Ownership should sit with identity governance, but accountability must extend to HR, managers, and system owners because all three influence hire, change, and departure events. Seasonal access is a cross-functional lifecycle problem, and no single team can prove it is clean without the others.
Who should own holiday access governance?
Identity governance should own the process, but holiday access is not something one team can clean up alone. HR, managers, and system owners all influence who is hired, changed, absent, or leaving, so accountability has to be shared across the lifecycle. The control only works when ownership, approvals, and deprovisioning decisions are coordinated.
Why ownership must sit with identity governance
Holiday access looks temporary, but the underlying control problem is permanent: who can grant, review, and remove access without creating privilege creep or orphaned access. That makes it an identity and access governance issue first, because the team owning the governance model is the only one positioned to enforce consistent rules across joiner, mover, and leaver events.
Seasonal or holiday access usually spans more than one system and more than one manager. If each business unit handles it differently, exceptions accumulate, reviews become inconsistent, and nobody can prove that temporary access actually expired when expected. The governance owner should therefore define the standard, while business teams supply the operational facts that make the standard accurate.
In practice, the cleanest operating model is to treat holiday access as a lifecycle case inside a broader access governance process. That means the governance function sets policy, approval rules, expiry expectations, and review cadence, while HR and management provide the event data that triggers the change. Joiner-Mover-Leaver controls are the right mental model because holiday access is just another timed change to entitlements.
What HR, managers, and system owners each contribute
HR should own the source-of-truth events for leave status, seasonal employment, and departures, because those facts determine whether access should be retained, reduced, or removed. Managers should own business justification, timing, and approval of the exception, because they are the only ones who can confirm whether the access is still needed for work continuity. System owners should validate whether the requested entitlement is technically appropriate and whether it matches the application’s access model.
That division of responsibility matters because holiday access often fails at the handoff points. HR may know someone is away, but not which applications are involved. A manager may know access is needed for coverage, but not whether the request creates excess privilege. A system owner may understand the platform, but not the business reason for the temporary exception. Identity governance ties those three views together so the access change is both justified and reversible.
For higher-risk environments, the review process should also include explicit expiry and recertification steps. The most common failure is not the initial approval, but the forgotten reversion after the holiday period ends. A governance process that cannot demonstrate automatic expiration, post-period review, or clean rollback is only documenting temporary access, not controlling it. Access review and certification practices are the mechanism that closes that loop.
How to assign accountability without losing control
The right ownership model is usually one named accountable team with distributed execution. Identity governance should be accountable for policy, workflow, evidence, and auditability. HR should be responsible for authoritative employment and leave data. Managers should be responsible for approving the business need. System owners should be responsible for the entitlement design and for confirming that removal is technically complete.
A useful test is whether the organisation can answer three questions quickly: who approved the holiday access, when does it expire, and who verified that it was removed. If those answers live in separate inboxes or spreadsheets, ownership is too loose. If they live in a governed workflow with clear audit trails, then the control is properly owned even though execution is shared.
Good practice is also to keep the model simple enough that people actually use it. Overly complex routing, too many approvers, or vague ownership language usually leads to rubber-stamping. A short approval path with strong expiry rules is better than a perfect-looking policy that nobody follows during peak holiday periods.
Risk and Threat Considerations
Holiday access is risky because temporary exceptions often become persistent access, especially when teams rely on manual reminders or informal approvals. The exposure is not just overreach during the holiday period, but lingering entitlements, weak accountability, and incomplete removal after the exception should have ended.
Failure mechanism: Approval, expiry, and removal are split across different teams, so no single owner can prove the access was time-bounded, justified, and actually revoked. That creates a predictable path to privilege creep, orphaned access, and audit gaps.
Impact: Unchecked holiday access can increase the blast radius of a compromise, create unnecessary access during absence, and leave the organisation unable to demonstrate control over temporary entitlements during review or audit.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
NIST SP 800-53 Rev 5, CIS Controls v8 and OWASP ASVS set the technical controls, while ISO/IEC 27001:2022 defines the regulatory obligations.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST SP 800-53 Rev 5 | AC-2 — Account Management | Holiday access is a time-bounded account and entitlement change that must be provisioned and removed. |
| AC-6 — Least Privilege | Temporary access should be limited to the minimum entitlement needed for coverage. | |
| AU-2 — Event Logging | Holiday access needs an audit trail for approvals, expiry, and removal evidence. | |
| Recommendation — Use AC-2 to time-limit holiday access and ensure removal is enforced at period end. Apply AC-6 to scope holiday access to the minimum privileges needed for the exception. Log holiday access approvals and revocations so ownership and expiry are auditable. | ||
| ISO/IEC 27001:2022 | A.5.15 — Access control | Holiday access is an access-control governance problem requiring defined rules and accountability. |
| A.5.18 — Access rights | Temporary access must be granted, reviewed, and removed as a controlled access-rights process. | |
| Recommendation — Define access-control rules for temporary holiday exceptions and enforce consistent approvals. Review holiday access rights after the exception window and revoke anything no longer needed. | ||
| CIS Controls v8 | CIS-5 — Account Management | Holiday access is a core account-management lifecycle activity with approval and cleanup requirements. |
| Recommendation — Use account-management controls to grant, track, and remove holiday access on schedule. | ||
| OWASP ASVS | V8 — Authorization | Temporary access still requires explicit authorization boundaries and reviewable privilege decisions. |
| Recommendation — Verify holiday access is authorized, limited, and revocable through the application control model. | ||
Practitioner Guidance
What to prioritise: Assign one accountable governance owner, then make HR, managers, and system owners responsible for the inputs they actually control. The governance owner should control the workflow and evidence trail, not the business justification itself.
What to verify: Check that every holiday access request has an expiry date, an approver, and a removal checkpoint. If any of those three are missing, the process is not ready for operational use.
Decision rule: If the access is production-facing, privileged, or cross-system, require explicit expiry and post-period review; if it is low-risk and fully time-bounded, the approval path can be lighter, but not informal.
Practitioner takeaway: Holiday access governance works when ownership is centralised for control, while responsibility for the underlying business and system facts remains distributed across the teams that create, approve, and end the exception.
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Reviewed and updated by the NHIMG editorial team on October 11, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org