ISO/IEC 27001

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Emergency Access Procedure

1. Purpose

The Emergency Access Procedure defines how temporary or exceptional access to information systems, applications, cloud environments, infrastructure, data, or administrative functions is requested, approved, granted, monitored, and removed during an emergency.

Emergency access may be required when normal access arrangements are unavailable or insufficient to:

  • Restore critical business services.
  • Respond to a security incident.
  • Recover from a disaster.
  • Contain an active security threat.
  • Restore critical infrastructure.
  • Investigate a major incident.
  • Resolve a critical production failure.
  • Maintain essential business operations.

The objective is to enable rapid response without creating uncontrolled or permanent security access.


2. Scope

This procedure applies to emergency access involving:

  • Employees
  • Contractors
  • IT administrators
  • Security personnel
  • Cloud administrators
  • DevOps personnel
  • Database administrators
  • Application administrators
  • Suppliers or external specialists
  • Privileged accounts
  • Cloud accounts
  • Production systems
  • Databases
  • Networks
  • Security tools
  • Backup systems
  • SaaS platforms
  • CI/CD systems
  • Customer information
  • Security logs
  • Recovery environments

It applies to emergency access for both security incidents and operational/business continuity events.


3. Emergency Access Principle

Emergency access follows:

Minimum Access + Clear Authorization + Time Limitation + Strong Authentication + Monitoring + Evidence + Immediate Revocation

Emergency access is an exception to normal access processes, not an exception from access control.


4. When Emergency Access May Be Used

Emergency access may be considered when:

  • A critical production service is unavailable.
  • Normal administrators are unavailable.
  • A critical security incident requires immediate action.
  • A privileged account is compromised.
  • Disaster recovery is activated.
  • A cloud service requires urgent recovery.
  • A critical vulnerability requires emergency remediation.
  • Backup recovery requires elevated privileges.
  • Normal access-management systems are unavailable.
  • A critical supplier requires temporary technical access.
  • An emergency change requires elevated access.

Emergency access must have a legitimate business or security justification.


5. When Emergency Access Must Not Be Used

Emergency access must not be used:

  • For convenience.
  • To avoid normal approval processes without a legitimate emergency.
  • To obtain permanent privileges.
  • To bypass security controls unnecessarily.
  • To perform routine administrative work.
  • To access information unrelated to the emergency.
  • To avoid logging or monitoring.
  • To create unapproved accounts or credentials.

6. Emergency Access Roles

RoleResponsibility
RequestorIdentifies and requests emergency access
ApproverAuthorizes access based on risk and urgency
System OwnerConfirms system/business need
Security LeadReviews security implications
IT/Cloud LeadImplements technical access
Incident CommanderCoordinates access during major incidents
Auditor/ReviewerReviews emergency access after the event

One person may perform multiple roles in a startup, but access approval and implementation should be separated where practical.


7. Emergency Access Lifecycle

Emergency Identified
↓
Need Assessed
↓
Access Requested
↓
Emergency Validated
↓
Risk Assessed
↓
Access Approved
↓
Temporary Access Created/Enabled
↓
MFA & Security Controls Applied
↓
Activity Monitored
↓
Emergency Work Performed
↓
Access Reviewed
↓
Access Revoked
↓
Evidence Recorded
↓
Post-Emergency Review


8. Step 1 — Identify the Emergency

Record:

  • Emergency ID
  • Date/time
  • Requestor
  • Affected service
  • Affected system
  • Description
  • Business impact
  • Security impact
  • Reason emergency access is required
  • Expected access duration

Example:

EA-2026-0001

Production database is unavailable following an infrastructure failure. The normal database administrator is unavailable. Temporary elevated access is required to perform recovery.


9. Step 2 — Determine Whether Emergency Access Is Necessary

Before granting access, determine:

  • Can the task be completed using existing authorized access?
  • Is the situation genuinely urgent?
  • What system requires access?
  • What information may be accessed?
  • What privilege is required?
  • How long is access required?
  • Can a less-privileged role perform the task?
  • Is an approved alternative available?

If normal access is sufficient, emergency access should not be used.


10. Step 3 — Define the Minimum Required Access

The requestor should specify:

  • System
  • Environment
  • Account
  • Role
  • Permissions
  • Resources
  • Data
  • Actions required
  • Expected duration

Access should be limited to the minimum required scope.

Example

Instead of:

Full AWS AdministratorAccess

Prefer:

Temporary access to the specific production ECS service and associated deployment resources required to restore the affected application.

Where the emergency genuinely requires broader privilege, the reason should be documented.


11. Step 4 — Emergency Approval

Emergency access should be approved by an authorized person.

Approval should consider:

  • Business impact
  • Security risk
  • Required privilege
  • System criticality
  • Information sensitivity
  • User identity
  • Expected duration
  • Alternative options
  • Compensating controls

For a major security incident, the Incident Commander or Security Lead may authorize access according to the organization’s incident-response authority model.


12. Emergency Approval Levels

EmergencyMinimum Approval
Low-risk operational recoverySystem Owner/IT Lead
Critical production recoveryIT/Cloud Lead + Business Owner where practical
Privileged production accessAuthorized Manager/Security Lead
Security incident responseIncident Commander/Security Lead
Major disaster recoveryAuthorized Management + Technical Owner
Highly sensitive/customer data accessSecurity/Privacy/Business authority as applicable
External specialist accessSystem Owner + Security/IT authority

Where immediate action is necessary and prior approval cannot reasonably be obtained, emergency access may be granted under predefined emergency authority and must be reviewed afterward.


13. Step 5 — Strong Authentication

Emergency access should use strong authentication.

Where supported:

  • MFA must be enabled.
  • Named accounts must be used.
  • Privileged authentication must be protected.
  • Hardware security keys should be used where appropriate.
  • Shared credentials should be avoided.

If MFA must temporarily be bypassed due to a genuine emergency, the exception must be explicitly authorized, documented, monitored, and corrected as soon as possible.


14. Step 6 — Temporary Account or Privilege

Where possible, emergency access should be implemented using:

  • Temporary account
  • Temporary role
  • Just-in-time privilege
  • Time-limited group membership
  • Temporary cloud role
  • Privileged-access-management mechanism

The access should automatically expire where technically possible.


15. AWS Emergency Access Example

Suppose the production AWS environment becomes unavailable and the normal administrator is unavailable.

Instead of sharing an administrator password:

  1. Create or enable an approved emergency role.
  2. Require MFA.
  3. Restrict the role to the required AWS account.
  4. Apply the minimum required permissions.
  5. Set an expiration time.
  6. Record the Emergency Access ID.
  7. Monitor CloudTrail activity.
  8. Perform the recovery.
  9. Verify the service.
  10. Remove/revoke the emergency role.
  11. Review CloudTrail activity.
  12. Record the closure.

Example:

EA-2026-0012

Temporary AWS production recovery role enabled for 90 minutes to restore ECS deployment and verify associated infrastructure.


16. Step 7 — Record Emergency Access

The following information should be recorded:

FieldDescription
Emergency Access IDUnique identifier
Incident/DR IDRelated record
RequestorPerson requesting access
UserPerson receiving access
SystemTarget system
EnvironmentProduction/Test/etc.
Access LevelPrivilege granted
ReasonEmergency justification
ApprovalApprover
Start TimeAccess activation
Expiry TimePlanned expiry
Actual RevocationActual removal
MonitoringMonitoring method
Actions PerformedWork completed
EvidenceLogs/records
ReviewerPost-event reviewer
StatusOpen/Closed

17. Step 8 — Monitor Emergency Activity

Emergency access should be monitored more closely than ordinary access where practical.

Monitoring may include:

  • Authentication logs
  • Privileged activity
  • CloudTrail
  • Application logs
  • Database logs
  • Network logs
  • Command history
  • Administrative actions
  • Configuration changes
  • File access
  • Security alerts

The purpose is to establish:

Who accessed what, when, from where, and what actions were performed.


18. Step 9 — Protect Sensitive Information

Emergency access may expose:

  • Customer information
  • Personal data
  • Financial information
  • Source code
  • Security logs
  • Credentials
  • Secrets
  • Encryption keys
  • Confidential business information

The person receiving emergency access must only access information necessary for the emergency.

Sensitive information must not be copied to:

  • Personal devices
  • Personal email
  • Unapproved cloud storage
  • Unapproved collaboration tools
  • Removable media without authorization

19. Step 10 — Emergency Access During a Security Incident

When emergency access is required during an incident:

Incident Identified
→ Access Need Determined
→ Minimum Privilege Defined
→ Emergency Access Approved
→ Access Granted
→ Activity Monitored
→ Evidence Preserved
→ Response Performed
→ Access Revoked
→ Activity Reviewed

Where possible, emergency access activity should itself be treated as investigation evidence.


20. Step 11 — Emergency Access During Disaster Recovery

During DR activation, emergency access may be required for:

  • Cloud infrastructure
  • Backup systems
  • Databases
  • Network configuration
  • DNS
  • IAM
  • Security controls
  • Recovery environments
  • CI/CD

Recovery access should follow the same principles:

Authorized + Limited + Time-Bound + Monitored + Recorded + Revoked


21. Break-Glass Access

A break-glass account may be maintained for situations where normal authentication or identity services are unavailable.

Examples:

  • Identity provider outage
  • MFA service failure
  • Major cloud recovery
  • Critical infrastructure failure

Break-glass accounts should have enhanced protection.

Controls should include:

  • Strong unique credentials
  • MFA or equivalent protection where feasible
  • Restricted storage
  • Limited number of custodians
  • Monitoring
  • Periodic testing
  • Periodic access review
  • Documented use
  • Immediate review after use
  • Credential rotation after use where appropriate

Break-glass accounts should not be used for routine administration.


22. Break-Glass Credential Protection

Where physical or offline credentials are required:

  • Store them in an approved secure mechanism.
  • Restrict access to authorized custodians.
  • Maintain access records.
  • Protect against unauthorized copying.
  • Test the retrieval process periodically.
  • Rotate credentials after use where appropriate.

Passwords, recovery codes, private keys, or other secrets should not be included in ordinary documents or tickets.


23. Supplier Emergency Access

External suppliers or specialists may require emergency access.

Before granting access:

  • Confirm supplier identity.
  • Confirm business need.
  • Define exact system and access.
  • Obtain authorization.
  • Use named accounts.
  • Require MFA where possible.
  • Restrict duration.
  • Monitor activity.
  • Record actions.
  • Remove access immediately after the work.

Supplier emergency access should comply with applicable contractual security requirements.


24. Emergency Access to Customer Data

Access to customer data should receive additional scrutiny.

Before access:

  • Confirm the data is necessary.
  • Identify the specific data required.
  • Confirm authorized personnel.
  • Limit access scope.
  • Record the reason.
  • Monitor access.
  • Avoid unnecessary copying.
  • Remove access afterward.

Where personal or regulated information is involved, applicable privacy and legal requirements should be considered.


25. Emergency Credential Compromise

If an emergency account or credential is suspected to be compromised:

  1. Revoke or disable it.
  2. Preserve relevant logs.
  3. Determine when compromise may have occurred.
  4. Identify systems accessed.
  5. Review privileged actions.
  6. Rotate related credentials.
  7. Investigate possible lateral movement.
  8. Assess data access.
  9. Create or update an incident record.
  10. Apply the Account Compromise or Cloud Compromise Playbook where applicable.

26. Emergency Access Exceptions

If normal access requirements cannot be followed, document:

  • Requirement bypassed
  • Reason
  • Risk
  • Compensating control
  • Approver
  • Start time
  • Expiry
  • Owner
  • Review requirement

Example:

FieldExample
Exception IDEAX-2026-003
RequirementMFA
ReasonIdentity service unavailable during DR
RiskIncreased account compromise risk
Compensating ControlRestricted network + monitored break-glass account
ApprovalSecurity Lead
Start02:00
Expiry04:00
ReviewPost-DR review

27. Step 12 — Revoke Access

Emergency access should be revoked immediately when:

  • The emergency task is completed.
  • The system is recovered.
  • The incident is contained.
  • The recovery activity ends.
  • The approved expiry time is reached.
  • The person no longer requires access.

Revocation should include, where applicable:

  • Account disablement
  • Role removal
  • Group removal
  • Token revocation
  • API-key revocation
  • Session termination
  • VPN removal
  • Temporary firewall-rule removal
  • Credential rotation

28. Step 13 — Verify Revocation

Do not assume that removing a role automatically terminates all access.

Verify:

  • Account disabled.
  • Group membership removed.
  • Privileged role removed.
  • Active sessions terminated where applicable.
  • Tokens revoked.
  • API keys disabled.
  • Temporary credentials invalidated.
  • Temporary network access removed.
  • Temporary infrastructure removed.

Record evidence of revocation.


29. Step 14 — Post-Emergency Review

Every significant emergency access event should be reviewed.

Review:

  • Was access necessary?
  • Was the minimum privilege used?
  • Was approval appropriate?
  • Was MFA used?
  • Was access time-limited?
  • Was activity logged?
  • Were sensitive systems accessed?
  • Were unauthorized actions detected?
  • Was access revoked on time?
  • Were credentials rotated?
  • Were there security gaps?
  • Should the normal access process be improved?

30. Emergency Access Review Record

The reviewer should record:

FieldDescription
Emergency Access IDRelated access event
Access DurationPlanned vs actual
Access UsedYes/No
Systems AccessedSystems
Privileges UsedActual privilege
Actions PerformedKey activities
Security EventsAny unusual activity
Data AccessInformation accessed
RevocationCompleted
Credential RotationRequired/Completed
FindingsIssues identified
RiskResidual risk
Corrective ActionRequired action
ReviewerReview owner
ClosureApproval

31. Emergency Access Register

The organization should maintain a central register.

Recommended fields:

FieldDescription
Emergency Access IDEA-YYYY-XXXX
DateDate
Related Incident/DR IDReference
RequestorRequesting person
UserPerson receiving access
SystemTarget
EnvironmentProduction/etc.
PrivilegeAccess level
ReasonEmergency reason
ApproverApproval
Start TimeActivation
ExpiryPlanned expiry
RevocationActual removal
MonitoringMonitoring source
ActionsActivities
ReviewPost-event review
FindingsResults
Corrective ActionAction reference
StatusOpen/Closed

32. Emergency Access Status

Recommended status values:

  • Requested
  • Under Review
  • Approved
  • Active
  • Expired
  • Revoked
  • Under Review
  • Corrective Action
  • Closed

33. Emergency Access Checklist

Request

  • Emergency identified.
  • Business/security need documented.
  • Normal access confirmed insufficient.
  • Target system identified.
  • Required privilege identified.
  • Duration defined.

Approval

  • Authorized approver identified.
  • Risk assessed.
  • Minimum privilege defined.
  • Compensating controls identified where necessary.
  • Approval recorded.

Activation

  • Named account used.
  • MFA enabled where possible.
  • Temporary access configured.
  • Expiry configured.
  • Monitoring enabled.
  • Emergency Access ID recorded.

Operation

  • Activity monitored.
  • Sensitive information protected.
  • Actions documented.
  • Evidence preserved where relevant.

Revocation

  • Access disabled.
  • Roles/groups removed.
  • Sessions/tokens revoked.
  • API keys revoked where applicable.
  • Temporary network access removed.
  • Credentials rotated where required.

Review

  • Activity reviewed.
  • Access duration reviewed.
  • Security events assessed.
  • Findings recorded.
  • Risk reassessed.
  • Corrective actions assigned.
  • Emergency access record closed.

34. Startup Implementation

A startup can implement emergency access without deploying a complex privileged-access-management platform.

A practical minimum model is:

Named Emergency Role

  • MFA
  • Time-Limited Access
  • Minimum Privilege
  • Cloud/Application Logging
  • Approval Record
  • Immediate Revocation
  • Post-Access Review

For AWS, this may be implemented using:

  • IAM roles
  • MFA
  • Short-lived sessions
  • CloudTrail
  • IAM policies
  • Identity federation
  • Temporary privilege assignment
  • Restricted break-glass access

The specific implementation should reflect the organization’s architecture and risk.


35. Example — Production AWS Emergency Access

Situation

A production application is unavailable during a critical customer-impacting incident.

Required action

A cloud engineer needs temporary elevated access to restore the ECS service.

Process

Incident Created
→ Emergency Access Required
→ Existing Access Insufficient
→ Required Permission Defined
→ Security/Technical Approval
→ Temporary AWS Role Enabled
→ MFA Verified
→ CloudTrail Monitoring Confirmed
→ Recovery Performed
→ Application Tested
→ Temporary Role Revoked
→ Sessions Terminated
→ CloudTrail Reviewed
→ Emergency Access Record Closed

Evidence

  • Emergency Access Request
  • Approval
  • IAM role configuration
  • CloudTrail activity
  • Change record
  • Recovery evidence
  • Revocation evidence
  • Post-access review

36. Relationship With Other ISMS Documents

DocumentRelationship
Access Control PolicyDefines normal access requirements
Privileged Access Management ProcedureDefines privileged-access controls
Business Continuity PlanDefines business continuity
Disaster Recovery PlanDefines technology recovery
Information Security During Disruption ProcedureDefines security during disruption
Incident Response ProcedureDefines incident response
Incident Response PlaybooksProvides scenario-specific response
Emergency Change ProcedureControls emergency changes
Security Log Retention StandardSupports activity investigation
Evidence Collection ProcedurePreserves relevant evidence
Corrective Action TrackerTracks identified weaknesses
Risk RegisterRecords material residual risks

37. ISO 27001 Alignment

This procedure supports implementation of ISO/IEC 27001:2022 controls and requirements relating to:

  • Access control
  • Identity management
  • Authentication
  • Privileged access rights
  • Information security during disruption
  • ICT readiness for business continuity
  • Logging and monitoring
  • Configuration management
  • Incident management
  • Change management
  • Risk management

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

Emergency access should also be consistent with the organization’s access-control policy, business continuity requirements, incident-response arrangements, and risk appetite.


38. Audit Evidence

Typical evidence includes:

  • Emergency Access Procedure
  • Emergency Access Register
  • Emergency access requests
  • Approval records
  • IAM role configuration
  • Temporary privilege records
  • MFA evidence
  • CloudTrail logs
  • Authentication logs
  • Privileged activity logs
  • Break-glass account review
  • Emergency change records
  • Access revocation evidence
  • Credential rotation evidence
  • Post-emergency reviews
  • Security exceptions
  • Corrective actions
  • Risk assessments
  • Management review records

An auditor should be able to trace an emergency access event from:

Why access was required → Who approved it → What access was granted → What was done → When it ended → Whether it was revoked → Whether the activity was reviewed.


39. Final Audit Trail

Emergency Identified
→ Access Need Identified
→ Normal Access Assessed
→ Minimum Privilege Defined
→ Risk Assessed
→ Emergency Access Approved
→ Named Access Enabled
→ MFA Applied
→ Expiry Defined
→ Monitoring Enabled
→ Emergency Activity Performed
→ Activity Logged
→ Evidence Preserved Where Required
→ Task Completed
→ Access Revoked
→ Sessions/Tokens Terminated
→ Credentials Rotated Where Required
→ Activity Reviewed
→ Risk Reassessed
→ Corrective Action Assigned
→ Emergency Access Closed


40. Final Principle

Emergency access should make the organization faster during a crisis without making the organization permanently less secure.

Justify → Minimize → Approve → Authenticate → Monitor → Use → Revoke → Review

The objective is:

Give the right person the minimum required access + for the shortest practical time + with strong authentication and monitoring + revoke it immediately when the emergency ends.

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