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Understanding ISO 27001:2022 Annex A Control 5.16 – Strengthening Identity Management

The revised ISO 27001:2022 Annex A 5.16 Identity Management establishes a framework for approving, registering, and administering human and non-human identities on any network – defined as the “full lifecycle.

Computer networks use identities to identify the underlying ability of an entity (a user, group of users, device, or IT asset) to access a set of hardware and software resources.

What Does ISO 27001:2022 Annex A 5.16 Do?

The purpose of Annex A 5.16 is to describe how an organisation can identify who (users, groups of users) or what (applications, systems, and devices) is accessing data or IT assets at any given moment, and how those identities are granted access rights.

As a preventative measure, Annex A 5.16 aims to maintain risk by establishing the main perimeter for all related information security and cyber security operations, as well as the primary mode of governance that determines an organisation’s Identity and Access Management process.




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Ownership of Annex A 5.16

Considering ISO 27001:2022 Annex A 5.16 serves as a primarily maintenance function, ownership should be given to IT staff with Global Administrator rights (or equivalent for non-Windows infrastructure).

In addition to other built-in roles that allow users to manage identities (such as Domain Administrator), Annex A 5.16 should be owned by the individual responsible for the entire network of the organisation, including all subdomains and Active Directory tenants.

General Guidance on ISO 27001:2022 Annex A 5.16

Annex A 5.16 compliance is achieved by expressing identity-based procedures clearly in policy documents and monitoring staff adherence on a daily basis.

Six procedures are listed in Annex A 5.16, to ensure that an organisation meets the requisite standards of infosec and cybersecurity governance:

  1. Whenever an identity is assigned to a person, that person is the only one who can authenticate with that identity and/or use it when accessing network resources.
  2. Achieving compliance means IT policies must stipulate clearly that users are not to share login information, or allow other users to roam the network using any identity other than the one they have been given.

  3. In some cases, it may be necessary to assign a single identity to several people, also known as a ‘shared identity’. Only use this approach when an explicit set of operational requirements is needed.
  4. To achieve compliance, registration of shared identities should be handled separately from single user registration, with a dedicated approval process.

  5. ‘Non-human’ entities (any identity that isn’t tied to a real person) should be treated differently from user-based identities at registration.
  6. A non-human identity should also have its own approval and registration process, acknowledging the fundamental difference between assigning an identity to a person and granting one to an asset, application or device.

  7. In the event of a departure, redundant assets, or other non-required identities, a network administrator should disable them or remove them completely.
  8. The IT department should conduct regular audits to determine which identities are being used, and which entities can be suspended or deleted. It is important for HR staff to include identity management in offboarding procedures, and to inform IT staff immediately when a leaver leaves.

  9. It is imperative to avoid duplicate identities at all costs. A ‘one entity, one identity’ rule should be followed by all organisations.
  10. To comply, IT staff should ensure that entities do not receive access rights based on more than one identity when assigning roles across a network.

  11. Identities management and authentication information should be documented adequately for all ‘significant events.
  12. It is possible to interpret the term ‘significant event’ differently, but on a basic level, organisations need to make sure that their governance procedures include a comprehensive list of assigned identities at any given time, robust change request protocols with appropriate approval procedures, and an approved change request protocol.

Additional Supplementary Guidance for Annex A 5.16

When creating an identity and granting it access to network resources, Annex A 5.16 also lists four steps that businesses need to follow (amending or removing access rights is shown in ISO 27001:2022 Annex A 5.18):

  1. Before creating an identity, establish a business case.
  2. Every time an identity is created, identity management becomes exponentially more challenging. It is advisable for organisations to create new identities only when it is clearly necessary.

  3. Make sure that the entity (human or non-human) assigned an identity has been independently verified.
  4. Identities and Access Management procedures should ensure that, once the business case has been approved, an individual or asset receiving new identities has the required authority before an identity is created.

  5. Creating an identity
  6. Your IT staff should build an identity in line with the business case requirements, and it should be limited to what is outlined in any change request documentation.

  7. The final configurations steps for an identity
  8. As the final step in the process, an identity is assigned to each of its access-based permissions and roles (RBAC) as well as any authentication services required.




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What Are the Changes From ISO 27001:2013?

ISO 27001:2022 Annex A 5.16 replaces ISO 27001:2013 A.9.2.1 (formerly known as ‘User Registration and Deregistration’).

While the two controls share some striking similarities – primarily in maintenance protocols and deactivating redundant IDs – Annex A 5.16 contains a comprehensive set of guidelines that deal with Identity and Access Management as a whole.

Annex A 5.16 Human vs. Non-human Identities Explained

There are some differences between the 2022 Annex and its predecessor in that despite differences in registration processes, humans and non-humans are no longer treated separately when it comes to general network administration.

It has become more common in IT governance and best practice guidelines to talk about human and non-human identities interchangeably since the advent of modern Identity and Access Management and Windows-based RBAC protocols.

In Annex A 9.2.1 of ISO 27001:2013, there is no guidance on how to manage non-human identities, and the text is concerned only with managing what it calls ‘User IDs’ (i.e. login information along with a password that’s used to access a network).

ISO 27001:2022 Annex A 5.16 Documentation

Annex A 5.16 provides explicit guidance on both the general security implications of identity governance, and how organisations should record and process information prior to the assigning of identities, as well as throughout the lifecycle of the identity.

Comparatively, ISO 27001:2013 A.9.2.1 only briefly mentions the IT governance role that surrounds the administration of identities, and limits itself to the physical practice of identity administration.

Table of All ISO 27001:2022 Annex A Controls

In the table below you’ll find more information on each individual ISO 27001:2022 Annex A Control.

ISO 27001:2022 Organisational Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Organisational Controls Annex A 5.1 Annex A 5.1.1
Annex A 5.1.2
Policies for Information Security
Organisational Controls Annex A 5.2 Annex A 6.1.1 Information Security Roles and Responsibilities
Organisational Controls Annex A 5.3 Annex A 6.1.2 Segregation of Duties
Organisational Controls Annex A 5.4 Annex A 7.2.1 Management Responsibilities
Organisational Controls Annex A 5.5 Annex A 6.1.3 Contact With Authorities
Organisational Controls Annex A 5.6 Annex A 6.1.4 Contact With Special Interest Groups
Organisational Controls Annex A 5.7 NEW Threat Intelligence
Organisational Controls Annex A 5.8 Annex A 6.1.5
Annex A 14.1.1
Information Security in Project Management
Organisational Controls Annex A 5.9 Annex A 8.1.1
Annex A 8.1.2
Inventory of Information and Other Associated Assets
Organisational Controls Annex A 5.10 Annex A 8.1.3
Annex A 8.2.3
Acceptable Use of Information and Other Associated Assets
Organisational Controls Annex A 5.11 Annex A 8.1.4 Return of Assets
Organisational Controls Annex A 5.12 Annex A 8.2.1 Classification of Information
Organisational Controls Annex A 5.13 Annex A 8.2.2 Labelling of Information
Organisational Controls Annex A 5.14 Annex A 13.2.1
Annex A 13.2.2
Annex A 13.2.3
Information Transfer
Organisational Controls Annex A 5.15 Annex A 9.1.1
Annex A 9.1.2
Access Control
Organisational Controls Annex A 5.16 Annex A 9.2.1 Identity Management
Organisational Controls Annex A 5.17 Annex A 9.2.4
Annex A 9.3.1
Annex A 9.4.3
Authentication Information
Organisational Controls Annex A 5.18 Annex A 9.2.2
Annex A 9.2.5
Annex A 9.2.6
Access Rights
Organisational Controls Annex A 5.19 Annex A 15.1.1 Information Security in Supplier Relationships
Organisational Controls Annex A 5.20 Annex A 15.1.2 Addressing Information Security Within Supplier Agreements
Organisational Controls Annex A 5.21 Annex A 15.1.3 Managing Information Security in the ICT Supply Chain
Organisational Controls Annex A 5.22 Annex A 15.2.1
Annex A 15.2.2
Monitoring, Review and Change Management of Supplier Services
Organisational Controls Annex A 5.23 NEW Information Security for Use of Cloud Services
Organisational Controls Annex A 5.24 Annex A 16.1.1 Information Security Incident Management Planning and Preparation
Organisational Controls Annex A 5.25 Annex A 16.1.4 Assessment and Decision on Information Security Events
Organisational Controls Annex A 5.26 Annex A 16.1.5 Response to Information Security Incidents
Organisational Controls Annex A 5.27 Annex A 16.1.6 Learning From Information Security Incidents
Organisational Controls Annex A 5.28 Annex A 16.1.7 Collection of Evidence
Organisational Controls Annex A 5.29 Annex A 17.1.1
Annex A 17.1.2
Annex A 17.1.3
Information Security During Disruption
Organisational Controls Annex A 5.30 NEW ICT Readiness for Business Continuity
Organisational Controls Annex A 5.31 Annex A 18.1.1
Annex A 18.1.5
Legal, Statutory, Regulatory and Contractual Requirements
Organisational Controls Annex A 5.32 Annex A 18.1.2 Intellectual Property Rights
Organisational Controls Annex A 5.33 Annex A 18.1.3 Protection of Records
Organisational Controls Annex A 5.34 Annex A 18.1.4 Privacy and Protection of PII
Organisational Controls Annex A 5.35 Annex A 18.2.1 Independent Review of Information Security
Organisational Controls Annex A 5.36 Annex A 18.2.2
Annex A 18.2.3
Compliance With Policies, Rules and Standards for Information Security
Organisational Controls Annex A 5.37 Annex A 12.1.1 Documented Operating Procedures
ISO 27001:2022 People Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
People Controls Annex A 6.1 Annex A 7.1.1 Screening
People Controls Annex A 6.2 Annex A 7.1.2 Terms and Conditions of Employment
People Controls Annex A 6.3 Annex A 7.2.2 Information Security Awareness, Education and Training
People Controls Annex A 6.4 Annex A 7.2.3 Disciplinary Process
People Controls Annex A 6.5 Annex A 7.3.1 Responsibilities After Termination or Change of Employment
People Controls Annex A 6.6 Annex A 13.2.4 Confidentiality or Non-Disclosure Agreements
People Controls Annex A 6.7 Annex A 6.2.2 Remote Working
People Controls Annex A 6.8 Annex A 16.1.2
Annex A 16.1.3
Information Security Event Reporting
ISO 27001:2022 Physical Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Physical Controls Annex A 7.1 Annex A 11.1.1 Physical Security Perimeters
Physical Controls Annex A 7.2 Annex A 11.1.2
Annex A 11.1.6
Physical Entry
Physical Controls Annex A 7.3 Annex A 11.1.3 Securing Offices, Rooms and Facilities
Physical Controls Annex A 7.4 NEW Physical Security Monitoring
Physical Controls Annex A 7.5 Annex A 11.1.4 Protecting Against Physical and Environmental Threats
Physical Controls Annex A 7.6 Annex A 11.1.5 Working In Secure Areas
Physical Controls Annex A 7.7 Annex A 11.2.9 Clear Desk and Clear Screen
Physical Controls Annex A 7.8 Annex A 11.2.1 Equipment Siting and Protection
Physical Controls Annex A 7.9 Annex A 11.2.6 Security of Assets Off-Premises
Physical Controls Annex A 7.10 Annex A 8.3.1
Annex A 8.3.2
Annex A 8.3.3
Annex A 11.2.5
Storage Media
Physical Controls Annex A 7.11 Annex A 11.2.2 Supporting Utilities
Physical Controls Annex A 7.12 Annex A 11.2.3 Cabling Security
Physical Controls Annex A 7.13 Annex A 11.2.4 Equipment Maintenance
Physical Controls Annex A 7.14 Annex A 11.2.7 Secure Disposal or Re-Use of Equipment
ISO 27001:2022 Technological Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Technological Controls Annex A 8.1 Annex A 6.2.1
Annex A 11.2.8
User Endpoint Devices
Technological Controls Annex A 8.2 Annex A 9.2.3 Privileged Access Rights
Technological Controls Annex A 8.3 Annex A 9.4.1 Information Access Restriction
Technological Controls Annex A 8.4 Annex A 9.4.5 Access to Source Code
Technological Controls Annex A 8.5 Annex A 9.4.2 Secure Authentication
Technological Controls Annex A 8.6 Annex A 12.1.3 Capacity Management
Technological Controls Annex A 8.7 Annex A 12.2.1 Protection Against Malware
Technological Controls Annex A 8.8 Annex A 12.6.1
Annex A 18.2.3
Management of Technical Vulnerabilities
Technological Controls Annex A 8.9 NEW Configuration Management
Technological Controls Annex A 8.10 NEW Information Deletion
Technological Controls Annex A 8.11 NEW Data Masking
Technological Controls Annex A 8.12 NEW Data Leakage Prevention
Technological Controls Annex A 8.13 Annex A 12.3.1 Information Backup
Technological Controls Annex A 8.14 Annex A 17.2.1 Redundancy of Information Processing Facilities
Technological Controls Annex A 8.15 Annex A 12.4.1
Annex A 12.4.2
Annex A 12.4.3
Logging
Technological Controls Annex A 8.16 NEW Monitoring Activities
Technological Controls Annex A 8.17 Annex A 12.4.4 Clock Synchronization
Technological Controls Annex A 8.18 Annex A 9.4.4 Use of Privileged Utility ProgramsAccess Rights
Technological Controls Annex A 8.19 Annex A 12.5.1
Annex A 12.6.2
Installation of Software on Operational Systems
Technological Controls Annex A 8.20 Annex A 13.1.1 Networks Security
Technological Controls Annex A 8.21 Annex A 13.1.2 Security of Network Services
Technological Controls Annex A 8.22 Annex A 13.1.3 Segregation of Networks
Technological Controls Annex A 8.23 NEW Web filtering
Technological Controls Annex A 8.24 Annex A 10.1.1
Annex A 10.1.2
Use of Cryptography
Technological Controls Annex A 8.25 Annex A 14.2.1 Secure Development Life Cycle
Technological Controls Annex A 8.26 Annex A 14.1.2
Annex A 14.1.3
Application Security Requirements
Technological Controls Annex A 8.27 Annex A 14.2.5 Secure System Architecture and Engineering PrinciplesLearning From Information Security Incidents
Technological Controls Annex A 8.28 NEW Secure Coding
Technological Controls Annex A 8.29 Annex A 14.2.8
Annex A 14.2.9
Security Testing in Development and Acceptance
Technological Controls Annex A 8.30 Annex A 14.2.7 Outsourced Development
Technological Controls Annex A 8.31 Annex A 12.1.4
Annex A 14.2.6
Separation of Development, Test and Production Environments
Technological Controls Annex A 8.32 Annex A 12.1.2
Annex A 14.2.2
Annex A 14.2.3
Annex A 14.2.4
Change Management
Technological Controls Annex A 8.33 Annex A 14.3.1 Test Information
Technological Controls Annex A 8.34 Annex A 12.7.1 Protection of Information Systems During Audit Testing




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How ISMS.online Helps You Achieve Annex A 5.16 Compliance

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David Holloway

Chief Marketing Officer

David Holloway is the Chief Marketing Officer at ISMS.online, with over four years of experience in compliance and information security. As part of the leadership team, David focuses on empowering organisations to navigate complex regulatory landscapes with confidence, driving strategies that align business goals with impactful solutions. He is also the co-host of the Phishing For Trouble podcast, where he delves into high-profile cybersecurity incidents and shares valuable lessons to help businesses strengthen their security and compliance practices.

ISO 27001:2022 Annex A Controls

Organisational Controls