User Access Reviews: A Step-by-Step Guide + Checklist

There’s a good chance that you’ve shared a login with a colleague to help them quickly complete a task. While this may seem harmless, one small instance of sharing access to systems containing sensitive information can quickly snowball into a much bigger problem. 

The truth is countless data breaches can stem from improper access management. Verizon’s 2022 Data Breach Report found that 82% of data breaches were caused by credential theft, phishing attacks, and employee misuse or mistakes. 

The good news is that there are steps you can take to help protect your data and better control how access is granted and managed. Below, we dive into how to perform user access reviews and provide a simple checklist to streamline the process.

What Are User Access Reviews?

A user access review (UAR) is a process that involves regularly reviewing access rights for a company’s employees and third-party vendors. The goal is to limit the number of employees who can access sensitive data to reduce the risk of a data breach.

A user is a term that describes more than just your organization’s employees. It also extends to anyone who interacts with your systems and data, each with different access needs: 

• Business partners often need user access rights to collaborate on joint projects or shared platforms. Their access should be strictly limited to the systems or data necessary for the partnership. It’s also a good idea to have formal agreements in place that outline how data is shared and how long access will be granted. 

• Vendors, such as IT or cloud service providers, require access to keep your systems running without a hitch. However, their access should be restricted to the systems they need and monitored closely for any unusual activity. 

• Contractors require temporary access to systems and data to complete their tasks, but only for a limited time. You want to grant them just enough access to do their jobs, and revoke it as soon as their contract ends. 

• Former employees are one of the biggest insider threats when their access hasn’t been properly revoked. If companies fail to withdraw access immediately after they leave, they leave their data hung out to dry.

Why Are Access Reviews Important?

With data breaches on the rise, it’s all the more important to ensure the access to sensitive data gets locked down within your organization. 

Proactively addressing user access can help you avoid costly data breaches, like the Cash App breach of 2022. A former employee downloaded internal reports without permission, leading to a data leak that impacted 8 million Cash App customers. 

Access reviews help alleviate a number of data issues, including: 

• Privilege creep: Occurs when an employee changes job roles within an organization and receives new privileges. Privilege creep can occur naturally over time, where employees who have been with the organization a long time obtain access to more and more systems.

• Privilege misuse: Involves mishandling data or installing unapproved hardware or software.

• Privilege abuse: Happens when user accounts get used inappropriately or fraudulently used—either maliciously, accidentally, or through willful ignorance of policies.

What Standards, Laws, and Regulations Encourage User Access Reviews? 

Many standards, laws, and regulations include guidance for companies to implement user access measures within their organization. We dig into a few common security frameworks and how they handle user access reviews below. 

Payment Card Industry Data Security Standard (PCI DSS) 

PCI DSS is a data security standard that ensures companies accept, process, store, or transmit cardholder data safely and securely. PCI DSS is transitioning from the current version v3.2.1 to v4.0, effective March 31, 2025. 

This new version includes updated requirements regarding access reviews to be aware of, including: 

• User accounts and related access privileges (including third-party/vendor accounts) must be reviewed every six months to ensure access remains appropriate. 

• Application and system accounts must be based on least privileges needed for operability. 

• Employee access must be limited to the systems, applications, or processes that are necessary for them to perform their roles. This is also referred to as Role-Based Access Control. 

• Organizations must employ policies and procedures to manage and assign accounts and related access privileges. 

SOC 2 

SOC 2 is a security framework that guides how companies should manage, process, and store customer data based on the Trust Services Criteria (TSC). 

When it comes to access management for SOC 2, best practices include: 

• Employee offboarding management: Consider implementing automated access restrictions when an employee leaves to ensure departures don’t turn into security breaches. 

• Physical access controls: Access control isn’t limited to the digital world. Consider the physical access points (security gates, door locks, employee ID cards) that also need to be managed. 

• Multi-factor authentication (MFA): MFA is a common control that helps companies secure logins and prevent unnecessary access sharing. 

Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act—better known as HIPAA—is the United States’ legal standard for protected health information (PHI) protection. The HIPAA Security Rule specifically outlines requirements for managing access to PHI and electronic protected health information (e-PHI), which includes: 

• Information access management: Covered entities must implement policies and procedures for authorizing role-based access to e-PHI. 

• Workstation and device security: Covered entities must implement policies and procedures outlining the proper use of and access to workstations and electronic media. 

• Audit controls: Covered entities must implement hardware, software, or procedural mechanisms to record and examine access and other activity in information systems that contain or use e-PHI.

General Data Protection Regulation (GDPR) 

The European Union passed the General Data Protection Regulation (GDPR) in 2016 and went into effect in 2018. GDPR aims to regulate how organizations collect, process, and store the personal data of EU residents. Article 32 of the regulation requires organizations to “implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk,” which includes identity and access management (IAM). 

Managing identity and access management under GDPR can include: 

• The Principle of Least Privilege (POLP): Providing the minimal level of permissions to a user to do their job. 

• Segregation of duties: An approach requiring more than one user to complete tasks related to the collection or processing of customer information .

• Authentication: Techniques like two-factor authentication (2FA) or MFA can verify user identities. 

Sarbanes-Oxley Act (SOX) 

The Sarbanes-Oxley Act is a law passed by the U.S. Congress on July 30, 2002. Known as the SOX Act, it means to protect investors from fraudulent financial reporting by corporations. ITGCs or IT General Controls are a subset of the Sarbanes-Oxley (SOX) internal control set that protect the security of IT systems and data centers, data backup and storage, and change management activities. 

The ITGS portion of the SOX Act also includes requirements for limiting access to and protecting financial data. Managing access rights under SOX includes: 

• Overseeing access rights when onboarding new employees, as employees transition to new roles, and when they leave the organization. 

• Implementing Segregation of Duties (SoD). 

• Maintaining an access control matrix. 

• Performing periodic access audits.

Common Obstacles to Conducting User Access Reviews

In an ideal world, implementing cybersecurity measures would be as easy as flipping a switch. But as relentless news about data breaches reminds us, security is anything but straightforward.

User access reviews aren't an exception. While essential for maintaining a strong security posture and staying compliant, they can pose a formidable challenge.

Scope and Complexity for Large Organizations 

User access reviews can be a long process for organizations with complex IT infrastructures and hundreds (or thousands) of employees. Reviewing access rights for all these people across multiple systems and applications is detail-oriented work. Each system may have its own set of permissions and access levels, which only adds layers of complexity to the process. 

Of course, business doesn't stop for these reviews. IT teams must conduct them without disrupting the daily flow of work and halting productivity.

Resistance from Stakeholders

Getting buy-in from all necessary stakeholders can be an uphill battle. Department heads might perceive access reviews as just another administrative task eating into their team's productivity. There's a common worry that tightening access might slow things down or make work more complicated. 

It's not just the higher-ups who might push back, as individual users can get pretty attached to their access privileges. When permissions are revoked, you might hear grumbling—or worse, run into attempts to work around the new restrictions. If the reasoning behind access changes isn't clearly communicated, people can get frustrated and become uncooperative.

Lack of Clear Processes and Visibility

It's not unheard of for companies to lack a complete inventory of the systems and applications their employees can access. To make matters worse, different departments control access to different systems, turning what should be a straightforward review into a wild chase across the organization.

Then there's the challenge of managing user identities throughout their lifecycle, from onboarding to role changes to offboarding. Keeping track of appropriate access levels can easily slip through the cracks, resulting in access creep and a number of orphaned accounts.

How to Perform an Access Review: 6 Steps

So, how exactly do you review user access? Below is an easy six-step process.

1. Create an Access Control Matrix

The first step in locking down user access is to understand where your high-risk data lives and determine who needs access. One way to do this is by creating an access control matrix. 

An access control matrix is a table that identifies access permissions between specific subjects and objects. A subject refers to the people who need access to objects. Objects are files, resources, system processes, data, or tools that subjects need to do their job.

To create a matrix for your organization:

List All Users and Systems

Compile a list of all users who have access to your systems, including employees, contractors, partners, vendors, and service providers. Your list should also include the systems, applications, and data each user has access to.

Define Access Permissions

Designate user permissions for each subject and object within your organization. This includes specifying what they can do with the systems or data to which they have access. Companies often use the following attributes to assign varying levels of permissions:

• Read: The subject can open and read the object but not edit it. 

• Write: The subject can read the object and add or write new content. 

• Execute: The subject can execute particular programs.

2. Develop an Access Management Policy

After establishing your access control matrix and understanding the current access permissions within your organization, you can draft your access management policy. This policy will serve as the foundation for how your organization handles user access moving forward.

Inventory Critical Data and Resources

Identify and document the key data and systems that need to be protected, including sensitive information, proprietary data, and mission-critical systems. 

Define User Roles and Responsibilities

Outline the roles within your organization and the permissions required for each. Cover every team and department and define:

• Who has the authority to grant or revoke access 

• Who is responsible for conducting access reviews

• How these roles fit into your broader security strategy

Document Access Controls and Processes

Document the processes for granting, revoking, and modifying access rights, including how access requests are made, who approves them, and how long access should be granted. 

If you’re using methods like multi-factor authentication or least privilege principles, document them as well.

Include Guidelines for Periodic Reviews

Decide how often you will perform access reviews based on your organization’s size, risk level, and regulatory requirements. 

One access review myth is that regular user access reviews occur quarterly or monthly. However, best practices are to do access reviews every six months or once a year. High-risk systems may require more frequent reviews, while lower-risk systems may be reviewed less often.

3. Begin a User Access Review Process

Once you have your access management policy documented, begin the access review process: 

Assign Responsibilities for the Review Process

Typically, this involves both IT and department managers. IT teams are often responsible for generating access reports and handling technical aspects, while department heads and managers can validate whether access rights are appropriate for their teams’ job functions. You’ll also need to assign responsibilities to relevant team members. 

Review User Access Against Roles

Begin the review by examining each user's access permissions in relation to their current role. The review is conducted based on two criteria:

• Is the user’s access to the system or service appropriate based on their role? 

• Are the user’s permissions within the system or service appropriate based on their role? 

This step helps you identify users who have accumulated excessive permissions or those who no longer require access.

Flag Unnecessary or Inactive Accounts

During the review, look for any unnecessary or inactive accounts. These might include:

• Users who have left the company but still have active accounts

• Contractors whose projects have ended

• Accounts that haven’t been used in a significant amount of time

4. Train Team Members on the Importance of Access Permissions

Training is another key aspect of protecting your organization’s access permissions. Your team should receive formal training on your access management policy to ensure they understand the importance of following those procedures.

Educate Everyone on the Importance of Access Controls

Explain to your team why access controls matter. Paint the big picture—how improper access can lead to data breaches, security incidents, or compliance violations. To drive the point home and make the security risks feel more tangible, use real examples. The Cash App breach mentioned earlier is a good start, or you could share instances where your own organization has faced similar challenges.

Highlight the consequences of non-compliance at the individual level. Make it clear that mismanaging access doesn’t just impact the company through fines, legal penalties, or reputational damage—it could also have a resounding impact on each individual team member dealing with the fallout of a breach. 

However, don't leave it on a negative note. Shift the focus to success stories and share examples of how proper access controls have prevented these issues. If your company has averted a crisis thanks to well-managed access, that's a powerful tale to tell. If not, industry examples abound.

Provide Role-Specific Training

Each department or team will have different access needs, so tailor your training to fit those specific requirements. 

For example, IT teams might need a deeper understanding of system-level permissions, while other departments need to understand their role in and procedures for requesting, granting, and managing access. Make sure the training is relevant to each group’s day-to-day responsibilities.

5. Implement Role-Based Access Control (RBAC) and the Principle of Least Privilege (POLP)

As you’re considering ways to further protect your data from unauthorized access, there are two effective techniques to consider: Role-Based Access Control (RBAC) and the Principle of Least Privilege (POLP). 

• Role-based access control (RBAC) is a process where organizations assign permissions to employees based on their job role. 

• Principle of Least Privilege (POLP) is a process where organizations limit employee access rights to only those they need to effectively perform their job. 

Building RBAC and POLP into your access management procedures helps your security program shift left and prevent access issues in the first place.

6. Analyze Access Review Results and Improve Processes Continuously

Once you've completed your review, look for opportunities to enhance your access management processes. 

Evaluate Trends in Access Issues

Analyze the results to identify recurring trends or issues. Are there specific systems or departments that frequently have inappropriate access? Are certain permissions being granted too broadly? Recognizing patterns helps you understand where your access controls may be weak or misaligned.

Assess How Effective Your Access Revocation Process Is

Evaluate how quickly and efficiently your team is revoking access after someone leaves the company or changes roles. If delays are common, you might need to tighten or automate the revocation process.

Adjust Access Controls Based on Your Findings

Use the results of your access review to make adjustments to your access controls. This could involve:

• Implementing stricter access rules for high-risk systems.

• Reducing permissions for specific roles.

• Addressing recurring privilege creep issues by automating access limitations.

Track and Measure Improvement Over Time

Keep track of the metrics associated with your access reviews (such as the number of revoked permissions, the speed of access adjustments, and the frequency of access violations) to assess the effectiveness of your access management process and show improvements to stakeholders.

Best Practices for Effective User Access Reviews

Below we outline a few best practices to keep your access reviews efficient, thorough, and aligned with your organization's security and compliance needs.

Prioritize High-Risk Systems and Data

Where access risk is concerned, not all systems are equal. During access reviews, prioritize those that contain sensitive data, as they are often the primary targets for external threats and insider misuse. 

High-risk systems generally include those that:

• Store or process personally identifiable information (PII).

• Contain financial data or transaction records.

• House intellectual property or trade secrets.

• Handle customer data or other confidential information.

• Are critical to your core business operations.

Establish (and Stick to) a Consistent Review Schedule

A consistent schedule—whether every six months or annually—turns access reviews into a regular part of your security practices. You’ll catch onto issues like privilege creep and unnecessary access early, and prevent them from slipping under your radar until they snowball into major security risks.

In some industries, regulatory requirements may dictate how frequently reviews need to occur, so be sure to align your schedule with any compliance obligations.

Involve Department Heads in the Review Process

The IT team often spearheads access reviews, but it’s important to involve department heads and managers who have a deeper understanding of what their teams need to be able to access. 

Department heads can better determine whether their team’s access is appropriate and can flag any unnecessary or outdated permissions.

Document Everything

If it's not written down, it didn't happen. It’s in your organization’s best interest to keep detailed records of who has access to what, any changes you make during reviews, and why you're granting or revoking access. In the event of a security incident or an audit, you’ll be able to demonstrate that your organization is following best practices for access management.

Documentation also helps keep things consistent from one review to the next and lets you easily spot how access has changed over time. "Why does Jake from Accounting have access to the marketing database?" Your documentation should have the answer.

Automate Where Possible

Manually tracking access across your entire organization is both time-consuming and liable to errors. There are parts of the process where you can leverage automation to save time and improve the accuracy and consistency of your reviews. Automation tools can:

• Generate regular user access reports.

• Send timely reminders to reviewers.

• Flag unusual access patterns.

• Track the progress of ongoing reviews.

While automation handles these routine tasks, your team can focus on the aspects that require human judgment—like evaluating unusual access patterns or making decisions about appropriate levels of access.

User Access Review Checklist

To help you perform effective user access reviews, we created this downloadable checklist. 

Download User Access Review Checklist

How Drata Can Help You Automate User Access Reviews

Protecting your data from improper user access is no small task—whether your organization is just starting up or at the enterprise level. Finding ways to help automate aspects of user access management not only frees up your employees to focus on their responsibilities but also helps prevent human error. 

A tool like Drata enables you to automate risk management processes, sending you alerts for new or evolving risks, helping you determine a treatment plan, and addressing concerns before they pose a real threat to your business.

Ready to learn more? Schedule a demo with our team today.