CYB-15 · Cyber security
Access lifecycle management — user access provisioned, reviewed, and deprovisioned systematically
Orphaned accounts (former staff, former contractors) represent a persistent access risk. A formal joiners-movers-leavers (JML) process must exist to provision, modify, and revoke access to all systems within defined timeframes. Departing staff access must be revoked on the same day as departure.
Trigger
When this rule fires
No formal JML access management process; evidence of active accounts for former employees; access not reviewed in last 6 months; no defined revocation SLA
Applicability gate
Confirm the entity's role before treating this as a duty
This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.
- Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
- Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
- Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.
Citation
Mapped source
This control maps to the public instruments below. The mapping does not establish entity applicability.
- Section
- Joint Standard 2 of 2024 — paragraphs 7.2.2 and 8.1 (access management) / POPIA s.19
- Legislation
-
- Joint Standard 2 of 2024
- POPIA s.19
Remediation
How to close the gap
Implement a JML access management checklist. Define revocation SLA (same-day for involuntary, 24-hour for voluntary departures). Conduct a full access audit. Implement quarterly access certification reviews.
Evidence required
Evidence to prepare if this control applies
- JML process documentation
- Access certification review records (last 6 months)
- Off-boarding checklist with access revocation step
- No active accounts for departed staff (HR list vs AD reconciliation)