Immediate Takeaways
- Treat privileged and supplier identities as critical assets, not just user accounts.
- Map Article 21 measures to access control, MFA, asset ownership, cyber hygiene, supplier access, and evidence testing.
- Prepare incident workflows for early warning, incident notification, and final reporting windows.
- Give management a monthly access-risk register with owners, gaps, remediation dates, and accepted residual risk.
Action Plan
- Week 1: build the inventory of critical apps, privileged accounts, third-party identities, and service accounts.
- Weeks 2–3: enforce MFA, least privilege, emergency access controls, joiner-mover-leaver automation, and supplier expiry dates.
- Weeks 4–5: run access certification for critical systems and document exceptions.
- Week 6: rehearse an identity incident, produce evidence, and brief management.
Useful References
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