ISO 27001 User Access Review: Roadmap for Compliance

Samuel Bismut
CTO and co-founder
December 4, 2024
1
minute of reading

Ensuring that only authorized individuals have access to necessary SaaS applications and data is a cornerstone of ISO 27001 compliance. This standard aims to create a controlled access environment where access is granted based on individual necessity. Regular user access reviews are crucial for adhering to this standard, enabling effective management and governance of the organization’s access landscape. An effective user access review involves a systematic and structured approach, ensuring security and compliance are maintained through formal processes and regular scheduling.

Without a solution in place that can help with access reviews, you are stuck with a highly manual and unpleasant task that you need to do four times per year—these are typically quarterly reviews. Depending on your risk assessment and compliance requirements, organizations may opt for monthly or quarterly reviews, as ISO 27001 allows for flexible scheduling based on risk. Automating this process can significantly improve operational efficiency.

The Benefits of ISO 27001 Compliance

Complying with ISO 27001 enhances security and supports regulatory compliance by allowing IT teams to manage who has access to what, reducing the risk of data breaches and unauthorized access. Additionally, it helps protect the organization’s reputation, especially by safeguarding customer data, which is highly sensitive and subject to strict regulatory requirements. In the event of a security breach, effective access control management minimizes potential penalties and negative PR impacts. Many, especially larger and more established, companies prefer to buy from vendors that have at least one certification. In the European market, ISO 27001 is widely recognised as certification. ISO can be a door opener to sell to more traditional companies.

The Risks of Non-Compliance

A non-compliant company trying to get certified will struggle in the process without proving comprehensive conformity on the requirements. Beyond the issues of not getting certified or losing your certification, failing to comply with ISO 27001 can have severe consequences for the company. It is akin to giving keys to your office to anyone who asks, inviting potential attackers into your systems. Such negligence can lead to data loss, legal and regulatory penalties. Inadequate user access management also exposes the organization to significant security risks and information security risks, such as unauthorized access, data breaches, and increased vulnerability to cyber threats.

Needless to say there is also a business impact. Auditors often grant the initial certification despite lacking access management but latest at the second audit, non-conformities in this area can lead to the loss of the certification. As many companies get certified in order to boost their sales, this loss will have a business impact as the signal of security and safety will be lost. A loss of certification can very well be a reason that a client cancels a contract.

Key Aspects to Focus on for ISO 27001 Compliance

To comply with ISO 27001, focus on these critical aspects of user access management that are required to be fulfilled in order to pass the audit:

  1. User Access Lifecycle: Establish clear processes for managing user access from onboarding to offboarding. This includes granting, modifying, and revoking both physical and logical access as needed. Ensure that access rights are promptly revoked for employees, third party vendors, and external party users when they leave or change roles.
  2. Requesting Access: Develop a formal system for users to request access to systems, applications, or resources, specifying their needs. Requests should be aligned with business requirements and the organization's access control policy.
  3. Approving Access Requests: Implement a flexible approval process, ensuring only authorized personnel can grant access, typically involving managers verifying the alignment of requests with job responsibilities. Approvals should consider user roles, associated permissions, and the principle of least privilege.
  4. Implementing Access: Ensure a structured approach to implementing approved access, including provisioning user accounts, modifying user permissions, setting up necessary security controls, and managing temporary access where appropriate.
  5. Managing Changes to Access: Establish protocols for updating access permissions as users’ roles change, revoking unnecessary access, or granting additional access as required. Changes should be based on risk assessment, and special attention should be given to privileged accounts and asset owners. Automated user provisioning not only makes the job of your IT manager easier, it also increases security and compliance.
  6. Monitoring Access: Regularly monitor user access to detect anomalies or unauthorized activities. Use security tools and system logs to track system access, who accesses what and when, and monitor user identities through integration with HR systems, identifying potential threats proactively.
  7. Revoking Access: Ensure both logical access and physical access are promptly revoked when no longer needed or when a user leaves the organization. This process must include external party users and third party vendors to prevent unauthorized access.
  8. User Responsibilities: Clearly define user responsibilities for safeguarding authentication information and following secure log-on procedures, including the use of multi factor authentication.
  9. Access Control Procedures: Maintain documented access control procedures for managing access to information assets and ensuring regulatory compliance.

By effectively addressing these aspects, your IT team can seamlessly comply with ISO 27001, ensuring controlled and secure access to your organization’s systems and data.

Information Processing Facilities and Access Reviews

Information processing facilities are the backbone of any organization’s digital operations, serving as the central hubs where sensitive data is stored, processed, and transmitted. Because these facilities handle valuable assets and critical data, implementing strong access control measures is essential to safeguard against unauthorized access and potential data breaches.

Regular user access reviews play a pivotal role in maintaining the security of information processing facilities. By reviewing user access rights at regular intervals, organizations can ensure that only authorized individuals have access to these sensitive environments. This proactive approach helps identify and address unnecessary access, outdated permissions, or unauthorized users who may pose a significant risk to information security.

Effective access control measures, combined with thorough user access reviews, help organizations detect and prevent unauthorized access before it leads to data breaches or operational disruptions. By ensuring that user access to information processing facilities is reviewed regularly, businesses can maintain a strong security posture, comply with ISO 27001 requirements, and protect their most sensitive data from evolving security threats.

How User Automated Access Reviews Help Achieve ISO 27001 Compliance

ISO 27001 includes Annex A, which outlines controls for the information security management system (ISMS). The iso 27001 annex provides the formal requirements for access reviews, establishing a structured process for managing, reviewing, and revoking access rights. One essential control is the “periodic review of access rights.” Regular access reviews are mandatory for compliance, ensuring that all users with access are authorized. This process helps identify unauthorized users and mitigate risks associated with disgruntled former employees, temporary staff, or contractors. Most companies do this quarterly so they check if the accesses are still up to date 4 times per year. This is a very manual, repetitive and frankly boring task.

For example, if an ex-employee’s account remains active, they could misuse their credentials to gain unauthorized access. Timely user access reviews are crucial to prevent unauthorised access to systems, applications, or sensitive data. This could lead to unauthorized data access, data leaks, or even malicious attacks.

Depending on the organization’s size and complexity, user access reviews can range from simple data extractions to sophisticated analytical methods. It is important to keep records of these reviews and prepare for audits. Internal audit processes play a key role in verifying that access control policies and procedures are effectively implemented, helping to ensure compliance with ISO 27001 requirements. Here’s how your IT team can conduct user access reviews effectively:

Best Practices for User Access Reviews

A formal user access review process is essential for managing access rights across the organization. Establishing a systematic, recurring procedure ensures that user privileges are regularly audited and aligned with security and compliance requirements.

  1. Implement Role-Based Access Control (RBAC): Assign specific permissions to different job roles to streamline onboarding and access management. This simplifies access reviews by focusing only on special permissions.
  2. Set Up and Update Access Policy: Develop and maintain an access policy that outlines what permissions are needed for each job role. Update this policy as organizational needs evolve.
  3. Decide Review Frequency: Determine how often access reviews should occur based on compliance requirements and the criticality of the resources. Conduct regular reviews to maintain security.
  4. Record Audit Results: Keep a record of findings from access reviews, including evidence from system logs, to identify potential issues and improve the process. This will also make the process easier for the upcoming audit which is never far away!

Simplifying and automating Access Reviews with Corma

Managing user access reviews manually can be challenging, especially in large organizations. Automated solutions like can simplify this process. Corma offers features such as automated access reviews, auto-remediation, and activity alerts, helping your IT team manage user access and meet ISO 27001 requirements without dozens and dozens of manual work.

For example, consider an intern who gains access to multiple departments' systems during their internship. Even if they don't intend to misuse this access, retaining these permissions poses a risk. Corma helps you conducting frequent reviews and helps revoke unnecessary permissions, ensuring security.

Corma's advanced capabilities provide full visibility into user access data, simplifying the access review process. By leveraging tools like Corma, your organization can effectively manage user access, maintain data security, and ensure ISO 27001 compliance. By implementing these best practices and utilizing advanced tools, your IT team can achieve and maintain ISO 27001 compliance, ensuring a secure and well-controlled access environment.

The IT Circle
January 27, 2026

The IT Circle: Interview with Manuel Cuesta, Group CIO at Rubis Energie

Read Article
SaaS Management
January 21, 2026

20 Best SaaS Management Platforms in 2026

Read Article
The IT Circle
January 6, 2026

45 Years in IT: Key Lessons from Orange's Zaima Chati

Read Article

The new standard in license management

Ready to revolutionize your IT governance?