What is an access review?
An access review is a periodic check, usually quarterly, that every user’s access to systems still matches their role, with any removals recorded. It is one of the first pieces of evidence a SOC 2 or ISO 27001 auditor samples, because access that outlives its purpose is a common way into a system.
What a review covers
The reviewer receives a list of everyone who can reach a system and at what level, and confirms that each account is still needed. Anything that is not needed is removed or reduced, and the change is recorded. The systems in scope are usually the identity provider, cloud consoles, production databases, source code, and any business system that holds customer data.
Joiner and leaver processes are meant to prevent stray access. The review catches what they missed: people who changed roles and kept their old permissions, contractors past their end date, shared accounts and service accounts nobody owns. Privileged and third-party accounts are where most findings come from.
What auditors check
In a SOC 2 Type II audit the auditor picks reviews that fell inside the observation period and follows each one from the user list to the removals. ISO 27001 auditors do the same against control 5.18, which expects access rights to be reviewed at regular intervals.
A review where every account was approved and nothing changed, on a system with regular joiners and leavers, makes an auditor ask whether anyone really looked.
- Complete population. The user list was exported from the system itself and dated, not typed up by hand.
- Right reviewer. Someone who knows what the role needs decides, and nobody approves their own access.
- Decisions recorded. Each account is marked keep, change or remove, with the reviewer’s name and the date.
- Removals done. A ticket or log shows each removal was carried out, and when.
Running reviews that hold up
Set the frequency by risk and write it into the access control policy: quarterly for production and privileged access is a common choice, with less frequent reviews for low-risk tools. Then keep to it. A missed quarter becomes an exception in a Type II report.
Where access is granted through groups in an identity provider, review both who is in each group and what each group can do. Keep every cycle’s export, decisions and removal tickets together, so the evidence for one review can be handed over in one piece.
Questions
Access review, answered
How often should access reviews happen?
Neither SOC 2 nor ISO 27001 sets a frequency. You set one in your access control policy and the auditor tests against it. Quarterly is common for production and privileged access. PCI DSS requires user accounts and access privileges to be reviewed at least once every six months.
Who should carry out the review?
The person who understands what access each role needs, usually the system owner or the user’s manager. Security can run the process and chase responses, but a reviewer should never approve their own access.
Does a good offboarding process replace access reviews?
No. Offboarding removes access when someone leaves. The review finds the access offboarding missed, and the access that built up as people moved between roles.
Working through this for an audit?
Talk it through with someone who has run the audit before, or look up another term.
- Each customer workspace has its own database
- Every change written to a tamper-evident activity log
- Auditors get scoped, read-only access
- AI suggestions wait for a person to accept them