The entity authorizes, modifies, or removes access to data, software, functions, and services

SOC 2 access controls fail less from missing tools and more from missing proof. Auditors rarely argue that you “should have MFA” under this specific requirement; they ask whether you can show, end-to-end, that every material access grant and change was authorized, and every removal happened when it should. This requirement (TSC-CC6.3) is the operational heart of identity and access management because it governs the decisions and records behind who can reach data and perform actions in your environment.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to define a single, standard access workflow that works across IT, cloud platforms, business applications, and production tooling. Then you instrument it so you can answer basic audit questions without scramble: Who approved this access? Why was it needed? When did it start? When did it end? Did it match the user’s job role? Did elevated access have tighter approval and review?

This page breaks TSC-CC6.3 into an implementable control set: scope, policy, procedures, system configuration expectations, evidence to retain, and a practical 30/60/90-day execution plan.

Regulatory text

Requirement (TSC-CC6.3): “The entity authorizes, modifies, or removes access to data, software, functions, and services.” ¹

Operator interpretation (what you must do):

• Authorize access before it is granted. Approval must come from an appropriate authority (typically the data/system owner or delegated approver) and follow defined criteria.
• Modify access through controlled change when job duties, projects, or risk changes. “Modification” includes role changes, group membership changes, privilege elevation, and adding/removing access to specific applications or environments.
• Remove access when no longer needed, including termination, role change, end of contract, or project completion.
• Prove it happened with evidence. In SOC 2, “we do this” is not enough; you need records that show the control operated.

Plain-English meaning

You need a repeatable process that ensures people and accounts only have the access they are supposed to have, for as long as they are supposed to have it, and no longer. The process must be consistent across systems that matter to your SOC 2 scope.

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Who it applies to (entity and operational context)

This requirement applies to any service organization pursuing SOC 2 where systems in scope store, process, or transmit customer data, or support the services covered by the SOC 2 report ¹.

Include these access types in scope (common examiner focus):

• Workforce identities: employees and contractors with corporate accounts.
• Privileged/admin access: cloud admins, database admins, IAM admins, CI/CD admins, endpoint management admins.
• Service accounts and API tokens: non-human identities used by apps, automation, integrations.
• Third-party access: support vendors, consultants, MSPs, and customer access paths if they reach in-scope environments.
• Application-level roles: access inside SaaS tools (ticketing, CRM, finance), not just the SSO layer.

Operational context where this control breaks:

• Fast-growing teams with ad hoc approvals in chat.
• Engineering teams granting production access outside ticketing.
• Contractors added directly in cloud consoles without HR or procurement signals.
• Service accounts created without owners and never removed.

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What you actually need to do (step-by-step)

Step 1: Define scope and “access governance rules”

Create an access control standard that answers:

• Which systems are in scope (SSO, cloud platforms, databases, code repos, CI/CD, ticketing, data warehouses, endpoint tools, key SaaS apps).
• Who can approve access by system and data type (system owner, data owner, security, manager).
• What requires extra scrutiny (privileged access, production access, customer data stores).
• What evidence is required (ticket ID, approver, timestamp, access granted, access removed).

Deliverable: Access Control Policy + Access Management Procedure mapped to in-scope systems ¹.

Step 2: Implement a single access request and approval workflow

Operationalize one workflow for all access events:

1. Request submitted via ticketing or access request system.
2. Justification captured (role need, project, time-bounded if appropriate).
3. Approval recorded from the correct approver.
4. Provisioning performed by automation or IT/SecOps, tied back to the ticket.
5. Notification to requester and, when needed, the system owner.

Practical control design choices auditors accept:

• Ticketing approvals with identity of approver and timestamp.
• Access request tooling integrated with your IdP.
• Standard roles/groups with pre-approved entitlements.

Step 3: Control modifications (role changes, privilege elevation, expansions)

Treat modifications as new access decisions:

• Require the same approval rigor as initial provisioning.
• For privileged elevation, require stronger approvals (often system owner + security) and record the rationale.
• If you use temporary elevation, record start/end and the mechanism used to remove it.

Evidence pattern auditors like: ticket shows old access → requested change → approval → implementation proof (access report or system log) → confirmation.

Step 4: Make removals reliable (deprovisioning)

Define removal triggers and how they flow:

• HR termination → disable corporate identity → revoke app access → revoke privileged roles → rotate shared secrets if impacted.
• Contractor offboarding → same, triggered by procurement/vendor owner or HR-equivalent process.
• Role change → remove old entitlements and grant new ones, not additive “permission creep.”

Minimum operational requirement: you can demonstrate that departures and access removals are processed through a consistent mechanism and are verifiable ¹.

Step 5: Add periodic verification (catch what workflows miss)

Even good workflows drift. Add a recurring review:

• System owners receive access lists for their systems and confirm appropriateness.
• Privileged access gets a tighter review.
• Service accounts get an ownership and necessity check.

Keep reviews actionable:

• Require owners to attest and file exceptions as tickets.
• Track completion and follow-up removals.

Step 6: Instrument evidence collection (don’t do it by hand during the audit)

Set up a standing “SOC 2 evidence” folder or GRC workflow that collects:

• Policy/procedure versions and approvals.
• Samples of access tickets (new, modified, removed).
• Exported access listings and review sign-offs.
• Termination/offboarding samples with deprovision proof.

If you use Daydream, configure a control record for this requirement and attach operating evidence on a recurring cadence so you are not reconstructing decisions late in the cycle.

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Required evidence and artifacts to retain

Keep evidence that proves authorization, modification control, and removal. Typical artifacts:

• Access control policy and access management procedure aligned to in-scope systems.
• Role/entitlement definitions (RBAC matrix or group-to-role mapping).
• Approval records for access requests (tickets or workflow approvals).
• Provisioning proof (IdP logs, admin console logs, screenshots or exports showing membership).
• Deprovisioning proof for terminations and contract ends (account disable logs, removal from groups, SaaS access removal).
• Access review outputs: reviewer, date, population reviewed, decisions, and remediation tickets.
• Privileged access registry (who has admin, why, when approved).
• Service account inventory with owners, purpose, and rotation/removal actions when decommissioned.

What matters is traceability: a reviewer should be able to go from “user X had access to system Y” back to an authorization record and forward to removal evidence.

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Common exam/audit questions and hangups

Auditors often probe these areas under TSC-CC6.3 ¹:

• “Show me how access is approved for production systems. Who can approve?”
• “Provide samples of new user provisioning, access changes, and terminations.”
• “How do you prevent managers from approving access they don’t own?”
• “How do you track and approve service accounts and API tokens?”
• “How do you know terminated users lose access everywhere?”
• “Show the latest access review and the tickets created to remove access.”

Hangups that cause findings:

• Approvals in chat with no durable record.
• Tickets missing justification, approver identity, or timestamps.
• Access reviews completed but remediation not tracked to closure.
• Inconsistent scope: SSO governed, but direct app accounts unmanaged.

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Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix that works in audits
“Manager approval” for every system	Managers may not be the system/data owner	Define approver per system; delegate approvals formally
RBAC exists but nobody uses it	Ad hoc entitlements create drift	Force access via roles/groups; restrict direct grants
Deprovisioning only disables SSO	Apps with local users still accessible	Maintain an app inventory and prove revocation per app
Service accounts have no owners	No one reviews or removes them	Require named owner and ticket for creation/change/removal
Access reviews are checkbox exercises	No evidence of follow-up	Require remediation tickets and attach them to review records

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Enforcement context and risk implications

SOC 2 is an attestation framework, so the immediate “penalty” is usually business impact: report qualifications, carve-outs, or inability to claim effective controls to customers. The underlying risk is concrete: unauthorized access, privilege creep, orphaned accounts, and untracked admin changes can lead to confidentiality, availability, and integrity incidents. TSC-CC6.3 is one of the first places an auditor looks when access failures show up in incident response or change management narratives ¹.

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Practical 30/60/90-day execution plan

First 30 days: establish the minimum viable access lifecycle

• Confirm in-scope systems list with IT/Security/Engineering and your SOC 2 scope owner.
• Publish/refresh access management procedure: request, approve, provision, modify, remove.
• Assign system owners and approvers for each in-scope system.
• Standardize an access request ticket template (fields: system, role, justification, approver, start/end if time-bound).
• Start collecting evidence samples immediately (new access, change, removal).

Days 31–60: close the biggest audit gaps

• Build an entitlement map (roles/groups → permissions) for key systems.
• Implement termination/offboarding runbook that includes app-by-app revocation checks.
• Stand up privileged access tracking (registry) and tighten approvals for admin roles.
• Create service account inventory and require ownership for new non-human identities.
• Run your first access review for one high-risk system and remediate findings with tickets.

Days 61–90: make it sustainable and provable

• Expand access reviews to remaining high-risk systems; define cadence by risk.
• Add automation where feasible (IdP workflows, joiner/mover/leaver integrations).
• Create a standing evidence package per system: last review, sample tickets, access list export, owner attestation.
• If you use Daydream, set recurring evidence tasks and map artifacts to the control so audits become retrieval, not archaeology.

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Frequently Asked Questions

Does this requirement mean every access change needs a ticket?

You need a durable record of authorization, implementation, and timing. Tickets are the most common way to produce that record, but an access request workflow with equivalent audit trails can also satisfy the requirement ¹.

Who counts as an “authorized approver”?

The approver should have accountability for the system or data and understand the risk of granting access. Many teams use system owners for application access and security for privileged or production access decisions ¹.

Are service accounts in scope for “authorizes, modifies, or removes access”?

Yes if they can access in-scope systems, data, or functions. Treat them as identities that need a request, approval, ownership, and removal process, plus periodic review of continued need.

What evidence is strongest for access removal?

Show the trigger (termination or contract end), the removal action (disabled account, group removal, token revocation), and the timestamped log or export proving access no longer exists.

We use SSO for most apps, but some tools have local accounts. What should we do?

Add those tools to your app inventory, define owners and approvers, and implement a removal check as part of offboarding. Auditors often focus on these “SSO gaps” because they create orphaned access paths.

How do we handle emergency or break-glass access?

Document the conditions for emergency access, require post-access approval and review, and retain logs showing who used it and why. Treat it as a controlled exception, not an informal shortcut ¹.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. AICPA TSC 2017