ISO/IEC 27001

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  5. User Account Management Procedure

User Account Management Procedure

1. Purpose

The purpose of this User Account Management Procedure is to define the operational process for requesting, creating, modifying, reviewing, disabling, and removing user accounts.

The procedure ensures that user accounts are:

  • Created only for authorized users.
  • Linked to a legitimate business need.
  • Uniquely attributable to an individual where practical.
  • Assigned appropriate access.
  • Protected using appropriate authentication controls.
  • Modified when user responsibilities change.
  • Periodically reviewed.
  • Disabled or removed when no longer required.
  • Supported by appropriate evidence.

Core Lifecycle

Request → Verify → Approve → Create → Configure → Provision Access → Verify → Review → Modify → Disable/Remove → Record


2. Scope

This procedure applies to:

  • Employees
  • Contractors
  • Consultants
  • Interns
  • Temporary personnel
  • Third-party users
  • Administrators
  • Privileged users

It covers user accounts for:

  • Identity providers / SSO
  • Email and collaboration
  • SaaS applications
  • AWS, Azure, GCP and other cloud environments
  • Servers
  • Databases
  • VPN and remote access
  • Source-code repositories
  • CI/CD platforms
  • Security platforms
  • Business applications
  • Customer environments
  • Other systems containing organizational information

Service accounts, application identities, API credentials, and machine identities should be managed under appropriate separate controls, although they may be referenced by this procedure where relevant.


3. Objectives

The procedure is intended to ensure:

  1. Every user account has an identifiable owner.
  2. Account creation is authorized.
  3. Access is based on business need.
  4. Users receive only appropriate permissions.
  5. Authentication is appropriately protected.
  6. Role changes trigger access review.
  7. Former users lose access.
  8. Privileged accounts receive additional controls.
  9. Dormant accounts are identified.
  10. Account activities can be traced to appropriate users.
  11. Account management activities can be demonstrated through evidence.

4. Roles and Responsibilities

RoleResponsibility
HR / People TeamNotify IT of joiners, movers and leavers
ManagerDefine and approve business access requirements
System OwnerApprove system-specific access
IT / IAMCreate, modify, disable and remove accounts
Security / ISMSDefine security requirements and support reviews
Data OwnerApprove access to sensitive information where required
Application OwnerManage application-level account requirements
Cloud OwnerManage cloud identities and permissions
UserProtect credentials and use the assigned account appropriately
Internal AuditIndependently assess account-management controls

For small organizations, one person may perform multiple responsibilities, but appropriate approval and review separation should be maintained where practical.


5. Account Types

Account TypeExampleManagement Approach
Standard UserEmployee accountNormal user access
Privileged UserCloud administratorEnhanced controls
ContractorExternal developerTime-limited access
Third-Party UserAuditorRestricted, approved access
Temporary UserProject resourceExpiry required
Service AccountBackup serviceSeparate service-account controls
Emergency AccountBreak-glassRestricted and monitored

6. User Account Lifecycle

The standard account lifecycle is:

1. Request

Business need is identified.

2. Verify

User identity, employment/engagement and role are verified.

3. Approve

Manager/system owner approves the requested account and access.

4. Create

IT/IAM creates the account.

5. Configure

Authentication and required security controls are configured.

6. Provision Access

Approved permissions are assigned.

7. Verify

User access is checked against the approved request.

8. Review

Account and access are periodically reviewed.

9. Modify

Account/access is changed when responsibilities change.

10. Disable or Remove

Account is disabled or removed when no longer required.

11. Record

Evidence of the lifecycle activity is retained.


7. User Account Request

A user account should be created only after an appropriate request has been submitted.

The request should include, as applicable:

  • Request ID
  • User name
  • Employee/contractor ID
  • Department
  • Job role
  • Manager
  • System/application
  • Environment
  • Required access
  • Business purpose
  • Data/information accessed
  • Access level
  • Start date
  • Expiry date, where applicable
  • Approver
  • System owner
  • Security approval, where required

Example

A new software developer requires access to GitHub and the AWS development environment.

The request should specify:

  • Required repositories
  • AWS account
  • Required role
  • Business justification
  • Start date
  • Approver

The user should not automatically receive AWS production administrator access simply because they are a developer.


8. User Verification

Before account creation, the responsible team should verify that:

  • The person is an employee or authorized external user.
  • The engagement is active.
  • The manager/sponsor is valid.
  • The requested role is accurate.
  • The system access is required.
  • The requested access is appropriate.

For third parties, verify the applicable contract, SOW, NDA, sponsor and engagement period.


9. Account Approval

Approval should be obtained before account creation.

Depending on the system, approval may involve:

Manager → System Owner → Data Owner/Security → IT/IAM

Not every request requires every approval.

Higher-risk access may require additional approval.

Examples:

  • Production access
  • Privileged access
  • Customer database access
  • Security administration
  • Financial systems
  • Restricted information
  • Administrative cloud roles

10. Account Creation

IT/IAM or the authorized administrator shall create the account using the approved identity-management process.

The account should:

  • Use the user’s approved identity.
  • Have a unique username where practical.
  • Use approved naming conventions.
  • Be associated with the correct department/role.
  • Be linked to the appropriate identity provider where possible.
  • Have only approved access.
  • Have required authentication controls.
  • Be recorded in the appropriate system or register.

11. Authentication Configuration

Authentication should be configured according to organizational requirements.

Controls may include:

  • Password
  • MFA
  • SSO
  • Security key
  • Authenticator application
  • Conditional access
  • Device authentication
  • Federation

For higher-risk systems, stronger authentication should be applied according to the organization’s risk assessment.


12. MFA Configuration

MFA should be enabled for systems where required by:

  • Organizational policy
  • Risk assessment
  • Customer requirements
  • Contractual requirements
  • Regulatory requirements
  • System security requirements

Particular attention should be given to:

  • Privileged accounts
  • Cloud administration
  • Identity-provider administration
  • Production systems
  • Remote access
  • Security platforms
  • Sensitive SaaS applications

13. Access Provisioning

After account creation, only approved access should be provisioned.

Provisioning Flow

Approved Request → Identify Required Role → Assign Appropriate Permission → Configure MFA → Verify → Record

Access should follow:

  • Least privilege
  • Need-to-know
  • Role requirements
  • Information classification
  • System risk
  • Segregation of duties

14. Privileged Account Provisioning

Privileged access requires additional controls.

Before granting privileged access:

  • Business need must be established.
  • Appropriate approval must be obtained.
  • The privilege should be limited to the required scope.
  • MFA should be enabled where required.
  • Named accounts should be used where practical.
  • Privileged access should be recorded.
  • Monitoring/logging should be enabled where appropriate.

Privileged access should also be recorded in the Privileged Access Register.


15. Production Access

Production access should be separately evaluated from development or test access.

For example:

UserDevelopmentProduction
DeveloperApprovedRestricted/role-based
DevOpsApprovedApproved based on role
SupportUsually noLimited application access
AuditorNoEvidence access only

Production access should be granted only where there is a documented business requirement.


16. User Account Verification

After provisioning, IT/IAM or the relevant system owner should verify:

  • Correct account created
  • Correct user assigned
  • Correct system assigned
  • Correct role assigned
  • Correct permissions
  • MFA configured where required
  • No unnecessary privileged access
  • Start/expiry dates correctly configured
  • Account recorded appropriately

The user or system owner may confirm that required access works.


17. Account Modification

User accounts should be modified when there is a change in:

  • Job role
  • Department
  • Responsibilities
  • Project
  • Employment status
  • Security requirements
  • System requirements
  • Privilege level

Mover Process

Role Change → Review Existing Access → Remove Unnecessary Access → Approve New Access → Provision → Verify → Record

The organization should avoid simply adding new permissions without reviewing existing permissions.


18. Joiner Process

For a new employee or authorized user:

  1. HR/People or sponsor sends notification.
  2. User identity is verified.
  3. Role is confirmed.
  4. Required systems are identified.
  5. Access request is submitted.
  6. Appropriate approvals are obtained.
  7. User account is created.
  8. MFA/authentication is configured.
  9. Approved access is provisioned.
  10. Security responsibilities are communicated.
  11. Access is verified.
  12. Evidence is retained.

19. Mover Process

When a user changes role:

  1. Role change is received.
  2. Existing accounts are identified.
  3. Existing access is reviewed.
  4. Unnecessary permissions are removed.
  5. New access requirements are identified.
  6. New access is approved.
  7. New permissions are provisioned.
  8. Privileged access is reassessed.
  9. SoD implications are considered.
  10. Access is verified.
  11. Records are updated.

Example

A developer becomes an Engineering Manager.

Their new access may include:

  • Jira management
  • Engineering dashboards
  • Approved management tools

Their previous access to certain production resources may no longer be required and should therefore be reviewed and potentially removed.


20. Leaver Process

When a user leaves:

  1. HR/manager provides exit notification.
  2. All known accounts are identified.
  3. Account status is reviewed.
  4. Corporate identity is disabled.
  5. Sessions are terminated where applicable.
  6. MFA credentials are revoked.
  7. SaaS access is removed.
  8. Cloud access is removed.
  9. VPN access is removed.
  10. Source-code access is removed.
  11. Database access is removed.
  12. API tokens/SSH keys/certificates are reviewed.
  13. Privileged access is revoked.
  14. Physical access is removed.
  15. Assets are recovered.
  16. Business responsibilities are transferred.
  17. Completion is verified.
  18. Evidence is retained.

Important: Disabling the email account alone does not complete account termination.


21. Emergency Account Revocation

Immediate account action may be required when:

  • Credentials are suspected to be compromised.
  • A security incident occurs.
  • A device containing authentication information is lost.
  • Unauthorized access is detected.
  • A privileged account is suspected of compromise.
  • Emergency termination is required.

Actions may include:

  • Disable account
  • Revoke sessions
  • Reset credentials
  • Revoke MFA methods
  • Revoke API tokens
  • Revoke SSH keys
  • Remove cloud roles
  • Disable VPN
  • Block application access

The event should be handled under the organization’s incident-management process where applicable.


22. Temporary Accounts

Temporary accounts should have:

  • Defined purpose
  • Named user
  • Approver
  • Start date
  • Expiry date
  • Limited permissions
  • Appropriate authentication
  • Review requirement

Example:

An external auditor requires access to an audit evidence repository for 14 days.

The account should automatically expire where technically possible or be explicitly reviewed and disabled at the end of the engagement.


23. Third-Party Accounts

Third-party user accounts shall be managed according to the Third-Party Access Procedure.

Before creating the account, verify:

  • Organization
  • Individual
  • Internal sponsor
  • Contract/SOW
  • NDA/confidentiality
  • Business purpose
  • Systems required
  • Information accessed
  • Access level
  • Start date
  • Expiry date

Third-party accounts should not be created using shared employee credentials.


24. Dormant Account Management

The organization should periodically identify inactive accounts.

Review:

  • Last login
  • Last activity
  • Account owner
  • Business purpose
  • Employment/engagement status
  • System criticality
  • Privilege level

Possible actions:

  • Disable
  • Remove
  • Confirm business need
  • Transfer ownership
  • Investigate activity

The inactivity threshold should be determined according to system risk and organizational requirements.


25. Account Lockout and Protective Controls

Where supported and appropriate, systems should implement controls such as:

  • Failed-login protection
  • Account lockout or throttling
  • Risk-based authentication
  • Session timeout
  • Reauthentication
  • Suspicious-login detection
  • Conditional access

The exact configuration should reflect system risk and usability requirements.


26. Shared Accounts

Shared user accounts should generally be avoided because they reduce accountability.

Where a shared account is technically necessary:

  • Document the business justification.
  • Obtain approval.
  • Restrict access.
  • Protect credentials.
  • Maintain appropriate accountability.
  • Monitor use where technically possible.
  • Review the account periodically.

Privileged shared accounts should receive particular scrutiny.


27. Service Accounts

Service accounts should be managed using appropriate service-account controls.

Each service account should have:

  • Owner
  • Purpose
  • System/application
  • Permissions
  • Credential location
  • Rotation requirements
  • Review date
  • Dependencies
  • Status

Where possible:

  • Disable interactive login.
  • Use workload identities.
  • Use short-lived credentials.
  • Avoid embedding secrets in source code.

28. Cloud Account Management

AWS Example

For an AWS-based SaaS company:

Employee → Corporate IdP → SSO/MFA → AWS IAM Identity Center → Approved Role → AWS Account

Administrators should avoid unnecessary long-lived credentials.

Where practical, use:

  • IAM roles
  • Federation/SSO
  • MFA
  • Temporary credentials
  • Least privilege
  • Separate production/development access
  • CloudTrail
  • Periodic access reviews

29. Account Review

User accounts should be periodically reviewed according to organizational requirements and risk.

The review should compare:

Actual Account → Current User → Current Role → Approved Access → Required Access

The review should identify:

  • Unauthorized accounts
  • Excessive permissions
  • Former employees
  • Role-change issues
  • Dormant accounts
  • Privileged accounts
  • Third-party accounts
  • Temporary accounts
  • MFA exceptions
  • Shared accounts

Results should be documented in an Access Review Report.


30. Account Revocation

Account revocation should include more than disabling the primary account.

Depending on the user/system, review:

  • SSO
  • Email
  • SaaS
  • VPN
  • AWS/Azure/GCP
  • Source code
  • CI/CD
  • Databases
  • Customer systems
  • Security platforms
  • API tokens
  • SSH keys
  • Certificates
  • Active sessions
  • MFA devices
  • Physical access

The revocation should be verified.


31. Access Revocation Verification

After revocation, verify:

  • Account disabled/removed
  • Sessions terminated where applicable
  • Privileged roles removed
  • Cloud access removed
  • SaaS access removed
  • Source-code access removed
  • Tokens/keys reviewed
  • Physical access removed
  • Registers updated

Verification Record

ItemResultVerified ByDateEvidence
Corporate Account
AWS
GitHub
SaaS
VPN
Physical Access

32. Account Management Records

The organization should maintain appropriate records such as:

  • User Account Request
  • Account Creation Record
  • Access Approval
  • Account Modification Record
  • JML records
  • Privileged Access Register
  • Third-Party Access Register
  • Account Review Report
  • Access Revocation Checklist
  • Exception records
  • Relevant system logs

33. User Account Management Register

Where a centralized register is appropriate, consider maintaining:

FieldDescription
Account IDUnique identifier
UserAccount owner
Employee/Contractor IDReference
DepartmentUser department
RoleBusiness role
Account TypeStandard/Privileged/Temporary
SystemApplication/system
EnvironmentProduction/Test/Development
Access LevelPermission level
Business PurposeReason for access
ApproverApproval authority
Created DateAccount creation
Expiry DateWhere applicable
MFAEnabled/Not Enabled
StatusActive/Disabled/Removed
Last ReviewReview date
Next ReviewNext review
OwnerAccount/system owner
EvidenceSupporting record

34. Exceptions

Any deviation from this procedure should be documented.

The exception should include:

  • Exception ID
  • Requirement
  • Reason
  • Affected account/system
  • Risk
  • Compensating controls
  • Owner
  • Approver
  • Expiry/review date
  • Status

35. Procedure for Lost or Compromised Credentials

If a user believes credentials have been compromised:

User

Stop using the credential → Report immediately

IT/Security

Assess → Disable/Reset → Revoke Sessions/Tokens → Investigate → Restore Access → Monitor

Where required, the incident should be recorded through the Security Incident Management Procedure.

Examples include:

  • Password entered into phishing site
  • AWS access key exposed
  • API token committed to GitHub
  • MFA device lost
  • SSH key compromised
  • Session token stolen

36. Audit Evidence

An auditor may request:

  • User account list
  • Access requests
  • Approval records
  • Account creation records
  • JML records
  • Access review reports
  • Privileged Access Register
  • Third-party access records
  • Account revocation records
  • MFA evidence
  • SSO configuration
  • AWS IAM/Identity Center evidence
  • Application access listings
  • Dormant account review
  • Service account records
  • Exception records
  • Relevant audit logs

Evidence should demonstrate not only that accounts exist, but that the account lifecycle is controlled.


37. AWS SaaS Startup Example

A 30-person SaaS startup operates its platform on AWS.

New Developer

HR Notification

→ Manager confirms role
→ User Access Request
→ Approval
→ Corporate SSO account created
→ MFA enabled
→ GitHub access provisioned
→ AWS development role assigned
→ Access verified
→ Evidence retained

Developer Becomes Engineering Manager

Role Change

→ Existing access reviewed
→ Unnecessary developer permissions removed
→ Manager access approved
→ New access provisioned
→ Production privileges reassessed
→ Verification completed

Developer Leaves

Exit Notification

→ SSO disabled
→ GitHub access removed
→ AWS roles removed
→ VPN disabled
→ SaaS access removed
→ API/SSH credentials reviewed
→ Sessions revoked
→ Laptop returned
→ Access revocation verified
→ Evidence retained


38. Startup-Friendly Minimum Control Set

A startup can establish a strong account-management process without a complex IAM program.

Minimum model

1. Central Identity

Use an approved identity provider where practical.

2. MFA

Protect important and privileged systems.

3. Access Request

Require approval before creating access.

4. JML

Connect HR/contractor changes to account management.

5. Privileged Access Register

Track administrative accounts.

6. Periodic Access Review

Compare actual accounts and permissions with approved requirements.

7. Revocation

Remove access when the business need ends.

8. Evidence

Keep approval, provisioning, review and revocation evidence.


39. Common Mistakes

1. Creating accounts through informal requests

Use a controlled request and approval process.

2. Giving access based only on job title

Validate actual business requirements.

3. Adding permissions after role changes

Review and remove old permissions first.

4. Disabling only email

Review all systems and credentials.

5. Forgetting API credentials

Tokens, SSH keys and certificates may continue to provide access.

6. Ignoring dormant accounts

Review inactive identities periodically.

7. Using shared administrator accounts

Prefer individually attributable identities.

8. Forgetting third-party users

External identities need the same lifecycle discipline.

9. No expiry for temporary access

Temporary access should have a defined end point.

10. No evidence

An account-management process should leave an auditable trail.


40. Quick Procedure Checklist

Account Creation

  • Business need identified
  • User verified
  • Role confirmed
  • Access requested
  • Approval obtained
  • Account created
  • MFA configured where required
  • Access provisioned
  • Access verified
  • Evidence retained

Account Modification

  • Role change identified
  • Existing access reviewed
  • Unnecessary access removed
  • New access approved
  • New access provisioned
  • Privileged access reassessed
  • SoD considered
  • Verification completed

Account Termination

  • Exit notification received
  • Accounts identified
  • SSO/email disabled
  • SaaS access removed
  • Cloud access removed
  • Source-code access removed
  • VPN removed
  • Tokens/keys reviewed
  • Sessions revoked
  • Physical access removed
  • Assets recovered
  • Revocation verified
  • Evidence retained

41. Relationship with Other ISMS Documents

This procedure works together with:

  • Identity Management Policy
  • Access Control Policy
  • Access Control Matrix
  • User Access Request
  • User Access Review Checklist
  • Access Review Report
  • JML Procedure
  • Privileged Access Register
  • Third-Party Access Procedure
  • Access Revocation Checklist
  • Employee Offboarding Checklist
  • Contractor Offboarding Checklist
  • Segregation of Duties Policy
  • Information Classification Policy
  • Cloud Asset Inventory
  • SaaS Application Register
  • Incident Response Plan

Complete Lifecycle

Identity Management Policy

↓

User Account Request

↓

Approval

↓

Account Creation

↓

Access Provisioning

↓

User Account Management

↓

Periodic Access Review

↓

Access Modification / Revocation

↓

Evidence & Audit Trail


42. ISO 27001 Connection

This procedure supports applicable ISO/IEC 27001 requirements relating to:

  • Identity management
  • Authentication information
  • Access rights
  • Access restriction
  • Privileged access
  • Access review
  • Segregation of duties
  • Supplier and third-party access
  • Logging and monitoring where applicable

The exact controls applicable to the organization should be determined through its risk assessment and Statement of Applicability (SoA).


43. Final Audit Trail

An auditor should be able to trace:

User → Business Need → Request → Approval → Account Creation → Authentication → Access → Review → Modification → Revocation → Verification → Evidence

The procedure should answer:

  • Who is the account for?
  • Why does the account exist?
  • Who approved it?
  • What access was granted?
  • Is MFA appropriately configured?
  • Does the access match the user’s role?
  • Was access reviewed?
  • What happened when the user changed roles?
  • What happened when the user left?
  • Were tokens, keys and privileged access also addressed?
  • Can the organization demonstrate the entire lifecycle?

Final Principle

Create accounts only when needed, give only the access required, protect the identity appropriately, review it periodically, and remove it when the business need ends — with evidence at every important stage.

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