Document ID: ILM-001
Version: 1.0
Effective Date: ____________________
Approved By: ____________________
Last Review Date: ____________________
Next Review Date: ____________________
1. Purpose
The purpose of this Identity Lifecycle Management Policy is to establish requirements for the creation, modification, maintenance, review, and removal of digital identities throughout their lifecycle. Effective identity lifecycle management ensures that only authorized individuals and systems have appropriate access to organizational resources at the appropriate time.
This policy supports secure onboarding, role changes, temporary assignments, leaves of absence, and offboarding while reducing the risk of unauthorized access, orphaned accounts, excessive privileges, and compliance violations.
2. Scope
This policy applies to:
- Employees
- Contractors
- Consultants
- Temporary workers
- Interns
- Volunteers
- Board members
- Vendors
- Third-party service providers
- Managed Service Providers (MSPs)
This policy also applies to non-human identities, including:
- Service accounts
- Application accounts
- API identities
- Robotic Process Automation (RPA) accounts
- Device identities
- Cloud workload identities
The policy applies to all organizational systems, including:
- Directory services
- Cloud identity providers
- Business applications
- Email systems
- Collaboration platforms
- Databases
- File storage
- VPNs
- Remote access systems
- Network infrastructure
- Cloud services
3. Policy Statement
The organization shall manage every identity through a controlled lifecycle consisting of provisioning, maintenance, modification, periodic review, suspension where appropriate, and deprovisioning.
Access shall be granted, modified, and removed only through approved processes based on documented business needs.
4. Guiding Principles
The organization follows these principles:
- Least Privilege
- Need-to-Know
- Zero Trust
- Individual Accountability
- Separation of Duties
- Secure by Default
- Timely Provisioning
- Timely Deprovisioning
5. Identity Types
Identity lifecycle controls apply to:
Human Identities
- Employees
- Contractors
- Temporary workers
- Consultants
- Vendors
- Interns
Non-Human Identities
- Service accounts
- Application identities
- API accounts
- Device identities
- Cloud service identities
- Automation accounts
Each identity shall have a documented owner or responsible party.
6. Identity Lifecycle Stages
The organization manages identities through the following stages:
- Identity Request
- Identity Verification
- Account Provisioning
- Access Assignment
- Ongoing Maintenance
- Role Modification
- Periodic Review
- Temporary Suspension (when applicable)
- Deprovisioning
- Account Removal or Archiving
7. Identity Provisioning
Accounts shall be created only after:
- Identity verification
- Documented business justification
- Management approval
- Completion of onboarding requirements
- Assignment of appropriate job role
- Approval by system owners where applicable
Each individual shall receive a unique identity whenever technically feasible.
8. Access Assignment
Access shall be assigned according to:
- Job responsibilities
- Business requirements
- Organizational role
- Data classification
- Regulatory requirements
- Risk level
Permissions shall follow the Principle of Least Privilege.
9. Identity Maintenance
Identity records shall remain accurate throughout employment or engagement.
Updates shall occur when:
- Names change
- Departments change
- Job titles change
- Managers change
- Employment status changes
- Business responsibilities change
Identity information shall be synchronized across systems where appropriate.
10. Role Changes (Movers)
When an individual’s responsibilities change:
- Existing permissions shall be reviewed.
- Unnecessary access shall be removed promptly.
- New permissions shall be approved before assignment.
- Privileged access shall be revalidated.
- Temporary access shall be removed if no longer required.
Role changes shall not result in unnecessary accumulation of permissions.
11. Temporary Access
Temporary access shall:
- Have documented business justification
- Receive appropriate approval
- Include expiration dates
- Be automatically revoked where technically feasible
- Be reviewed periodically
12. Leaves of Absence
During extended leave, the organization may:
- Suspend accounts
- Restrict privileged access
- Disable remote access
- Modify authentication requirements
The approach shall be based on business and legal requirements.
13. Identity Deprovisioning (Leavers)
Access shall be removed promptly when:
- Employment ends
- Contracts expire
- Vendor relationships terminate
- Temporary engagements conclude
- Access is no longer required
Deprovisioning activities should include:
- Disabling accounts
- Removing group memberships
- Revoking privileged access
- Revoking remote access
- Recovering authentication devices where applicable
- Revoking certificates and tokens where applicable
14. Account Retention and Removal
Disabled accounts may be retained for:
- Legal requirements
- Regulatory obligations
- Audit purposes
- Business continuity
- Data retention policies
Accounts shall be permanently removed according to organizational retention requirements.
15. Service Account Lifecycle
Service accounts shall:
- Have documented owners
- Have documented business purposes
- Follow formal approval processes
- Operate with minimum required permissions
- Be periodically reviewed
- Be removed when no longer required
Unused service accounts shall be disabled.
16. Periodic Identity Reviews
Managers and system owners shall periodically review:
- User accounts
- Privileged accounts
- Service accounts
- Group memberships
- Administrative roles
- Third-party accounts
- Dormant accounts
Reviews should occur:
- At least annually
- Following organizational restructuring
- During audits
- After security incidents
Higher-risk environments may require more frequent reviews.
17. Dormant Accounts
Inactive or dormant accounts shall be identified through periodic monitoring.
Dormant accounts should:
- Be investigated
- Be disabled when appropriate
- Be removed if no longer required
The organization shall define inactivity thresholds in supporting technical standards.
18. Identity Synchronization
Where multiple identity systems exist:
- Identity data shall remain consistent.
- Synchronization processes shall be monitored.
- Synchronization failures shall be investigated promptly.
- Identity conflicts shall be resolved in a timely manner.
19. Monitoring and Logging
Identity lifecycle events shall be logged where technically feasible, including:
- Account creation
- Account modification
- Account suspension
- Account disablement
- Account deletion
- Privilege assignments
- Group membership changes
- Administrative actions
- Failed provisioning events
Logs shall be protected against unauthorized modification.
20. Exception Management
Exceptions require:
- Documented business justification
- Risk assessment
- Management approval
- Information Security approval where applicable
- Compensating security controls
- Defined review and expiration dates
21. Responsibilities
Executive Management
- Support identity governance
- Approve organizational identity management objectives
- Allocate appropriate resources
Human Resources
- Notify IT of hiring, transfers, leaves of absence, and terminations
- Support timely onboarding and offboarding processes
Managers
- Approve access requests
- Validate business need
- Review user access
- Notify IT of personnel changes
IT Department
- Provision identities
- Modify user access
- Deprovision accounts
- Maintain identity systems
- Monitor synchronization
- Conduct periodic identity reviews
Information Security
- Define identity management standards
- Review privileged identities
- Monitor identity-related security events
- Investigate identity-related incidents
- Assess policy compliance
System Owners
- Approve application access
- Review permissions
- Validate user access
Users
- Protect authentication credentials
- Notify management of access issues
- Report suspected unauthorized access
- Comply with organizational security policies
22. Compliance
Compliance with this policy is mandatory.
Violations may result in:
- Removal of access
- Suspension of privileges
- Disciplinary action
- Contract termination
- Legal action where applicable
23. Policy Review
This policy shall be reviewed at least annually or following:
- Organizational restructuring
- Technology changes
- Security incidents
- Regulatory updates
- Audit findings
24. Related Policies
- Information Security Policy
- Access Control Policy
- Identity and Authentication Policy
- Joiner, Mover, Leaver (JML) Policy
- Least Privilege Policy
- Privileged Access Management (PAM) Policy
- Directory Services Policy
- Password Policy
- Multi-Factor Authentication (MFA) Policy
- Remote Access Policy
- Logging and Monitoring Policy
- Incident Response Policy
Document Objective
This policy establishes the organization’s requirements for securely managing digital identities throughout their lifecycle, from initial provisioning through modification, suspension, and deprovisioning. It provides a consistent, vendor-neutral framework for managing both human and non-human identities across on-premises, cloud, and hybrid environments. By ensuring timely access provisioning, regular access reviews, and prompt removal of unnecessary access, this policy reduces security risk, supports operational efficiency, and aligns with recognized frameworks including NIST CSF, ISO/IEC 27001, CIS Controls, SOC 2, HIPAA, PCI DSS, CMMC, and the FTC Safeguards Rule.