What this control covers
Documents role-based access policies per SP-01, enforcing least privilege, segregation of duties, and two-factor authentication for privileged access. Specifies account management, regular reviews, and automated blocking to protect cloud customer data from unauthorized access.
Why it matters
Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.
How to implement
AWS
Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.
Azure
Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.
GCP
Use Cloud Identity (or Workspace) as the IdP and IAM for resource access. Grant roles at the lowest scope (project > folder > org) using Workload Identity Federation for CI/CD and service accounts for workloads — never download service-account keys when avoidable. Enable Policy Intelligence recommenders to right-size privileges and detect dormant identities.
Google Workspace
Enforce 2-Step Verification (preferably hardware keys for admins) for the entire org, set session length to ≤ 12 hours, and disable less-secure-app access. Use Context-Aware Access levels to restrict admin sign-in by IP/device posture. Provision and de-provision users via SCIM from your HRIS so leavers lose access on day one.
GitHub
Require SSO + SCIM from your IdP on the organisation; enforce 2FA org-wide and use fine-grained PATs (or, better, GitHub Apps) instead of classic tokens. Restrict outside collaborators, require signed commits on protected branches, and use OIDC from Actions to short-lived AWS/GCP/Azure credentials rather than stored secrets.
Zoho Mail
Make two-factor authentication mandatory for all users (TOTP, OneAuth, or YubiKey) in Admin Console → Security. Configure SAML SSO against your IdP and disable password-based logins for admins. Use role-based privileges (Admin / Spam Moderator / Mail Account Admin) and review the Login history report monthly for anomalies.
On-premises
Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.
Evidence to collect
identity_scan— See the iCompaas Evidence library for the canonical source for this evidence type.policy_document— A signed, version-controlled policy stating leadership intent and the named owner.
Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Signed policy or standard documents the safeguard. Focus: Policy for user accounts and access rights.
Quick checklist
- Segregation — Access Rights / Cloud Customer Data
- Risk — Access Rights / Cloud Customer Data
- Review — Access Rights / Cloud Customer Data
- Data — Access Rights / Cloud Customer Data
- Policy — Access Rights / Cloud Customer Data
- Access — Access Rights / Cloud Customer Data
Related articles on this site
- Ensure periodic IAM user access reviews are performed to ensure users have least privilege access
- Ensure Access Review is Set Up for External Users in Azure AD Privileged Identity Management (PIM
- Implement and Periodically Review Access Policies for Azure Cache for Redis to Enforce RBAC and Least Privilege
- NIST 800-171 3.1.5 Employ the principle of least privilege, including for specific security functions and privileged accounts.