User Access Reviews: Best Practices for Security & Compliance

Most organizations today operate in a multi-application environment, where thousands of users regularly access various applications. Many of these applications store or provide access to sensitive data that needs to be protected.

With new privacy regulations coming into effect worldwide, data protection has become a regulatory requirement. User access reviews, also known as user certification, are a critical process that helps security teams, compliance managers, and business owners understand who has access to what and make informed decisions about whether a particular access is necessary.

This article offers a complete overview of the entire user access review process and helps you understand the various steps and best practices you can follow to streamline user access reviews within your organization.

What is a User Access Review (UAR)?

A user access review is a periodic evaluation of the access rights granted to individuals for computing systems and networks. This control inventory identifies users who have access permissions and checks the activity of their access, including the identity of the users, the resources they are attempting to access, the privileges they possess, and whether they are appropriately authorized to have these access rights.

The review examines all parties with privileged access, including employees, third parties, and contractors, with the objective of preventing any accidental or intentional misuse of these rights. Neglecting user access reviews can lead to the undetected malicious activities of individuals with compromised access rights.

Why is it Important to Review User Access Rights?

As the organization grows and the number of employees, and consequently the number of roles, increase, managing access becomes increasingly difficult. The purpose of any user access review exercise is to decrease the risk of security breaches by revisiting access rights on a regular basis and making informed decisions based on who has access to sensitive data and critical resources and if such access is indeed necessary for a given user.

User access reviews are an effective method of mitigating threats such as:

Privilege Creep

Privilege creep occurs when users have access to certain sensitive data even though they do not need access to it. As employees move to different roles within the organization and are assigned more responsibilities, in many cases, their old access rights are not revoked. Access reviews help security teams to identify roles and authorizations that are not needed or are unused and revoke them.

Excessive Privileges

While certain access privileges are essential for the user to perform their tasks, there are instances when a user is granted greater access to execute one-time transactions. However, when there is no mechanism to cut off access after the task is done, many users end up with more access privileges than necessary. User access reviews enable the revocation of unnecessary access privileges and reduce overprovisioning.

Access Abuse and Errors

Access to sensitive and critical data can lead to data breaches, abuse or unauthorized changes due to an error, especially when it concerns financial transactions and reporting, which can prove costly for the organization. By ensuring access is granted only where it is required, reviews play a significant role in mitigating the abuse or unintentional misuse of data.

Insider Threats

Insider threats are one of the most significant risks faced by most organizations. Whether it’s a disgruntled employee or a compromised account, the greater the access to data, the greater the risk of exposure. User access reviews help security and IT teams enforce the principle of least privilege, thereby reducing data exposure only to the extent it is required. Even if a breach occurs, limited data access mitigates the reach of the threat and prevents the threat from causing greater damage to the organization.

In addition to the above benefits, regular user access reviews can help organizations achieve compliance and stay current with new privacy mandates and regulations.

User Access Reviews Are Required for Many Businesses

Depending on your location and type of business, user access reviews could be a regulatory requirement. And even if they are not, multiple security and compliance guidelines recommend conducting a review at least once a year. Listed below are access review recommendations and mandates mentioned in some of the most pertinent security guides and regulations.

The National Institute of Standards and Technology (NIST) is a US government agency that provides widely accepted cybersecurity guidelines and standards. NIST’s Special Publication 800-53, specifically controls AC-1 and AC-2, requires organizations to review their access rights and policies periodically. Organizations can set their own schedules for these reviews and use specialized software to assist in the process. For more information, check out this overview of the NIST framework.

The Payment Card Industry Data Security Standard (PCI DSS) is a global security standard for handling credit card and cardholder data. It mandates granular access control, the principle of least privilege, and periodic reviews of user roles and rights (Requirement 7). Requirement 12 also calls for an annual review of access control policies. Organizations can self-assess the frequency and quality of these reviews.

The Health Insurance Portability and Accountability Act (HIPAA) regulates data protection for US healthcare companies. HIPAA 164.308, Administrative Safeguards, requires a periodic review of access policies and procedures to manage user access rights. The US Department of Health and Human Services audits organizations to ensure compliance.

The General Data Protection Regulation (GDPR) governs data privacy laws across the European Union (EU) and applies to organizations handling personal data of EU residents. Article 32 requires organizations to audit data processing and access, including employees and third-party vendors. Non-compliance can result in significant fines.

The Sarbanes–Oxley Act (SOX) is a US law for public accounting organizations that mandates assessment and reporting on internal controls for financial reporting. SOX requires enforcement of access control procedures, including user access reviews for digital records. Organizations must comply with SOX during an annual audit by an independent auditor, and specialized SOX compliance software can help meet these requirements.

Types of User Access Reviews

The Periodic User Access Review

A periodic user access review is a key step to ensuring access rights compliance. This review helps manage information systems effectively and is a form of quality control. By regularly checking who has access to what, it is possible to make sure that the right people have the right level of access.

The process involves two main steps:

• Mapping access rights within a specific scope, and
• Linking each employee’s responsibilities to the access permissions they have for resources.

This review should be repeated regularly, with the frequency determined by the sensitivity of the access rights being reviewed. Read our best practices guide to performing periodic reviews in ERP systems.

The Continuous User Access Review

The continuous rights review serves a different purpose than the periodic access rights review, which focuses on compliance. Instead, the continuous rights review aims to minimize access rights risk. It operates by constantly monitoring changes within the organization, such as the arrival or departure of employees, changes in job responsibilities, newly granted permissions, security incidents, or unusual access, in order to detect potential security breaches.

Conducted on an ongoing basis, it doesn’t have a set time frame and focuses on all exceptional circumstances. This review is integrated into the daily operations of the organization and prioritizes the analysis of access rights risks.

Since these two review strategies serve different objectives, they should be viewed as complementary but distinct methods for achieving regulatory compliance, security requirements, and reducing access rights risk.

5 Best Practices for Expanding User Access Reviews Across Your Application Landscape

Watch this Pathlock webinar to learn how you can optimise your user access reviews across multiple departments in a diverse application landscape.

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How to Conduct User Access Reviews

While there are no set mandates on how an organization should conduct a review, establishing a process and following it methodically for each of your critical applications ensures consistent compliance across your application landscape. Below are standard steps you can serve as a guide:

Define the Access Management Policy

A comprehensive access management policy should include the following components:

• Asset Inventory: A comprehensive list of assets that users have access privileges to, including all enterprise applications, databases, systems, networks, and physical infrastructure.
• Asset Owners: Identification of the owner for each asset, such as an administrator, manager, IT team member, etc. The owners should provide details about the content of their assets.
• User Roles and Access Levels: Allocation of roles and responsibilities to users with detailed descriptions. For example, some roles may only require read-level access to a resource.
• Report Types and Frequency: Specification of the various types of audits and user access reviews. These reviews can occur on a set schedule or in response to specific triggers.

Conduct the Review

A typical user access review procedure should include the following steps:

• Establish clear policies and then examine the access to databases, applications, and other sensitive systems to identify who has access.
• Generate a report and send it to the owners of each asset for review. Owners should assess if any changes are necessary for access rights.
• If the systems are accessed by a large number of employees, it’s typical for reviewers to grant or deny access to entire groups or departments within the organization. In such cases, it’s common practice to notify the department manager about this decision for further comments or negotiations about access for their employees.
• Once the access rights have been decided, implement the changes by modifying permissions on the affected systems and verify with the asset owners that the updates have been made correctly.

Report and Iterate

After the reviewers have made their decisions on user access, the next step is to adjust the permissions on the impacted systems. This includes revoking any unnecessary access rights and updating the existing access rights as needed. At the conclusion of this process, it is recommended to create a new user access report and confirm with the asset owners that the changes have been implemented accurately.

With access rights aligned with the organization’s requirements, it’s important to evaluate the performance of your security and access policies. Issues such as decreased user productivity and security concerns will inevitably arise. Document these problems and communicate them with the asset owners to continuously improve the process of updating user access.

User Access Review Best Practices

To minimize the risk of security breaches and maintain an efficient and secure user access management process, it is advisable for organizations to regularly conduct user access reviews. If your organization doesn’t already have a system in place, these user access review best practices can help you establish an efficient process.

Keep Your Access Management Policy Updated

Having a policy in place is a crucial step, but it is equally important to regularly update it as your organization evolves. This helps to ensure that users within the organization have the appropriate level of access to the relevant data assets. Document any changes in protected data, user roles, and access control procedures.

If your organization does not have an access management policy, it is advisable to create one. The policy should include the following elements:

• A list of the data and resources that need to be protected
• A comprehensive list of all user roles, levels of access, and types of access
• Control measures, tools, and approaches used to secure access
• Administrative procedures and software used to enforce the policy
• Procedures for granting, reviewing, and revoking access rights

Creating a full access control policy can be made easier by searching for and adapting relevant access management policy templates specific to your region and industry.

Get All Key Stakeholders Involved

In most organizations, the IT team is in charge of distributing system access to users. However, it is recognized that they may not always be the most suitable individuals to determine the access rights for users. Managers, leaders, and supervisors have a better understanding of what specific access rights employees require.

It’s important to note that network and system administrators shouldn’t be expected to make these decisions without guidance. Ensure that the appropriate managers are responsible for reviewing user access permissions and assigning them based on each employee’s role within the organization.

Enforce Role-Based Access Controls (RBAC) And Least Privilege

The Role-Based Access Control (RBAC) model streamlines the user access review process by organizing users into roles rather than managing individual user accounts. With RBAC, each role is assigned a specific set of access privileges, making it easier to review and manage user access.

By grouping users with similar privileges into roles, you can quickly and efficiently manage their access privileges with just a few clicks, eliminating the need to manually configure each user account. This approach not only simplifies the user access review process but also helps ensure consistency in access control across your organization.

Implement the Principle of Least Privilege

The principle of least privilege dictates that users should only have access to the data they need when needed. This helps to minimize the time spent on user access review and ensures the highest level of security. Under the least privilege policy, new users are granted the minimum level of access rights or privileges.

For instance, administrators can assign a user to a specific group, provide them with a privileged user role, or grant permanent access or temporary access to resources. This approach ensures that users have the minimum level of privileges necessary to perform their duties.

Educate Staff About UARs

Involving employees in the user access review process can speed up the process and also help educate them on the importance of cybersecurity measures. The review can be made more efficient by sending out lists of access rights to both users and their managers and asking for their input. Managers, who have a better understanding of their subordinates’ responsibilities, can provide valuable insights that can streamline the user access review programs process.

Automate User Access Reviews with Pathlock

Pathlock’s Access Certification module streamlines the entire review process and enables reviewers to make informed decisions on access confirmation or revocation while providing a clear audit trail. The customizable, automated workflows eliminate the need for spreadsheets, scattered emails, and the tracking of absent-minded reviewers, greatly reducing the time, effort, and costs associated with running recertification campaigns. The support for cross-applications allows reviewers to have a complete view of access usage while enabling campaign managers to run multiple campaigns at once.

Cross-app Access Reviews: Security teams can perform multi-system access reviews simultaneously to get a full view of all user access across business applications like SAP, Salesforce, Oracle EBS, and more.

Campaign Segmentation: Campaigns can be run based on attributes like role, dept, geo, SoD risks, etc. This allows high-risk user groups to be reviewed more frequently than the low-risk user base.

One-click Approval/Revocation: Role owners and supervisors can grant/remove specific user access directly without IT involvement. The customizable auto-lock also decertifies inactive users automatically.

Detailed Usage Insights: The solution provides reviewers with usage insights to make informed decisions. They can see data at the account, role, and entitlement level, including frequency and last date of usage.

Easy-to-Integrate SaaS Solution: The module supports applications like SAP, Oracle, Microsoft Dynamics 365, Salesforce, and more. It can be deployed in on-prem or hosted applications within a day.

To learn more about Pathlock’s access certification solutions, get in touch with us for a demo.