What is Access Control Review
Access control review is the systematic examination of user permissions, authentication mechanisms, and authorization policies to verify that only authorized individuals have appropriate access to systems and data. This control testing process validates that access rights align with job responsibilities, regulatory requirements, and the principle of least privilege.
Key takeaways:
- Required by SOC 2, ISO 27001, GDPR, and HIPAA for demonstrating access governance
- Must occur quarterly for privileged accounts, annually for standard users
- Documents segregation of duties and prevents authorization creep
- Creates defensible audit trail for regulatory examinations
Access control reviews form the backbone of third-party risk management programs. When you grant vendors access to your systems, you inherit their security posture. A single compromised vendor account can expose your entire infrastructure.
The stakes multiply across your vendor ecosystem. Each SaaS provider, contractor, and business partner represents a potential attack vector. Without systematic access reviews, permissions accumulate like sediment—former employees retain credentials, role changes leave orphaned privileges, and temporary access becomes permanent.
Modern regulatory frameworks recognize this reality. SOC 2 Type II audits specifically test CC6.1 (logical and physical access controls). ISO 27001:2022 mandates access reviews under control A.9.2.5. GDPR Article 32 requires "a process for regularly testing, assessing and evaluating" security measures, explicitly including access controls.
Core Components of Access Control Review
Access control review consists of four primary activities:
- User Access Certification: Line-of-business managers attest that direct reports have appropriate system access
- Entitlement Analysis: Security teams validate that assigned permissions match documented role definitions
- Privileged Account Audit: Administrators verify elevated access remains necessary and properly monitored
- Access Path Validation: Technical teams confirm authentication flows and authorization logic function correctly
Each component generates specific evidence for your audit trail. User certifications produce timestamped attestations. Entitlement analysis creates permission matrices. Privileged audits document compensating controls. Path validation confirms technical implementation matches policy.
Regulatory Requirements and Framework Mapping
SOC 2 Trust Services Criteria
CC6.1 requires entities to implement logical access security measures. Your access control review must demonstrate:
- Authentication mechanisms for all access points
- Authorization based on job responsibilities
- Regular review cycles with documented approvals
- Revocation procedures for terminated users
CC6.2 extends these requirements to system boundaries, demanding reviews of:
- API access tokens
- Service account permissions
- Third-party integrations
- Remote access mechanisms
ISO 27001:2022 Controls
A.9.2.5 (Review of user access rights) mandates asset owners review access at regular intervals. The standard specifies:
- Formal review process with defined frequencies
- Documentation of review results
- Immediate revocation of unnecessary access
- Special attention to privileged access rights
A.9.2.6 addresses access right removal upon termination—your review must verify deprovisioning effectiveness.
GDPR Article 32
Technical and organizational measures must include:
- Regular testing of access control effectiveness
- Assessment of authorization appropriateness
- Evaluation of data minimization through access restrictions
- Documentation proving ongoing compliance
HIPAA Security Rule
45 CFR 164.308(a)(4) requires access authorization procedures. Reviews must validate:
- Workforce clearance procedures
- Access establishment and modification
- Minimum necessary standards
- Sanction policies for violations
Practical Implementation for Vendor Risk
Vendor Access Inventory
Start with comprehensive discovery. Most organizations underestimate vendor access points by 40-60%. Document:
Direct System Access
- VPN credentials issued to vendor personnel
- Shared mailboxes accessible by third parties
- Database accounts for integration purposes
- Administrative access for managed services
Indirect Access Paths
- OAuth tokens for SaaS integrations
- API keys embedded in vendor applications
- SSO federation trusts
- File transfer protocol accounts
Review Frequency Matrix
| Access Type | Review Frequency | Reviewer | Evidence Required |
|---|---|---|---|
| Privileged vendor accounts | Quarterly | CISO + Vendor Manager | Access logs + business justification |
| Standard vendor access | Semi-annually | System Owner | Current contract + access certification |
| API/Integration tokens | Quarterly | Technical Owner | Usage metrics + data flow diagram |
| Dormant accounts (90+ days) | Monthly | Security Operations | Deactivation approval |
Common Vendor Access Failures
Ghost Accounts: A financial services firm discovered 147 active vendor accounts belonging to terminated contractor personnel during their Q3 2023 review. The exposure window averaged 18 months per account.
Permission Sprawl: Manufacturing company found their ERP integration vendor had accumulated read/write access to most database tables over three years. Initial scope covered 12% of tables.
Stale Integrations: Healthcare provider identified 23 active API connections to deprecated vendor services. Several connected to vendors whose contracts ended 2+ years prior.
Control Implementation Roadmap
Phase 1: Discovery and Baseline (Weeks 1-4)
- Export user lists from all systems with external access
- Cross-reference against vendor management database
- Identify access without current contracts
- Document initial findings and exposure metrics
Phase 2: Process Design (Weeks 5-8)
- Define role-based access templates for vendor categories
- Establish review frequencies based on risk ratings
- Create certification workflows with escalation paths
- Design exception handling procedures
Phase 3: Initial Review Cycle (Weeks 9-16)
- Launch pilot with high-risk vendor subset
- Conduct line-of-business manager training
- Execute first complete review cycle
- Remediate critical findings immediately
Phase 4: Automation and Maturity (Ongoing)
- Implement technical controls for dormant account detection
- Deploy access analytics for anomaly identification
- Integrate with vendor risk scoring
- Establish continuous monitoring capabilities
Evidence Collection for Auditors
Your access control review must produce specific artifacts:
Review Documentation
- Certification emails with manager attestations
- Screenshot evidence of access modifications
- Ticket numbers for revocation requests
- Exception approvals with risk acceptance
Technical Evidence
- Access reports with last-login timestamps
- Permission comparison reports (current vs. approved)
- Authentication logs for privileged activities
- System configuration baselines
Process Artifacts
- Review calendar with completion tracking
- Escalation records for missed deadlines
- Training attendance for certifying managers
- Continuous improvement recommendations
Industry-Specific Considerations
Financial Services
PCI DSS 8.2.4 requires quarterly reviews for all access. FFIEC guidance emphasizes third-party access monitoring. Reviews must address:
- Segregation between payment processing and development
- Multi-factor authentication for remote vendor access
- Activity monitoring for database administrators
Healthcare
HIPAA requires access reviews to enforce minimum necessary standards. Beyond user reviews, examine:
- Vendor access to different PHI categories
- Audit logging for all protected data access
- Business associate agreement alignment
Technology/SaaS
Focus on development environment access and production separation:
- Code repository permissions for offshore teams
- CI/CD pipeline access for DevOps vendors
- Customer data access for support providers
Frequently Asked Questions
How frequently should we review vendor privileged access?
Privileged vendor accounts require quarterly reviews per SOC 2 CC6.1 and PCI DSS 8.2.4. High-risk vendors or those with production access may warrant monthly reviews.
What constitutes sufficient evidence for access review completion?
Timestamped certification emails from system owners, access modification tickets, screenshots showing permission changes, and signed attestation forms create a complete audit trail.
How do we handle vendor resistance to access reviews?
Include review requirements in contracts with SLA penalties. Escalate to vendor management for relationship leverage. Document all vendor non-compliance for risk acceptance decisions.
Should service accounts be included in access control reviews?
Yes. Service accounts often have elevated privileges and don't follow standard password policies. Review them quarterly with technical owners validating continued necessity.
How do we review access for small vendors without formal IT processes?
Request screenshot evidence of their access. Use read-only audit accounts to verify independently. Consider more frequent reviews to compensate for limited vendor controls.
What's the difference between access review and access recertification?
Access review examines whether current permissions remain appropriate. Recertification is the formal process where managers attest to this appropriateness in writing.
How long should we retain access review documentation?
Retain for the longer of: three years, two complete audit cycles, or your regulatory requirement. HIPAA requires six years, while SOX typically requires seven.
Frequently Asked Questions
How frequently should we review vendor privileged access?
Privileged vendor accounts require quarterly reviews per SOC 2 CC6.1 and PCI DSS 8.2.4. High-risk vendors or those with production access may warrant monthly reviews.
What constitutes sufficient evidence for access review completion?
Timestamped certification emails from system owners, access modification tickets, screenshots showing permission changes, and signed attestation forms create a complete audit trail.
How do we handle vendor resistance to access reviews?
Include review requirements in contracts with SLA penalties. Escalate to vendor management for relationship leverage. Document all vendor non-compliance for risk acceptance decisions.
Should service accounts be included in access control reviews?
Yes. Service accounts often have elevated privileges and don't follow standard password policies. Review them quarterly with technical owners validating continued necessity.
How do we review access for small vendors without formal IT processes?
Request screenshot evidence of their access. Use read-only audit accounts to verify independently. Consider more frequent reviews to compensate for limited vendor controls.
What's the difference between access review and access recertification?
Access review examines whether current permissions remain appropriate. Recertification is the formal process where managers attest to this appropriateness in writing.
How long should we retain access review documentation?
Retain for the longer of: three years, two complete audit cycles, or your regulatory requirement. HIPAA requires six years, while SOX typically requires seven.
Put this knowledge to work
Daydream operationalizes compliance concepts into automated third-party risk workflows.
See the Platform