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Sanjeev NC
A lot of IT teams who are still using processes for reviewing user access often repeat the same errors. These mistakes can expose your organization to risks. Consume your team's resources and efforts. In this article we're going to change our approach. We'll focus on the pitfalls, in user access reviews. Most importantly, how to avoid them.
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A common mistake is diving into a user access review without clearly defined goals. Are you mainly concerned with checking boxes for a compliance audit? Or is your primary goal to uncover and reduce security risks? These are both valid objectives, but they'll guide your review process very differently.
Why is this important?
Focus: Clear objectives align team efforts and prevent reviews from devolving into a time-consuming exercise with little value
Efficiency: Knowing what you're looking for streamlines the review process and avoids unnecessary detours.
Outcomes: Specific objectives (security vs. compliance, etc.) shape the review process, ensuring you gather the right evidence and can address risks effectively.
How do you avoid this mistake?
Understand Drivers: Are you primarily driven by a compliance audit, a recent security concern, or a general proactive approach?
Define Scope: Will the review cover all systems or focus on high-risk, sensitive applications?
Set Key Metrics: How will you measure success? Number of revoked permissions? Time spent on review? Compliance checklist completion?
Spreadsheets might seem like a natural choice for user access reviews, but they quickly become a nightmare for IT teams. User access data gets scattered across multiple files, version control becomes a mess, and it's near impossible to visualize changes over time. The manual effort and error-prone nature of spreadsheet-driven reviews are a major drain on productivity. Don’t even get me started on VLOOKUPs.
Why is this important?
Inefficiency: Spreadsheets mean copying and pasting data, hunting down the latest versions, and manually reconciling conflicting information. This wastes valuable time.
Lack of Audit Trail: Spreadsheets make it hard to track who made changes, when, and why. This is a big problem for compliance and troubleshooting security incidents.
Prone to Errors: Manually entered formulas and endless copy-paste operations are breeding grounds for mistakes. One slip-up can create false positives or hide major security risks.
How do you avoid this mistake?
Invest in a tool specifically designed for user access reviews. These tools centralize access data, streamline workflows, and provide robust reporting.
The tool should have these features:
Centralized Data: Look for a tool that pulls access data from your various systems into one place.
Audit Trails: The ability to track all changes to approvals/revocations with timestamps and approver information.
Reporting and Visualization: Tools that offer customizable reports and dashboards to easily track trends and spot access anomalies.
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User access reviews shouldn't happen in an IT silo. Input from individuals across the organization is crucial for getting an accurate understanding of who needs access to what, and why. Not involving department heads, data owners, and other key stakeholders leads to incomplete or inaccurate reviews, causing frustration and potential security risks.
Why is this important?
Business Context: IT teams often lack the in-depth understanding of how different applications and data are actually used in day-to-day operations. Business stakeholders have this critical knowledge.
Appropriate Access Decisions: Department heads and data owners are best positioned to assess whether a user's access aligns with their job responsibilities.
Accountability: Engaging stakeholders fosters a sense of shared responsibility for security, rather than it being seen as solely an IT problem.
How do you avoid this mistake?
Identify Stakeholders:
Data Owners: Who is responsible for the data within each system?
Application Owners: Who manages the functionality of specific systems?
Department Heads: Who can confirm if a user in their team needs the specified access?
Define Roles & Responsibilities: Clearly outline what IT expects from stakeholders (approving/rejecting access, providing justifications) and what stakeholders can expect from IT (support, clear documentation).
Communicate: Keep stakeholders informed about review timelines, progress, and any issues that arise.
Also, consider formalizing a "Data Governance Committee' with representatives from key business areas to streamline these processes.
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Treating every user and every system with equal scrutiny during a user access review is a recipe for overwhelm and inefficiency. A one-size-fits-all approach fails to account for the fact that some access carries far more risk than others.
Why is this important?
Focus & Efficiency: Risk-based prioritization allows IT teams to focus their time and energy where it will have the most impact on risk reduction.
Meaningful Outcomes: Reviewing high-risk accounts and systems is more likely to uncover critical vulnerabilities or inappropriate access that needs remediation.
Combating Review Fatigue: Managers are less likely to become complacent when they know they're reviewing access that truly matters.
How do you avoid this mistake?
Risk Classification: Classify systems and data based on sensitivity (financial data, customer PII, intellectual property, etc.). Add a classification attribute to your systems inventory.
Identify High-Risk Users: Focus on those with admin privileges, access to sensitive data, and dormant accounts. Use tools if available, to highlight outliers (users with permissions significantly different from their peers).
Tiered Review Cadence: Establish different review frequencies based on risk. High-risk systems/users might get reviewed quarterly, while low-risk areas may only require an annual review.
Remember, risk assessment is not a one-time activity.
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Employees change jobs, get promoted, or move between departments. When their roles change, their access needs to change too. Failing to align user access reviews with these internal shifts creates security vulnerabilities and inefficiencies.
Why is this important?
Security Gaps: Users retaining access rights from a previous role they no longer need (sometimes called privilege creep) is a major risk. It increases the attack surface unnecessarily.
Reduced Productivity: Users lacking the access they need for their new role creates friction and inefficiencies. Access requests pile up while they wait for approvals.
Compliance Risks: Unnecessary permissions that don't align with job function could violate certain regulations or internal policies like segregation of duties.
How do you avoid this mistake?
Integrate with HR Systems: If possible, configure your UAR tool or process to receive notifications when employee roles change within your HR system.
Review Role Definitions: Use role changes as an opportunity to reevaluate and fine-tune your role-based access definitions to ensure they stay up-to-date with your organization's structure.
Third-party vendors, contractors, and external collaborators often need access to your systems to do their jobs. However, their access is often overlooked in user access reviews, creating a significant blind spot in your security posture. It's easy to lose track of who has external access and what they can do with it.
Why is this important?
Exploitable Entry Point: Vendors and contractors are frequently targeted by attackers. If a third-party account is compromised, attackers could gain a foothold into your systems.
Data Breach Liability: Even if the security breach originates from the third-party, your organization could still bear responsibility for the loss of sensitive data.
Changing Access Needs: Contractor projects end, vendor relationships change – but their access often lingers, creating unnecessary risk.
How do you avoid this mistake?
Maintain Third-Party Inventory: Keep a central list of all third-parties with system access, including what data they can access and their contract end dates.
Dedicated Review Process: Establish a separate track for reviewing third-party access. Include stakeholders responsible for managing these relationships (procurement, legal, etc.).
Prioritize High-Risk Vendors: Identify vendors with access to sensitive systems and subject them to more frequent reviews.
Software Support: Some identity management or UAR tools allow you to specifically flag external accounts for easier tracking and review.
Provisioning & Deprovisioning: Tie access reviews into the onboarding/offboarding processes of third-parties. Access should be granted only when needed and promptly revoked when the engagement ends.
Tailor your review processes based on the sensitivity of the data they handle, just like you do with your internal employees.
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Managers and other business stakeholders involved in user access reviews get bombarded with large spreadsheets or cumbersome lists of access rights. When the workload is overwhelming, it leads to rushed decisions, careless approvals, or a "just accept everything" mentality.
This is how inappropriate access slips through.
Why is this important?
Undermines Security: Hasty reviews due to fatigue defeat the core purpose of the UAR and increase the chance of serious security risks being overlooked.
Diminished Accountability: Once review fatigue sets in, approvers are less likely to question requests or provide thoughtful justifications for their decisions.
Reduced Compliance: If reviews become a mere formality, you'll struggle to demonstrate due diligence to auditors.
How do you avoid this mistake?
Implement Risk-Based Reviews: Prioritizing high-risk areas (covered in Mistake 4) dramatically reduces the overall review workload.
Micro-reviews: Instead of a single massive review, break it down into smaller batches organized by department, system, or risk level.
Workflow-Driven Tools: Choose UAR tools with clear workflows, filtering options, and easy-to-use interfaces. Make the review task as painless as possible.
Gamification: Some advanced UAR tools offer gamification features that keep reviewers engaged and reduce the feeling of it being a monotonous chore.
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Sporadic or ad-hoc user access reviews leave your organization exposed. Without regular reviews, inappropriate permissions can pile up, dormant accounts linger, and risks multiply over time. User access, especially in dynamic environments, changes quickly – infrequent reviews fail to keep up.
Why is this important?
Proactive Security: Consistent reviews help you stay ahead of security vulnerabilities arising from unauthorized access or outdated permissions.
Compliance Adherence: Many regulations (SOX, HIPAA, etc.) mandate regular access reviews. A haphazard approach could lead to compliance failures.
Efficient Remediation: Regular reviews make it easier to identify and promptly address inappropriate access, reducing the potential impact of a breach.
How do you avoid this mistake?
Define a Review Cadence: Establish review frequencies based on risk classifications (see Mistake #4) and your specific compliance requirements.
Create a Review Calendar: Develop a centralized calendar for all scheduled reviews. Factor in time for follow-up and remediation of identified issues.
Embed Reviews in Business Processes: Tie access reviews to onboarding/offboarding employees and contractors, as well as significant changes in job roles.
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User access reviews shouldn't exist in a vacuum. Without clear documentation, it's difficult to demonstrate compliance with regulations, track changes in access permissions, or investigate potential security incidents.
Why is this important?
Audit Trail: Auditors expect to see detailed records of UARs, including dates, participants, access decisions, and justifications for those decisions. Inadequate documentation is a red flag.
Accountability: Good documentation reinforces accountability throughout the review process. It provides a clear history of who approved what and why.
Troubleshooting Efficiency: When investigating security incidents, clear logs of past access changes can be invaluable for tracing the origin of a breach.
How do you avoid this mistake?
What to Document: At a minimum, record:
System or Application Reviewed
Date of Review
Review Participants (reviewers AND approvers)
Access Changes Requested
Decisions Made (approved/denied)
Justifications for Decisions
Centralized Repository: Don't let review documentation get scattered. Utilize a dedicated UAR tool or a secure document management system.
Access and Retention: Control access to UAR records appropriately. Determine how long records need to be retained based on compliance regulations and your internal risk management policies.
Automate when Possible: Some UAR tools automatically generate audit-ready reports and maintain robust logs of all review activities.
The entire purpose of a user access review is defeated if you identify inappropriate permissions, outliers, or other access risks and then...do nothing about it. Reviews without action are a waste of time and leave your organization exposed.
Why is this important?
Bridging the Gap: User access reviews provide the knowledge – taking action is what closes the security gap and truly reduces risk.
Wasted Effort: When teams dedicate time to reviews and nothing changes, it damages morale and can lead to future reviews being treated as a mere formality.
Compliance Implications: Failing to remediate issues identified during a UAR can leave you exposed during an audit, even if you have the review records themselves.
How do you avoid this mistake?
Prioritize Remediation: During the review process, identify high-risk findings needing immediate action and those that can be handled on a slightly longer timeline.
Create a Remediation Plan: Document a clear plan that includes:
The Specific Issue
Action to be Taken (revoke access, request further justification, etc.)
Responsible Party
Target Completion Date
Workflow and Accountability: If possible, incorporate remediation tasks into your UAR tool's workflow. Assign owners and track progress to avoid things slipping through the cracks.
Reporting: Include remediation status reporting as a follow-up stage in your overall UAR process.
Learn & Improve: Analyze the most common remediation needs to proactively refine access provisioning processes and reduce the volume of issues in future reviews.
Have you committed any other mistake while conducting user access reviews? Let us know!