It is possible that the page was indexed by google at a time it was made accessible/visible by the editor.
Otoh it is possible that due to bad cache management (caused by custom templates), a link to to an inaccessible/invisible page was shown. Google followed that link to an 'error, access denied' page and indexed that page. By default I think there is no meta tag that blocks indexation of those pages.
Imho the best way to prevent indexation of error pages could be too look up $ui_component variable in the pagelayout template; it seems to be set on "error" on all error pages.
Principal Consultant International Business
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