1. Purpose
The Identity Register is a centralized record of identities used to access the organization’s information, systems, applications, cloud environments, SaaS platforms, and services.
It helps the organization:
- Know what identities exist.
- Identify who or what each identity belongs to.
- Assign an accountable owner.
- Understand the purpose of each identity.
- Track identity status and lifecycle.
- Identify privileged and high-risk identities.
- Support access reviews.
- Support Joiner-Mover-Leaver activities.
- Identify dormant or unauthorized identities.
- Maintain audit evidence.
Core Principle
Every important identity should be known, owned, justified, appropriately protected, periodically reviewed, and removed when no longer required.
2. Scope
The register may include:
- Employee identities
- Contractor identities
- Consultant identities
- Intern identities
- Temporary identities
- Third-party identities
- Privileged identities
- Administrative identities
- Service accounts
- Application identities
- Cloud identities
- API identities
- Emergency/break-glass identities
It may cover identities associated with:
- Identity providers
- SSO
- SaaS applications
- AWS/Azure/GCP
- Servers
- Databases
- Source-code repositories
- CI/CD
- VPN
- Security tools
- Business applications
- Customer environments
Where service or machine identities are maintained in a separate register, this Identity Register should reference that register.
3. Identity Register – Master Template
| Field | Description |
|---|---|
| Identity ID | Unique identifier |
| Identity Name | Name/username/account |
| Identity Type | Employee/Contractor/Third Party/Privileged/Service etc. |
| Person/Entity | Person or system associated with identity |
| Employee/Contractor ID | HR or engagement reference |
| Department | Department/business unit |
| Job Role | Current role |
| Manager/Sponsor | Responsible manager or sponsor |
| Identity Provider | IdP/SSO used |
| System/Application | System associated with identity |
| Environment | Production/Test/Development |
| Account Type | Standard/Privileged/Temporary/Emergency |
| Business Purpose | Reason identity exists |
| Access Level | User/Admin/Read/Write etc. |
| Privileged Access | Yes/No |
| Information Accessed | Information/data accessed |
| Classification | Public/Internal/Confidential/Restricted |
| MFA | Enabled/Not Enabled/N/A |
| SSO | Yes/No |
| Start Date | Identity activation date |
| Expiry Date | If applicable |
| Status | Active/Disabled/Expired/Removed |
| Last Activity | Last known activity |
| Last Access Review | Most recent review |
| Next Review | Next review date |
| Identity Owner | Accountable owner |
| System Owner | System/application owner |
| Related Risk ID | Risk reference |
| Related Access Request | Request reference |
| Related JML ID | JML reference |
| Evidence | Evidence location/reference |
| Remarks | Additional information |
4. Example Identity Register
| Identity ID | Identity | Type | System | Role | Privileged | MFA | Status |
|---|---|---|---|---|---|---|---|
| ID-001 | user1@company.com | Employee | Microsoft 365 | Developer | No | Yes | Active |
| ID-002 | user2@company.com | Employee | AWS | DevOps | Yes | Yes | Active |
| ID-003 | auditor@vendor.com | Third Party | Audit Repository | Auditor | No | Yes | Active |
| ID-004 | svc-backup | Service | AWS | Backup Service | Yes | N/A | Active |
| ID-005 | breakglass-admin | Emergency | AWS | Emergency Admin | Yes | Yes | Active |
The examples above should be replaced with the organization’s actual identities.
5. Identity Types
Use a controlled list for consistent classification.
| Identity Type | Description |
|---|---|
| Employee | Internal employee |
| Contractor | Contractor or consultant |
| Intern | Intern or trainee |
| Temporary | Temporary worker |
| Third Party | External supplier/customer/auditor |
| Privileged | Administrative identity |
| Service | Automated service account |
| Application | Application-to-system identity |
| API | API credential/identity |
| Machine | Workload/device identity |
| Emergency | Break-glass identity |
6. Identity Status
Recommended status values:
- Pending
- Active
- Suspended
- Disabled
- Expired
- Removed
- Under Review
Status Lifecycle
Pending → Active → Suspended/Disabled → Removed
Temporary identities may follow:
Pending → Active → Expired → Removed
7. Identity Ownership
Each important identity should have an accountable owner.
The owner may be:
- IT Manager
- System Owner
- Application Owner
- Security Lead
- Cloud Owner
- Business Owner
- Internal Sponsor
For individual employee identities, the person may be the identity subject, while accountability for the identity-management process remains with the appropriate organizational function.
8. Business Purpose
Each non-standard or higher-risk identity should have a documented purpose.
Examples:
Employee
Software development and approved access to engineering systems.
Privileged Identity
Administration of AWS production infrastructure.
Third-Party Identity
External SOC 2 auditor requires read-only access to approved audit evidence.
Service Account
Automated database backup process.
Emergency Identity
Emergency recovery of the AWS identity-management environment.
Avoid vague descriptions such as:
“General access.”
9. Identity-to-System Mapping
An identity may have access to multiple systems.
Where appropriate, maintain a mapping.
| Identity | System | Environment | Role | Access Level | Approval |
|---|---|---|---|---|---|
| User A | GitHub | Production | Developer | Write | Approved |
| User A | AWS | Development | Developer | Read/Write | Approved |
| User A | Jira | Production | User | Standard | Approved |
| User A | Salesforce | Production | None | None | N/A |
This helps identify unnecessary access during reviews.
10. Identity Lifecycle
The register should be updated throughout the identity lifecycle.
Joiner
Request → Approval → Create Identity → Record → Provision → Verify
Mover
Role Change → Review Identity → Modify Access → Update Register → Verify
Leaver
Exit → Disable/Revoke → Update Register → Verify → Remove
The register should not be treated as a one-time inventory.
11. Identity Creation
When a new identity is created, record:
- Identity ID
- Identity name
- Person/system
- Type
- Role
- Business purpose
- System
- Access level
- Owner
- Approver
- Start date
- Expiry date where applicable
- Authentication controls
- Related request
- Status
12. Identity Modification
When an identity or its associated access changes, update the register.
Examples:
- Job role change
- Department change
- System change
- Privilege change
- Manager change
- Third-party engagement extension
- Access level change
- Authentication method change
- Ownership change
The old access should be reviewed rather than simply adding new access.
13. Identity Termination
When an identity is no longer required:
- Disable/revoke access.
- Terminate active sessions where appropriate.
- Revoke credentials/tokens where required.
- Review privileged access.
- Review cloud access.
- Review SaaS access.
- Review API/SSH credentials.
- Update the Identity Register.
- Record evidence.
- Mark the identity as Disabled, Expired, or Removed.
14. Privileged Identity Register Linkage
Privileged identities should also be recorded in the Privileged Access Register.
The two registers serve different purposes:
| Identity Register | Privileged Access Register |
|---|---|
| Records identities | Focuses on elevated access |
| Identity lifecycle | Privileged-access justification |
| Identity status | Privilege level |
| Identity owner | Privileged approval |
| Authentication | Privileged monitoring/review |
| JML linkage | Privilege review |
The Identity Register should reference the corresponding Privileged Access Register record where applicable.
15. Third-Party Identity Management
For external identities, record:
- Third party
- Individual
- Internal sponsor
- Contract/SOW
- Business purpose
- Systems accessed
- Information accessed
- Access level
- Start date
- Expiry date
- MFA
- Owner
- Approval
- Review date
Third-party identities should normally have a defined expiry or review point.
16. Temporary Identity Management
Temporary identities should include:
- Start date
- Expiry date
- Business purpose
- Approver
- Owner
- Access scope
- Review date
Example:
External VAPT consultant receives temporary access to a testing environment for the approved assessment period.
At expiry:
Review → Extend if justified → Otherwise Disable/Remove
17. Dormant Identity Review
The organization should periodically identify identities that have not been used or have no current business justification.
Review:
- Last activity
- User status
- Employment status
- Business purpose
- System
- Privilege level
- Owner
Possible outcomes:
- Retain
- Disable
- Remove
- Investigate
- Confirm business justification
The inactivity threshold should be defined according to organizational risk rather than assumed to be a universal ISO requirement.
18. Service and Application Identities
Service and application identities should have:
- Unique identifier
- Purpose
- Owner
- System
- Application
- Permissions
- Credential storage method
- Credential rotation requirements
- Interactive login status
- Dependencies
- Review date
- Status
Example:
| Identity | Purpose | Owner | System | Privilege |
|---|---|---|---|---|
| svc-backup | Database backup | IT | AWS | Backup access |
| svc-deploy | CI/CD deployment | DevOps | AWS | Deployment role |
19. AWS Identity Register Example
For an AWS SaaS organization, identity records may include:
- IAM Identity Center users
- Federated users
- IAM roles
- Break-glass identities
- Service identities
- Workload identities
Example:
| Identity | AWS Account | Role | Environment | Owner | MFA | Status |
|---|---|---|---|---|---|---|
| Developer A | Dev Account | Developer | Dev | Engineering | Yes | Active |
| DevOps A | Prod Account | DevOps Admin | Prod | CTO | Yes | Active |
| Security A | Security Account | Security Admin | Prod | Security | Yes | Active |
| Breakglass | Prod Account | Emergency Admin | Prod | CTO | Yes | Active |
Where AWS IAM Identity Center or another federation model is used, the organization should avoid maintaining unnecessary standalone IAM users.
20. Identity Authentication Information
The Identity Register should not store actual passwords, API secrets, private keys, recovery codes, or other authentication secrets.
Instead, record metadata such as:
- MFA enabled
- Authentication method
- Credential owner
- Credential location
- Credential status
- Rotation requirement
Example:
API credential stored in approved secrets-management platform.
Never enter the actual secret into the Identity Register.
21. Access Review
The Identity Register should support periodic access reviews.
The reviewer should compare:
Identity Register → HR/Contractor Records → Actual System Accounts → Access Control Matrix → Privileged Access Register
Review for:
- Unknown identities
- Former employees
- Role changes
- Excessive access
- Dormant accounts
- Privileged identities
- Third-party accounts
- Temporary accounts
- Missing owners
- Missing approvals
- MFA exceptions
The results should be documented in the Access Review Report.
22. Reconciliation Process
A practical reconciliation process is:
Identity Register
↓
Identity Provider / SSO
↓
Application Accounts
↓
Cloud Accounts
↓
HR / Contractor Records
↓
Third-Party Records
↓
Identify Differences
↓
Investigate
↓
Correct
↓
Update Register
↓
Retain Evidence
23. Unknown Identity Management
If an identity is found that is not present in the register:
- Identify the owner.
- Identify the business purpose.
- Verify authorization.
- Determine access level.
- Assess risk.
- Add it to the register if legitimate.
- Remove/disable it if unauthorized or unnecessary.
- Investigate as a potential security issue where appropriate.
- Record the action.
Unknown identities should not simply be added without validation.
24. Identity Review Record
| Identity ID | Review Date | Reviewer | Business Need | Access Appropriate | MFA | Status | Action |
|---|---|---|---|---|---|---|---|
| ID-001 | Yes | Yes | Yes | Active | None | ||
| ID-002 | Yes | No | Yes | Active | Reduce Access | ||
| ID-003 | No | No | Yes | Active | Disable |
25. Identity Changes Log
Maintain a history of important identity changes.
| Change ID | Identity | Change | Reason | Approved By | Date | Evidence |
|---|---|---|---|---|---|---|
| IC-001 | ID-001 | Role changed | Promotion | Manager | ||
| IC-002 | ID-002 | Privilege reduced | Access review | System Owner | ||
| IC-003 | ID-003 | Account disabled | Engagement ended | Sponsor |
26. Identity Exceptions
Document exceptions such as:
- Shared account
- Missing MFA
- Temporary privilege
- Extended third-party access
- Legacy account
- Technical limitation
- Emergency account
| Exception ID | Identity | Issue | Reason | Risk | Compensating Control | Owner | Expiry |
|---|---|---|---|---|---|---|---|
27. Identity Register Review Frequency
The register should be maintained continuously as identities change.
Formal reviews should be performed at a frequency appropriate to:
- System criticality
- Information sensitivity
- Privilege level
- User population
- Third-party risk
- Regulatory/contractual requirements
- Organizational risk
Examples:
- Privileged identities: more frequent review
- Production access: risk-based enhanced review
- Third-party identities: periodic or engagement-based review
- Standard identities: periodic review
- Temporary identities: review at or before expiry
These are practical examples, not universal ISO 27001 frequencies.
28. Data Quality Checks
Before an identity register review is closed, verify:
- Identity ID exists
- Identity owner exists
- Identity type is defined
- Business purpose is documented
- System is identified
- Role/access is documented
- Status is current
- Start date is recorded
- Expiry exists where applicable
- Privileged status is accurate
- MFA status is accurate
- Last review is recorded
- Evidence reference exists
29. Audit Evidence
Evidence supporting the Identity Register may include:
- Identity-provider export
- SSO user list
- Application user list
- AWS IAM/Identity Center records
- HR employee list
- Contractor list
- Third-party access records
- User Access Requests
- Access approvals
- JML records
- Privileged Access Register
- Access Review Reports
- Access Revocation Checklists
- Identity change records
- MFA configuration
- Relevant audit logs
- Exception records
The actual register should not contain authentication secrets.
30. Common Mistakes
Mistake 1: Treating the register as a simple employee list
An employee can have multiple identities and privileged accounts.
Mistake 2: Ignoring service accounts
Machine identities can have significant access.
Mistake 3: Not recording third-party identities
External users also need lifecycle management.
Mistake 4: No owner
Every important identity should have accountability.
Mistake 5: Storing passwords or secrets
Never store authentication secrets in the register.
Mistake 6: Not updating after role changes
Mover events can create privilege accumulation.
Mistake 7: Forgetting cloud identities
Cloud access may exist independently from corporate applications.
Mistake 8: Not reconciling with actual systems
The register should reflect reality, not just planned access.
31. Startup-Friendly Implementation
A startup does not need a complicated IAM database to establish identity visibility.
A practical model is:
Step 1 – Central Identity
Maintain a primary identity provider.
Step 2 – Master Identity Register
Record people, identities, systems, owners and status.
Step 3 – Privileged Register
Track administrative identities separately.
Step 4 – JML
Connect HR events to identity lifecycle.
Step 5 – Access Review
Periodically reconcile the register with actual systems.
Step 6 – Revocation
Remove identities when business need ends.
Step 7 – Evidence
Keep approval, review and revocation evidence.
32. Relationship with Other ISMS Documents
The Identity Register connects several identity and access controls:
Identity Management Policy
↓
Identity Register
↓
User Account Management Procedure
↓
User Access Request
↓
Access Control Matrix
↓
JML Procedure
↓
Privileged Access Register
↓
Third-Party Access Procedure
↓
Access Review Report
↓
Access Revocation Checklist
↓
Incident Management
This creates a traceable identity lifecycle.
33. ISO 27001 Connection
The Identity Register supports applicable ISO/IEC 27001 requirements relating to:
- Identity management
- Authentication information
- Access rights
- Access restriction
- Privileged access
- Segregation of duties
- Access review
- Supplier/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).
34. Final Audit Trail
An auditor should be able to select an identity and trace:
Identity
→ Who or what does it belong to?
→ Why does it exist?
→ Who owns it?
→ Which system does it access?
→ What permissions does it have?
→ Who approved it?
→ Is authentication appropriately protected?
→ Was it reviewed?
→ Was it modified when the role changed?
→ Was it revoked when no longer required?
→ Is evidence available?
Final Principle
Know every important identity, know who or what it belongs to, understand why it exists, control what it can access, review it periodically, and remove it when it is no longer required.
