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policies/Security/access_control_policy.md

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Access Control & Least Privilege Policy

Document owner: [Owner/Role]
Approved by: [Steering Committee / CISO]
Effective date: [YYYY-MM-DD]
Review cadence: [Annually]


1. Purpose & Scope

This policy establishes mandatory requirements for granting, reviewing, and revoking access to [Organization] systems and data, based on least privilege and need-to-know. It applies to all employees, contractors, vendors, and service accounts, and complements the account types defined in Authentication Policy §3.


2. Roles & Responsibilities

  • Access Owner (system/data owner): Approves access requests and grants for their system.
  • Manager: Approves role-appropriate access for direct reports; initiates leaver/mover requests.
  • IT/IAM: Provisions, reviews, and revokes access per this policy.

3. Policy Statements

3.1 Least Privilege & Need-to-Know

  • Access must be granted at the minimum level required for a person's role.
  • Standing access to TLP:AMBER+STRICT/RED data (per Data Classification Policy) must be justified and time-bound where feasible; prefer just-in-time elevation.

3.2 Role-Based Access Control

  • Access must be granted through defined roles mapped to job function, not ad hoc individual grants.
  • Direct/ad hoc grants outside a defined role must be logged, time-bound, and reviewed at next access review.
  • Role definitions must be documented and owned (see Authentication Policy §2.14).

3.3 Joiner-Mover-Leaver Lifecycle

  • Joiner: Access provisioned per role on or after start date; no standing access before identity verification completes.
  • Mover: Access must be updated within 5 business days of a role change; prior role's access must be removed, not just supplemented.
  • Leaver: Access must be revoked within 24 hours of termination (immediately for involuntary termination), consistent with Vendor Risk Management Policy §3.6 for third parties.

3.4 Separation of Duties

  • Conflicting duties (e.g., payment initiation and approval, code deployment and production access approval) must not be held by the same individual without a documented compensating control.
  • A separation-of-duties conflict matrix must be maintained for financial and production-critical systems.

3.5 Periodic Access Reviews

Account Type (per Authentication Policy §3) Review Cadence
Privileged/Admin Quarterly
Standard User Semi-annually
Third-party/Vendor Per contract term, minimum annually
Service/Machine Annually, plus on owner change
  • Reviews must be performed by the Access Owner, not solely by IT.
  • Unreviewed access past the cadence must be treated as a finding and escalated.

3.6 Emergency / Break-Glass Access

3.7 AI Agent Capability Scoping

  • For AI Agent (Autonomous) accounts (per Authentication Policy §3.1), RBAC role membership alone is not sufficient — the tool/plugin/MCP-server allow-list reachable by the agent is its privilege boundary and must be reviewed and approved with the same rigor as a role grant.
  • A sub-agent's capability set must be a subset of its parent's; delegation must not widen scope.
  • Agent capability grants must be reviewed at the same cadence as Privileged/Admin access (§3.5) given the runtime-decided, non-enumerable nature of agent action sequences.

3.8 Enforcement

  • Violations may result in disciplinary action or revocation of access.
  • Systems unable to support role-based provisioning or timely revocation must be remediated or formally excepted with CISO approval.

4. Antifragility Alignment

This policy is built to the five pillars of the organization's internal Antifragile Enterprise Manifest.

Pillar Applied In How
1. Structural Decoupling §3.2 Role definitions are documented independent of any single IAM vendor's proprietary grouping model
2. Optionality Preservation §3.1 Just-in-time elevation preferred over standing access — preserves the option to say no without an offboarding project
3. Stress-to-Signal Conversion §3.5 Unreviewed access past cadence is a tracked finding, not silence
4. Sovereign Intelligence §3.2 Roles and SoD matrix documented and owned, not held as tribal "ask Dave" knowledge
5. Asymmetric Payoff Design (Barbell) §3.5 Quarterly review concentrated on privileged accounts; standard users get a lighter semi-annual cadence

5. References