C.3 Access Management Policy

Version: April 2025
Applies to: All employees, contractors, and third parties
Aligned with: ISO/IEC 27001:2022 (A.5.15–A.5.20)

Purpose
To ensure that users only have access to the systems and data they need, based on their role, and that all access is authorized, reviewed, and revoked when no longer needed.

1. Scope
This policy applies to:
- All internal and third-party personnel
- All systems, apps, and data within the IT infrastructure
- User accounts, credentials, and roles across the organization

2. Core Requirements (Safeguards)

ID Requirement
AM-01 Define and document user roles and responsibilities
AM-02 Apply Separation of Duties when assigning access roles
AM-03 Maintain Access Control Lists (ACLs) for each system and application
AM-04 ACLs must reflect the organization's defined user roles
AM-05 ACLs must enforce Least Privilege on all system objects
AM-06 ACLs must restrict functions per documented role permissions
AM-07 ACLs must control access to code repositories
AM-08 ACLs must enforce encryption at rest
AM-09 ACLs must enforce encryption in transit
AM-10 Regularly review all ACLs for accuracy and relevance
AM-11 Regularly review ACL documentation
AM-12 Regularly audit group/role memberships
AM-13 Log and alert on changes to ACLs or role/group membership
AM-14 Same as AM-13 (duplicate noted in source)

3. Non-Compliance & Sanctions
Violations may lead to:
- Refresher training or official warnings
- Suspension of access rights
- Contract or employment termination
- Legal consequences if laws are violated

All actions will be taken proportionally and under HR/legal procedures.

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