6.6.2 User access management
User registration and deregistration for people who administer or operate systems processing personal data must address compromise of their access credentials, deactivated or expired user identifiers must never be reissu
5
artefacts
0
held by a system
3
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Evidence that identifiers on systems processing personal data are never reissued · Data governance / DLP tooling
- Current user profile record supporting attribution of access and change · Document repository
- Access review records · Identity provider / directory
governing documentDocuments that govern the control
- Registration and deregistration procedures covering credential compromise · Policy repository / GRC workspace
- Documented split of identity and access management responsibility with customers, and the administrative means provided to them · Document repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Identifiers reissued to new joiners, so historical access records point at the wrong person
- Attribution impossible because operations run through a shared service account
- Customer responsibility for access management assumed but never written down, so neither party performs it
- Credential compromise handled as a security incident with no consideration of the personal data exposed
- Profile records maintained at creation and never on change
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet6.6.1 Business requirements of access control · 6.6.3 User responsibilities