User Access Control Policy
Document Control
| Document ID | HL-ISMS-POL-03 |
|---|---|
| Document Title | User Access Control Policy |
| Classification | Internal |
| Version | 2.0 |
| Status | Approved |
| Document Owner | Information Security Manager (ISM) |
| Approved by | Executive Management |
| Effective Date | 30.10.2026 |
| Next Review Date | Annually from effective date, or upon significant change |
| Applies to | Hamurlabs Elektronik Hizmetler Yazılım ve Ticaret A.Ş. (Istanbul, Türkiye) and Hamurlabs BV (Leuven, Belgium), together "Hamurlabs" |
Revision history
| Version | Date | Author | Description of Change |
|---|---|---|---|
| 1.0 | — | — | Initial template-based version (superseded) |
| 2.0 | 30.10.2026 | ISM | Full rewrite: adapted to Hamurlabs group structure (A.Ş. + BV), Google Cloud environment, KVKK/GDPR legal basis, ISO/IEC 27001 alignment; roles and contact points corrected |
1. Introduction and Scope
This policy provides the framework for how user accounts and privileges are created, managed, reviewed and removed across Hamurlabs. It defines how new users are authorised and granted appropriate privileges, how those privileges are reviewed and revoked, and the controls that prevent users from obtaining unauthorised access.
This policy applies to all employees, contractors and suppliers who have access to Hamurlabs information and information systems, and to all systems used by Hamurlabs, including: the HaROS production and non-production environments, Google Cloud projects, source code repositories, CI/CD tooling, corporate SaaS applications (email, document collaboration, communication, support/ITSM), and databases. Certain roles — in particular privileged and production access — require stronger controls than those applied to standard users.
2. Definitions
| Users | All persons with access to Hamurlabs information and information systems as described in the Scope. |
|---|---|
| Privileged Users | Users with an elevated level of access to a network, system or application, authorised to perform functions that standard users cannot (e.g. Google Cloud project owners/editors, production database access, repository administrators, identity-provider administrators). Includes standard users with approved elevated privileges. |
| Access Approver | The person authorised to approve an access request: the user’s manager for standard business systems, and the Information Security Manager (ISM) or executive responsible for technology for privileged and production access. |
3. Policy Statements
3.1 Principle of Least Privilege
Access must be allocated on the basis of business need and least privilege. Users must be provided only with the minimum access rights and permissions to systems, services, information and resources that they need to fulfil their role. Access to customer data in production is restricted to personnel whose role requires it and is granted per the controls in Section 3.5.
3.2 Account Lifecycle (Joiner – Mover – Leaver)
- Joiner: accounts are created only upon a documented request approved by the Access Approver. Default access for a role may be defined in a role-based access matrix maintained by the ISM.
- Mover: when a user changes role or business need changes, access rights must be adjusted promptly; rights no longer required must be revoked, not accumulated.
- Leaver: all access of departing personnel must be revoked no later than the last day of employment or engagement (same day for third parties), and any access tokens or hardware must be recovered. Account deactivation takes priority over data handover arrangements.
- All additions, deletions, suspensions and modifications of access must be captured in an audit trail showing who took the action and when.
- Accounts not accessed for 90 days without prior arrangement must be disabled.
- Account management procedures may be executed only by suitably trained and authorised personnel.
3.3 Authentication
- All access to Hamurlabs information systems must be controlled by an approved authentication method that verifies the user’s identity — as a minimum, a unique user ID and strong password.
- Single sign-on through the corporate identity provider must be used wherever the system supports it.
- Multi-factor authentication (MFA) is mandatory for: the identity provider, email, Google Cloud, source code repositories, remote access, and all administrative interfaces.
- Each user ID must be unique and must never be reused or duplicated. Users are normally limited to one account per system for non-administrative purposes; variations require ISM approval.
3.4 Password Management
- Passwords must not be shared with any other person for any reason.
- All default system and vendor passwords must be changed immediately upon installation.
- Systems must support strong password management (length, complexity or passphrase support, history, account lockout). Minimum password length is 12 characters; the use of the corporate password manager is required for shared secrets and strongly recommended for individual credentials.
- New accounts must be forced to change their initial password at first use; passwords must be changed on indication or suspicion of compromise.
- Secrets used by systems (API keys, tokens, service-account keys) must be stored in an approved secrets manager, never in source code, tickets or chat.
3.5 Privileged and Production Access
- All privileged accounts must be based on job function and authorised by the ISM (or the executive responsible for technology) before access is granted.
- Privileged actions must be performed from individual accounts; use of shared root/administrator credentials is prohibited except in documented break-glass procedures.
- All changes to privileged accounts must be logged and reviewed regularly.
- Access to production customer data must be limited to named personnel, logged, and reviewed quarterly.
- Privileged access rights are reviewed quarterly; standard access rights are reviewed at least annually. Reviews are coordinated by the ISM with each manager.
3.6 Monitoring
Systems must be capable of logging events relevant to potential security breaches, and user access is subject to management checks. Anomalies identified in access rights — excessive, unused or inconsistent permissions — must be challenged and corrected.
4. Responsibilities
| Executive Management | Ensures this policy is implemented across all Hamurlabs systems and services, and retains ultimate accountability for the access control regime. Any non-compliance must be supported by a documented, evidence-based risk decision accepted at this level. |
|---|---|
| Managers | Ensure team members have the minimum access needed for their job; authorise access requests; keep a record of authorised permissions; ensure access of movers and leavers is adjusted or revoked immediately and tokens/hardware recovered; review team access levels. |
| ISM | Maintains the role-based access matrix; approves privileged access; coordinates periodic access reviews; audits compliance with this policy. |
| Engineering / IT operations | Grant and revoke access in accordance with approved requests and the role-based access matrix; evaluate and, if necessary, challenge requests to identify anomalies in the access levels requested. |
| Users | Use business systems only for legitimate purposes required by their job and in accordance with the procedures for those systems; protect their credentials; report suspected misuse to [email protected]. |
5. Compliance
Compliance with this policy is assessed regularly by the ISM through access reviews and audits. Any violation must be investigated and may result in disciplinary action in accordance with the Information Security Policy.