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Access Control Standard

An access control standard specifies the technical requirements that authentication mechanisms, authorisation models, and session management must satisfy. This standard establishes minimum requirements for all systems that store, process, or transmit organisational data. Individual systems may impose stricter controls based on data sensitivity or regulatory obligations, but no system may operate below these baselines.

The standard applies to all systems under organisational control, including cloud services, on-premises infrastructure, and third-party platforms where the organisation maintains administrative responsibility. Systems managed entirely by third parties fall under contractual security requirements rather than this standard directly, though vendor assessments must verify equivalent controls exist.

Authentication
The process of verifying that an entity is who or what it claims to be, typically through credentials, tokens, or biometric factors.
Authorisation
The process of determining what actions an authenticated entity is permitted to perform on specific resources.
Principal
Any entity that can be authenticated and granted permissions: human users, service accounts, automated processes, or federated identities.
Privileged access
Access rights that permit modification of security controls, system configuration, or other principals’ permissions.

Authentication requirements

Authentication mechanisms must verify principal identity before granting any system access. The strength of authentication required scales with the sensitivity of accessible data and the privilege level of the account.

Password requirements

Passwords remain acceptable as a single authentication factor only for systems classified as low sensitivity with no access to personal data. All other systems require passwords combined with additional factors or passwordless authentication methods.

Account typeMinimum lengthComplexityMaximum ageHistory
Standard user12 charactersNo composition rulesNo expiry5 previous
Privileged user16 charactersNo composition rulesNo expiry10 previous
Service account24 charactersGenerated random365 daysNot reused
Emergency/break-glass24 charactersGenerated randomSingle useNot applicable
Local administrator20 charactersGenerated random180 daysNot reused

Password complexity rules requiring specific character classes (uppercase, lowercase, numbers, symbols) reduce effective entropy by constraining user choices and encouraging predictable substitution patterns. Length provides greater security than composition requirements. A 12-character password without complexity rules drawn from a 95-character set provides approximately 79 bits of entropy, compared to 52 bits from an 8-character password with complexity requirements where users predictably select “Password1!”.

Systems must implement the following password controls:

ControlRequirement
Lockout threshold10 failed attempts within 15 minutes
Lockout duration30 minutes or manual unlock
Lockout scopePer-account, not per-source-IP
Breach detectionCheck against known compromised password databases at creation and change
Storagebcrypt with cost factor 12, Argon2id, or scrypt; never MD5, SHA-1, or unsalted hashes
TransmissionTLS 1.2 or higher only; never transmitted in URL parameters or logs

Multi-factor authentication requirements

Multi-factor authentication (MFA) combines two or more independent verification methods from different categories: something the principal knows (password, PIN), something the principal possesses (hardware token, registered device), or something the principal is (biometric). Using two methods from the same category does not constitute MFA.

System classificationMFA requirement
High sensitivity (personal data, financial, privileged access)Required for all access
Medium sensitivity (internal business data)Required for remote access; recommended for all access
Low sensitivity (public information only)Not required
Administrative interfacesRequired regardless of classification
Cloud platform consolesRequired regardless of classification
Email and collaboration platformsRequired for all users
VPN and remote accessRequired for all users

MFA methods vary in resistance to interception and phishing attacks. The following table ranks methods by security strength:

MethodPhishing resistantTheft resistantAcceptable for
FIDO2/WebAuthn hardware keysYesYesAll systems
Platform authenticators (Windows Hello, Touch ID)YesYesAll systems
FIDO2 passkeys (synced)YesPartialAll systems
Authenticator app (TOTP)NoYesMedium sensitivity
Authenticator app (push notification)NoPartialMedium sensitivity with number matching
SMS one-time passwordNoNoLow sensitivity only; not for privileged accounts
Email one-time passwordNoNoLow sensitivity only; not for privileged accounts

Privileged accounts require phishing-resistant MFA methods. SMS and email-based one-time passwords are unacceptable for any account with administrative capabilities or access to high-sensitivity data, as these channels are vulnerable to SIM swapping, call forwarding attacks, and email compromise.

Push notification authentication must implement number matching, where the authenticator displays a number that the user must enter at the authentication prompt. This control prevents MFA fatigue attacks where adversaries repeatedly trigger push notifications until the user approves.

Passwordless authentication

Systems should support passwordless authentication through FIDO2/WebAuthn where technically feasible. Passwordless authentication eliminates the password as an attack vector entirely, relying on cryptographic proof of possession of a registered authenticator. The authenticator may additionally require biometric or PIN verification for user presence.

Passwordless authentication satisfies MFA requirements when the authenticator itself requires multi-factor verification (for example, a hardware key with PIN, or a platform authenticator with biometric).

Authorisation model

Authorisation determines what actions authenticated principals may perform. The authorisation model must implement least privilege, granting only the minimum permissions necessary for each principal’s legitimate functions.

Role-based access control

Role-based access control (RBAC) assigns permissions to roles, then assigns principals to roles. A role represents a job function or responsibility within the organisation. Principals inherit all permissions of their assigned roles, and nothing more.

+------------------------------------------------------------------+
| RBAC STRUCTURE |
+------------------------------------------------------------------+
| |
| +-------------+ +-------------+ +-------------+ |
| | Principal | | Principal | | Principal | |
| | (User A) | | (User B) | | (Service X) | |
| +------+------+ +------+------+ +------+------+ |
| | | | |
| v v v |
| +------+------+ +-----+-------+ +-----+-------+ |
| | Role: | | Role: | | Role: | |
| | Finance | | Finance | | Backup | |
| | Analyst | | Manager | | Service | |
| +------+------+ +------+------+ +------+------+ |
| | | | |
| v v v |
| +------+------+ +-----+-------+ +-----+-------+ |
| | Permissions:| | Permissions:| | Permissions:| |
| | - View | | - View | | - Read all | |
| | reports | | reports | | files | |
| | - Run | | - Run | | - Write to | |
| | queries | | queries | | backup | |
| | | | - Approve | | storage | |
| | | | payments | | | |
| +-------------+ +-------------+ +-------------+ |
| |
+------------------------------------------------------------------+

Figure 1: RBAC model showing principals assigned to roles, which carry specific permissions

Role design must follow these requirements:

RequirementSpecification
Role granularityRoles must be granular enough that users do not require permissions they do not use; a role granting unused permissions violates least privilege
Role documentationEach role must have documented purpose, intended assignees, and permission rationale
Role ownershipEach role must have a designated owner responsible for membership and periodic review
Separation of dutiesRoles must enforce separation of duties for sensitive operations; no single role may both initiate and approve the same transaction type
Inheritance limitsRole hierarchies must not exceed 3 levels; deeper nesting obscures effective permissions
Maximum roles per userUsers should hold no more than 5 concurrent roles; additional roles require documented justification

Attribute-based access control

Attribute-based access control (ABAC) evaluates access requests against policies that consider attributes of the principal, resource, action, and environment. ABAC provides finer-grained control than RBAC alone and handles dynamic conditions such as time, location, or device posture.

Organisations may implement ABAC as a layer above RBAC, where role membership is one attribute among many. A policy might grant access when the principal has the “Finance” role AND the request originates from a managed device AND the current time falls within business hours AND the resource’s data classification does not exceed the principal’s clearance level.

Attribute categoryExample attributes
PrincipalRole, department, clearance level, employment status, training completion
ResourceData classification, owner, creation date, sensitivity tags
ActionRead, write, delete, export, share
EnvironmentTime, location, device posture, network zone, authentication method strength

ABAC policies must be documented, version-controlled, and tested before deployment. Policy changes require review and approval equivalent to code changes.

Privileged access requirements

Privileged accounts require additional controls beyond standard authentication and authorisation. Compromise of a privileged account threatens the entire environment, not merely the data that account directly accesses.

Privileged account types

Account typeDefinitionExamples
System administratorAccounts with ability to modify system configuration, security controls, or other accountsDomain Admin, root, Azure Global Administrator
Security administratorAccounts with ability to modify security policies, access logs, or detection systemsSecurity Operations, SIEM Administrator
Application administratorAccounts with ability to modify application configuration or access all application dataDatabase Administrator, SaaS tenant admin
Network administratorAccounts with ability to modify network configuration or intercept trafficFirewall admin, network device credentials
Backup administratorAccounts with ability to access backup data or modify backup configurationBackup operator, recovery service accounts

Privileged access controls

ControlRequirement
Dedicated accountsAdministrators must use separate accounts for privileged activities; daily work uses standard accounts
Privileged access workstationsHigh-sensitivity environments require dedicated devices for privileged access, isolated from email, web browsing, and general productivity applications
Just-in-time accessWhere technically feasible, privileged access should be provisioned on-demand for limited duration rather than standing
Session recordingAdministrative sessions on critical systems must be recorded for forensic and audit purposes
Command loggingCommands executed with elevated privileges must be logged with timestamp, principal identity, and full command text
Break-glass proceduresEmergency access mechanisms must exist for scenarios where normal privileged access is unavailable; these procedures must be documented, tested, and audited when invoked

Privilege escalation

Privilege escalation paths must be explicitly defined and controlled. No principal should obtain elevated permissions except through documented, auditable mechanisms.

Escalation typeAcceptable mechanism
Temporary elevation (same session)sudo, runas with logged invocation
On-demand privileged accessJust-in-time provisioning through approved PAM system with automatic expiry
Emergency accessBreak-glass procedure with mandatory incident documentation
Permanent privilege grantFormal access request with management approval and documented justification

Implicit privilege escalation through misconfigured permissions, overly broad service accounts, or unmonitored automation scripts constitutes a control failure requiring immediate remediation.

Service account requirements

Service accounts authenticate automated processes, applications, and system integrations rather than human users. Service accounts require distinct controls because they cannot respond to MFA prompts, often require persistent credentials, and their activity patterns differ fundamentally from human users.

RequirementSpecification
Purpose documentationEach service account must have documented purpose, owning system, responsible administrator, and data accessed
Unique accountsEach application or service must use its own dedicated service account; shared service accounts are prohibited
Credential typeUse managed identities, workload identity federation, or certificate authentication where supported; API keys or passwords only where unavoidable
Credential storageService credentials must be stored in secrets management systems, not in code repositories, configuration files, or environment variables accessible to unprivileged processes
Credential rotationService account credentials must rotate on schedule: certificates every 365 days, passwords every 365 days, API keys every 180 days
Least privilegeService accounts must have minimum permissions for their function; “administrator” or equivalent permissions on service accounts require documented exception
MonitoringService account activity must be logged and monitored for anomalous behaviour: unusual source locations, access times, or action patterns
InventoryMaintain a complete inventory of service accounts with owner, purpose, systems accessed, and last review date

Service accounts must not have interactive logon capability except where specifically required for the service function, in which case interactive logon must be restricted to designated service hosts.

Access review requirements

Access reviews verify that granted permissions remain appropriate. Without periodic review, permission accumulation occurs as principals change roles, projects conclude, and temporary access persists beyond its intended duration.

Review typeScopeFrequencyReviewer
Privileged accessAll accounts with administrative permissionsQuarterlySecurity team with system owner sign-off
High-sensitivity systemsAll accounts with access to systems classified high sensitivityQuarterlySystem owner
Standard accessAll accounts with access to medium-sensitivity systemsSemi-annuallySystem owner or delegate
Service accountsAll service accounts and their permissionsSemi-annuallyService owner and security team
External accessAll accounts belonging to external parties (contractors, partners, vendors)QuarterlyRelationship owner and security team
Dormant accountsAccounts with no authentication in 90 daysMonthlyAutomated identification; manual review before action

Review outcomes must be documented with the following information: reviewer identity, review date, accounts reviewed, decisions made (retain, modify, revoke), and justification for retained access. Reviewers must attest that they have verified each access grant remains necessary.

Identified violations must be remediated within defined timeframes:

Finding severityRemediation timeframe
Privileged access without valid justification24 hours
Access to high-sensitivity data without valid justification48 hours
Dormant privileged account24 hours (disable)
Dormant standard account7 days (disable)
Excessive permissions (more than role requires)14 days
Missing access review completion7 days (escalate to management)

Session management requirements

Sessions maintain authentication state after initial verification, eliminating the need to re-authenticate for each request. Session controls balance usability against the risk of session hijacking or abandoned sessions providing unauthorised access.

ControlRequirement
Session timeout (idle)15 minutes for high-sensitivity systems; 30 minutes for medium-sensitivity systems; 8 hours maximum for any system
Session timeout (absolute)12 hours maximum regardless of activity; 8 hours for privileged sessions
Concurrent sessionsLimit concurrent sessions per account based on legitimate need; alert on unusual patterns
Session bindingSessions should be bound to client characteristics (IP address, device fingerprint) where practical; changes should prompt re-authentication
Session terminationExplicit logout must invalidate session server-side, not merely clear client-side tokens
Token securitySession tokens must be generated using cryptographically secure random number generators; minimum 128 bits of entropy
Token transmissionSession tokens transmitted only over encrypted channels; Secure flag required for cookies; HttpOnly and SameSite attributes required
Token storageSession tokens should not be stored in localStorage; sessionStorage or HttpOnly cookies preferred

Re-authentication must be required for sensitive operations regardless of session validity:

OperationRe-authentication requirement
Password changeCurrent password required
MFA configuration changeCurrent MFA verification required
Email address changeCurrent password and MFA required
Payment or financial transaction above thresholdMFA required
Export of bulk dataMFA required
Access to particularly sensitive recordsStep-up authentication appropriate to data classification

Federated authentication requirements

Federation allows principals authenticated by one identity provider to access resources in another organisation’s systems without maintaining separate credentials. Federation reduces credential proliferation but introduces dependencies on external identity providers and requires trust relationships to be carefully scoped.

RequirementSpecification
ProtocolSAML 2.0 or OpenID Connect; WS-Federation acceptable for legacy systems; proprietary federation protocols prohibited
Identity provider vettingExternal identity providers must demonstrate security controls equivalent to organisational standards before federation trust establishment
Attribute mappingMap only necessary attributes from external assertions; do not blindly accept all provided attributes
Group/role mappingExternal group memberships should map to local roles rather than directly to permissions; review mappings semi-annually
Session lifetimeFederated sessions should have shorter maximum lifetime than internal sessions: 8 hours maximum
Just-in-time provisioningProvision federated user accounts at first access; disable accounts not accessed within 90 days
Federation agreementDocument federation relationships including: identity provider, permitted applications, attribute mappings, security requirements, termination provisions

Implementation by system type

The following table provides lookup reference for how requirements apply to common system categories. Specific systems may require stricter controls based on risk assessment.

System typeMFA requiredSession timeoutPrivileged access controlsReview frequency
Identity provider (IdP)Yes, phishing-resistant15 min idle / 8 hr absoluteFull PAM controlsQuarterly
Cloud platform console (AWS, Azure, GCP)Yes, phishing-resistant15 min idle / 8 hr absoluteFull PAM controlsQuarterly
Email and collaborationYes30 min idle / 12 hr absoluteDedicated admin accountsSemi-annually
Finance and ERPYes15 min idle / 8 hr absoluteDedicated admin accountsQuarterly
HR and payrollYes15 min idle / 8 hr absoluteDedicated admin accountsQuarterly
Case management (beneficiary data)Yes15 min idle / 8 hr absoluteDedicated admin accountsQuarterly
CRM and fundraisingYes30 min idle / 12 hr absoluteDedicated admin accountsSemi-annually
Internal wiki/documentationConditional8 hr idle / 24 hr absoluteRole-based adminAnnually
Public website CMSYes for admin30 min idle / 12 hr absoluteDedicated admin accountsSemi-annually

Exceptions

Exceptions to this standard require documented approval from the information security function and the system owner’s management chain. Exception requests must include:

  • Specific requirement(s) to be excepted
  • Business or technical justification
  • Compensating controls implemented
  • Risk assessment with residual risk acceptance
  • Review date (maximum 12 months)
  • Accountable individual

Exceptions do not exempt systems from review and audit. Excepted controls must be re-evaluated at each review date, and exceptions renewed only if the original justification remains valid and no compliant alternative has become available.

See also