cc6-3 Critical priority Security / Logical and Physical Access

Role-based access is used and reviewed periodically

Access permissions accumulate over time. People change roles, projects end, and permissions granted for a specific purpose are never removed. Periodic access reviews — where each user's access is compared against their current role — are the mechanism for correcting this drift. Without reviews, privileged access grows unchecked and auditors will find accounts with access far exceeding what is justified.

Complete first: cc6-2

Implementation steps

  1. 1

    Define access roles aligned to job functions

    Create a role-based access model where permissions are granted by assigning roles, not individually. Define roles for common job functions: developer, admin, read-only, support, etc. Document what each role can access. This makes it possible to review access at the role level rather than per-user.

    aws-iam okta google-workspace azure-ad
  2. 2

    Conduct user access reviews at least quarterly

    At least every 90 days, review all user access to in-scope systems. For each user, verify that their current access is appropriate for their current role. Remove or reduce access that is no longer needed. Document the review completion, including reviewer, date, and any access changes made.

    okta vanta drata google-sheets notion
  3. 3

    Review privileged access more frequently

    Privileged accounts — production admin access, root accounts, database admin roles — should be reviewed monthly. Privileged access should be time-limited where possible (just-in-time access). The number of users with privileged access should be minimized and documented.

    aws-iam cyberark okta-pam hashicorp-vault

Evidence required

Access review records

Documentation of completed periodic access reviews with dates, reviewers, and outcomes.

  • - Quarterly access review spreadsheet with reviewer sign-off
  • - Vanta or Drata access review completion report
  • - Okta access certification report

Role definitions documentation

Evidence of a defined role-based access model.

  • - IAM role definitions and permission boundaries
  • - Access control matrix showing roles and permissions
  • - Access control policy with role descriptions

Related controls