags SoD violations, unused privileges, and access anomalies will save you significant time.
Evidence Your Auditor Will Request
- Role definitions for each system with documented permissions and approval by system owners
- Access review records (quarterly for privileged, semi-annual for all) with reviewer sign-off
- Segregation of duties matrix identifying incompatible access combinations and mitigating controls
- Evidence of access modification during role changes, including removal of no-longer-needed access
- Exception records for access granted beyond standard roles with business justification and approval
Common Mistakes
- Users accumulate access over time through role changes without removal of previous role permissions
- Privileged access is granted broadly rather than limited to specific individuals who require it
- Access reviews are performed as a rubber-stamp exercise without genuine evaluation of appropriateness
- Segregation of duties conflicts are not identified or documented, and no compensating controls exist
- Role definitions are outdated and do not reflect current system capabilities or organisational structure
Related Controls Across Frameworks
Frequently Asked Questions
How do we prevent access creep?
How granular should access reviews be?
What if our small team makes strict segregation of duties impossible?
Track SOC 2 compliance in one place
AuditFront helps you manage every SOC 2 control, collect evidence, and stay audit-ready.
Start Free Assessment