ISO/IEC 27701:2025 A.3.9 — Access rights

What this control requires

Provision, review, modify and remove access rights per policy. Implementation: Implement access provisioning and periodic review processes. Justification: Limits unauthorized access to PII.

In plain English

Provision, review, modify and remove access rights per policy. In practice, this means you can prove you implement access rights-level controls on a defined cadence.

Why it matters

ISO 27701 is the international way to evidence the GDPR principle of accountability: certified PIMS controls translate directly into the records, contracts and rights-handling that supervisory authorities want, and into the privacy-engineering evidence SOC 2 + Privacy auditors and enterprise procurement teams ask for.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

PIMS auditors expect ISO 27001 to be implemented first and then the 27701-additional controls tested. For PII controllers they look at lawful-basis and rights-handling evidence; for PII processors they look at customer-instructions, sub-processor controls and return/transfer/disposal evidence.

Within Security considerations, the assessor will trace your implementation back to the catalogue reference (Annex A A.3.9) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Implement. Document the trigger, the owner and the cadence.
• Review. Document the trigger, the owner and the cadence.
• Limit. Document the trigger, the owner and the cadence.
• Scope: access rights.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. IAM analytics confirm RBAC, MFA, and access reviews. Focus: Access rights.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• ISO/IEC 27001:2022 A.8.2 — Privileged access rights
• BSI C5:2020 IDM-01 — Policy for user accounts and access rights
• SOC 2 (2017 TSC) CC6.2 — Access Provisioning
• GDPR Article 12 — Transparent information, communication and modalities for the exercise of the rights of the data subject
• NIST SP 800-53 Rev. 5 AC-6(6) — Privileged Access By Non-Organizational Users

Related controls in ISO/IEC 27701:2025

• Annex A A.3.8 — Identity management
• Annex A A.3.23 — Secure authentication

References

• ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
• Catalogue identifier: Annex A A.3.9

Topics: identity accessprivileged accessaccess reviewidentity management