Third-Party Access Procedure
1. Purpose
The Third-Party Access Procedure defines how access provided to suppliers, consultants, contractors, auditors, partners, service providers, and other external parties is requested, assessed, approved, provisioned, monitored, reviewed, and revoked.
The objective is to ensure third-party access is:
- Business justified
- Authorized
- Limited to the required systems and information
- Based on least privilege
- Time-bound where practical
- Individually attributable
- Securely authenticated
- Monitored where appropriate
- Periodically reviewed
- Removed when no longer required
Core Principle
Business Need → Assess → Approve → Provision → Monitor → Review → Revoke
2. Scope
This procedure applies to external parties requiring access to:
- Corporate systems
- SaaS applications
- AWS/Azure/GCP environments
- Production systems
- Development/test environments
- Databases
- Source-code repositories
- Customer systems
- File-sharing platforms
- Security tools
- VPN/remote-access systems
- Physical facilities
- Confidential or Restricted information
Examples of third parties include:
- Consultants
- Contractors
- Auditors
- Certification bodies
- VAPT providers
- Managed service providers
- Cloud consultants
- Software vendors
- Customer representatives
- Implementation partners
- Outsourced service providers
- Supplier personnel
3. Third-Party Access Principles
Third-party access should follow these principles:
- Business Need – access must have a defined purpose.
- Least Privilege – provide only required permissions.
- Need-to-Know – restrict information access.
- Named Accounts – avoid shared accounts.
- Strong Authentication – MFA where appropriate.
- Time Limitation – define an expiry date where practical.
- Approval – appropriate owners approve access.
- Monitoring – monitor high-risk activity where appropriate.
- Review – periodically confirm continued need.
- Revocation – remove access when the need ends.
- Evidence – retain records of authorization and actions.
4. Third-Party Access Lifecycle
The complete lifecycle is:
Business Need
↓
Access Request
↓
Third-Party Verification
↓
Security/Risk Assessment
↓
Contract/NDA Review
↓
Access Scope Definition
↓
Approval
↓
Provision Access
↓
Verify
↓
Monitor
↓
Periodic Review
↓
Revoke
↓
Close & Record
5. Third-Party Access Request
Every request should record:
| Field | Details |
|---|---|
| Request ID | Unique ID |
| Third Party | Organization/person |
| Individual User | Named external user |
| Role | Consultant/Auditor/etc. |
| Internal Sponsor | Internal owner |
| Business Purpose | Why access is required |
| System | System/application |
| Environment | Production/Test/Development |
| Information | Information accessed |
| Classification | Public/Internal/Confidential/Restricted |
| Access Level | Read/Write/Admin/etc. |
| Start Date | Access commencement |
| Expiry Date | Access end |
| Contract/SOW | Reference |
| NDA | Applicable status |
| Approver | Authorized approver |
| System Owner | System owner |
| Security Approval | Where required |
| Status | Requested/Approved/Active/Closed |
6. Verify the Third Party
Before granting access, confirm:
- Third-party organization
- Individual’s identity
- Role
- Business relationship
- Internal sponsor
- Contract/SOW
- NDA/confidentiality requirements
- Purpose of access
- Required duration
- Systems involved
- Information involved
For higher-risk access, additional supplier/security due diligence may be appropriate.
7. Contract and Agreement Review
Before granting access to sensitive information or systems, verify applicable contractual requirements.
Consider:
- NDA
- Master Service Agreement
- Statement of Work
- Data Processing Agreement
- Security requirements
- Confidentiality obligations
- Incident notification requirements
- Data protection requirements
- Subcontractor requirements
- Data return/deletion requirements
- Access restrictions
- Audit/assurance requirements
Access should not be granted merely because a commercial relationship exists.
8. Security Risk Assessment
Assess the risk associated with the requested access.
Consider:
- Information classification
- System criticality
- Production access
- Privileged access
- Customer information
- Personal data
- Financial information
- Source code
- Security information
- Credentials/secrets
- Internet exposure
- Duration of access
- Third-party location
- Remote access
- Subcontractors
- Business impact
Higher-risk access should receive additional review and stronger controls.
9. Access Classification
Classify third-party access based on risk.
| Access Type | Example | Typical Control |
|---|---|---|
| Low | Public/Internal information | Standard authenticated access |
| Moderate | Confidential business information | Named account + controlled access |
| High | Customer data / production systems | Strong approval + MFA + monitoring |
| Critical | Privileged production/cloud access | Explicit approval + strong controls + close monitoring/review |
These categories are organizational examples and should be defined according to the organization’s risk methodology.
10. Define Access Scope
Clearly identify:
Systems
- Application
- Cloud account
- Database
- Repository
- SaaS platform
Environment
- Development
- Test
- Staging
- Production
Resources
- Specific project
- Specific database
- Specific repository
- Specific AWS account/resource
- Specific customer environment
Permissions
- Read
- Create
- Update
- Delete
- Export
- Configure
- Administer
Avoid:
“Full access to the system.”
unless full access is genuinely necessary and formally approved.
11. Third-Party Access Approval
Typical approval flow:
Internal Sponsor → System Owner → Data Owner/Security → Authorized Approver
Approval should consider:
- Business justification
- Scope
- Data classification
- Risk
- Duration
- Permissions
- Contractual requirements
- Security controls
Privileged or production access should receive additional approval where required.
12. Account Provisioning
Once approved:
- Create an individual account.
- Do not share employee accounts.
- Apply approved role.
- Apply least privilege.
- Enable MFA where required.
- Configure expiry where practical.
- Restrict network access where appropriate.
- Enable logging where required.
- Document the account.
Third-party accounts should normally be identifiable to a specific individual.
13. Third-Party Access to AWS
For AWS access:
- Use individual identities.
- Prefer centralized identity/SSO where appropriate.
- Use IAM roles with limited permissions.
- Enable MFA.
- Avoid sharing administrator credentials.
- Limit access to required accounts/resources.
- Use temporary credentials where practical.
- Log administrative activity.
- Review access periodically.
- Remove access when the engagement ends.
Example
A cloud consultant requires access to troubleshoot a production configuration.
Instead of:
Permanent AWS Administrator access
provide, where technically appropriate:
Named consultant identity → MFA → Limited IAM role → Required production resources → Defined expiry → Logging
14. Third-Party Production Access
Production access should be treated as higher risk.
Before granting:
- Business justification
- System owner approval
- Security review where required
- Contractual authorization
- Named user
- MFA
- Least privilege
- Defined duration
- Logging
- Monitoring where appropriate
- Review/expiry date
15. Third-Party Privileged Access
Privileged third-party access may include:
- Cloud administration
- Database administration
- Security administration
- Network administration
- Source-code administration
- Identity administration
- Production administration
For privileged access:
- Specific business need
- Explicit approval
- Named account
- MFA
- Limited permissions
- Defined duration
- Logging
- Monitoring where appropriate
- Privileged Access Register entry
- Periodic review
- Immediate revocation when no longer required
16. Third-Party Access to Customer Information
Before providing customer information:
- Confirm contractual authorization.
- Identify the exact information.
- Confirm classification.
- Minimize information.
- Verify the recipient.
- Check privacy requirements where applicable.
- Use an approved transfer/access mechanism.
- Define retention/deletion requirements.
- Record the access.
17. Third-Party Source-Code Access
For consultants or suppliers requiring source-code access:
- Approved repository
- Named account
- Specific repository/project
- Least privilege
- MFA
- Branch protections maintained
- No unnecessary repository administrator access
- Secrets excluded
- Access expiry configured
- Activity logged where appropriate
18. Third-Party Database Access
Direct database access should be carefully controlled.
Consider:
- Read-only access where possible
- Specific database/schema
- Production vs test
- Restricted network access
- MFA/strong authentication
- Logging
- Temporary access
- Query monitoring where appropriate
- Data minimization
- Access expiry
19. Third-Party Remote Access
Remote access should use approved mechanisms.
Examples:
- VPN
- Zero-trust access
- SSO
- Secure remote-access gateway
- Bastion/jump host
- Approved cloud access
Do not provide unrestricted remote network access when a narrower mechanism can satisfy the business requirement.
20. Temporary Third-Party Access
Temporary access should include:
- Start date
- End date
- Purpose
- System
- Permission level
- Approver
- Owner
- Expiry
Example
A VAPT provider requires AWS access from:
10 October → 15 October
Access should be configured to expire at the end of the approved period where technically possible.
21. Access Monitoring
Depending on risk, monitor:
- Login activity
- Privilege changes
- Administrative activity
- File access
- Database activity
- Cloud activity
- Configuration changes
- Source-code activity
- Data downloads
- Authentication failures
High-risk third-party activity should receive appropriate monitoring.
22. Periodic Access Review
Review third-party access based on risk and engagement requirements.
Check:
- Third party relationship remains active
- Individual is still engaged
- Business purpose remains valid
- System access remains necessary
- Permissions remain appropriate
- Production access remains justified
- Privileged access remains justified
- MFA remains enabled
- Expiry date remains appropriate
- Contract/SOW remains valid
23. Third-Party Access Review Record
| Third Party | User | System | Current Access | Required? | Action | Owner | Review Date | Status |
|---|---|---|---|---|---|---|---|---|
| Cloud Consultant | User A | AWS | Admin | Yes | Retain with controls | CTO | Date | Active |
| Auditor | User B | Audit Repository | Read | Yes | Retain | ISMS | Date | Active |
| Former Consultant | User C | GitHub | Write | No | Revoke | Engineering | Date | Closed |
24. Third-Party Access Revocation
Access must be revoked when:
- Contract ends
- SOW ends
- Project ends
- Individual leaves supplier
- Business need ends
- Temporary access expires
- Supplier relationship terminates
- Security incident requires immediate restriction
Review:
- SSO
- SaaS
- AWS/cloud
- VPN
- Source code
- Database
- Customer systems
- API keys
- SSH keys
- Tokens
- Certificates
- Physical access
25. Third-Party Offboarding
Use the following process:
Engagement End → Identify Access → Disable Accounts → Revoke Privileges → Revoke Tokens/Keys → Recover Information → Collect Assets → Confirm Data Return/Deletion → Verify → Update Registers → Close
Where contractually or legally required, obtain appropriate confirmation of information return or deletion.
26. Subcontractor Access
If a supplier uses subcontractors:
- Identify subcontractors where required.
- Determine whether subcontractor access is permitted.
- Assess security requirements.
- Confirm contractual authorization.
- Apply equivalent security requirements where appropriate.
- Identify individual users.
- Limit access.
- Review periodically.
- Revoke when no longer required.
A supplier should not automatically be allowed to provide organizational information or access to an unknown downstream party.
27. Shared Accounts
Third-party shared accounts should generally be avoided.
If technically unavoidable:
- Document justification.
- Identify accountable owner.
- Protect credentials securely.
- Restrict access.
- Monitor activity where possible.
- Change credentials when personnel change.
- Review regularly.
28. Third-Party Access Exceptions
| Exception ID | Third Party | System | Exception | Reason | Risk | Compensating Control | Approver | Expiry | Status |
|---|---|---|---|---|---|---|---|---|---|
| TPA-001 | Supplier | AWS | Temporary Admin | Emergency remediation | High | MFA + logging | CTO | Date | Closed |
Exceptions should be:
- Business justified
- Risk assessed
- Approved
- Time-bound where practical
- Monitored
- Closed when no longer required
29. Security Incident Involving Third-Party Access
Examples:
- Compromised supplier account
- Suspicious third-party login
- Unauthorized data access
- Exposed third-party credential
- Unauthorized privilege escalation
- Lost third-party device
- Supplier employee accessing systems outside approved scope
Response may include:
Disable Access → Revoke Sessions → Rotate Credentials → Preserve Evidence → Investigate → Assess Impact → Notify Relevant Parties → Remediate → Review
Follow the organization’s Incident Response and Data Breach Response procedures where applicable.
30. Third-Party Access Register
Maintain a dedicated register where useful.
| ID | Third Party | User | System | Role | Access Level | Data | Purpose | Start | Expiry | Approver | MFA | Review | Status |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| TPA-001 | |||||||||||||
| TPA-002 | |||||||||||||
| TPA-003 |
31. Evidence
Maintain appropriate evidence such as:
- Third-Party Access Request
- Contract/SOW
- NDA
- DPA where applicable
- Security assessment
- Risk assessment
- Access approval
- IAM configuration
- MFA evidence
- Access logs
- Privileged Access Register
- Access review records
- Temporary access records
- Access revocation evidence
- Data return/deletion confirmation where applicable
- Exception records
- Incident records
32. Common Mistakes
❌ Giving suppliers permanent access
Access should normally have a defined lifecycle.
❌ Using employee accounts for contractors
External users should normally have individually attributable accounts.
❌ Giving full administrator access
Grant only the permissions required.
❌ Forgetting third-party access after project completion
Project closure should trigger an access review.
❌ Ignoring subcontractors
Downstream access should be considered.
❌ No expiry date
Temporary access should have an appropriate expiry.
❌ No monitoring for high-risk access
Production and privileged third-party activity may require enhanced monitoring.
❌ Contract exists, therefore access is automatically acceptable
A commercial relationship does not by itself define the required security permissions.
33. Startup-Friendly Implementation
A startup can implement a simple workflow:
Step 1 — Identify
Who is the third party?
Step 2 — Define
What exactly do they need?
Step 3 — Assess
What information and systems are involved?
Step 4 — Approve
Manager/System Owner/Security as appropriate.
Step 5 — Provision
Named account + least privilege + MFA.
Step 6 — Monitor
Log and monitor higher-risk activity.
Step 7 — Review
Confirm continued need.
Step 8 — Revoke
Remove access when the work ends.
Step 9 — Evidence
Retain approval, access, review, and revocation records.
34. Example – External VAPT Provider
A SaaS company hires an external VAPT provider.
Requirement
The provider needs to test:
- Web application
- APIs
- Selected cloud resources
Process
Business Requirement
↓
VAPT Scope
↓
Supplier Verification
↓
NDA/SOW
↓
Risk Assessment
↓
Access Request
↓
Security/CTO Approval
↓
Named Account + MFA
↓
Limited Testing Access
↓
Logging/Monitoring
↓
VAPT
↓
Access Revocation
↓
Evidence
The provider should not automatically receive unrestricted production administrator access simply because they are performing a security assessment.
35. Relationship with Other ISMS Documents
The Third-Party Access Procedure connects with:
- Supplier Security Policy
- Supplier Security Assessment
- Third-Party Information Sharing Agreement
- External Data Sharing Procedure
- Access Control Policy
- Access Control Matrix
- User Access Request
- User Access Review Checklist
- Privileged Access Register
- Access Revocation Checklist
- Contractor Offboarding Checklist
- Information Classification Policy
- Data Handling Guidelines
- Cloud Asset Inventory
- SaaS Application Register
- Incident Response Plan
- Data Breach Response Procedure
- Risk Register
Complete Lifecycle
Supplier → Business Need → Risk Assessment → Contract → Access Request → Approval → Provision → Monitor → Review → Revoke
36. ISO 27001 Connection
The Third-Party Access Procedure supports applicable ISO/IEC 27001 requirements relating to:
- Access control
- Identity management
- Authentication
- Access rights
- Privileged access
- Information classification
- Supplier relationships
- Information transfer
- Monitoring
- Incident management
- Access removal
The exact controls applicable to the organization should be determined through its risk assessment and Statement of Applicability (SoA).
37. Final Audit Trail
An auditor should be able to trace:
Who is the third party?
↓
Why do they need access?
↓
What information/system do they access?
↓
What permissions were granted?
↓
Who approved the access?
↓
What security controls were applied?
↓
Was access reviewed?
↓
When was it revoked?
↓
Was revocation verified?
Final Principle
Third-party access should be treated as a controlled lifecycle, not a one-time permission. Give external parties only the access they need, for the period they need it, protect and monitor that access according to risk, review it regularly, and revoke it when the business need ends.
