An identity provider (IdP) login log shows that an identity authenticated and when. It does not, by itself, show what that identity could access, whether a qualified person decided those permissions were still appropriate, or whether required changes were completed. Authentication logs support security monitoring; access-review records document an entitlement decision.
What a login log proves—and what it leaves unanswered
A sign-in record documents an authentication event. It can help establish that a particular identity signed in at a particular time, but it is not a certification of that identity’s permissions across the organization’s in-scope systems.
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An access review must address a different set of questions: What access did the identity have? Was it still appropriate for the person’s current responsibilities? Who made that determination, and when? If access needed to change, was the change completed?
Login events may be useful supporting evidence for monitoring, but a collection of them can still leave the entitlement decision and its approval trail undocumented. Whether particular evidence is sufficient depends on the organization’s control design and the evidence it retains; a login log alone should not be treated as proof that an access review occurred.
What an access review should record
A useful review lets someone reconstruct the population considered, the decision made, and any resulting action. CSA’s IAM-08 shared implementation guidance says to track review outcomes and evidence with timestamps and approver IDs.
- Scope: The identities, systems, roles, and access rights included in the review.
- Reviewer and decision: The identity of the reviewer or approver, the decision for each entitlement, and the time the review was completed.
- Rationale: Why access was retained when it is elevated, sensitive, or otherwise needs explanation.
- Disposition: Whether access was retained, modified, or removed.
- Remediation evidence: Follow-up changes tracked through completion, with records that can be retained for audit purposes.
The reviewer should be someone able to judge whether the access fits the identity’s current responsibilities. The review should consider least privilege and segregation of duties, not merely whether the account has been used recently.
Include privileged and programmatic access
Reviews limited to ordinary employee accounts can miss important access paths. CSA’s cloud service provider guidance expressly includes manual roles and programmatic access, such as service accounts, in its audit-review guidance. Define the population to include the identities and permissions relevant to the systems in scope, including privileged roles and non-human identities where applicable.
Prioritize high-risk privileges and access to sensitive data when scheduling reviews. A dormant account is not automatically safe, and recent sign-in activity does not establish that its permissions remain appropriate.
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Set a review cadence without misattributing the requirement
The AICPA identifies the Trust Services Criteria as the framework used to evaluate and report on controls relevant to security, availability, processing integrity, confidentiality, or privacy. The AICPA resource library lists the 2017 Trust Services Criteria with revised points of focus from 2022. The specific annual-minimum language below comes from CSA’s IAM-08 control specification; it should not be described as a universal SOC 2 or AICPA cadence.
CSA IAM-08 says to review and revalidate identity access for least privilege and separation of duties at a frequency commensurate with organizational risk tolerance and at least annually, or upon significant changes. Its CSP implementation guidance gives quarterly reviews as an example, not a universal requirement. The guidance also describes scheduling based on risk and data or system sensitivity. Organizations should set a schedule that fits their risk and control design, and review access after significant changes where appropriate.
A practical access-review workflow
- Define the review population. List the in-scope systems, identities, roles, privileged access, and programmatic identities to be reviewed.
- Assign knowledgeable reviewers. Route each review to a resource owner or another person who can assess access against current responsibilities.
- Evaluate each entitlement. Ask whether access remains necessary and appropriate, whether least privilege is maintained, and whether segregation-of-duties concerns exist. Record the rationale for retaining elevated or sensitive access.
- Capture the decision and context. Preserve the entitlement reviewed, reviewer or approver identity, completion time, decision, and disposition.
- Complete and document remediation. Track modifications and removals through completion, then retain the resulting evidence.
- Schedule the next cycle. Set frequency according to risk and applicable control commitments, and account for significant changes.
How to assess an automated review process
Automation can coordinate review work, but a tool is useful only if its coverage and evidence fit the control being performed. Evaluate whether the process:
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- Routes decisions to appropriate owners and gives reviewers enough context to assess need.
- Identifies stale, orphaned, or excessive entitlements for investigation.
- Records review decisions, timestamps, and approver identities.
- Tracks approved changes through completion and reconciles decisions to actual permissions.
- Retains evidence in a usable form for audit purposes.
These are operational criteria derived from the review tasks in CSA guidance, not a ranking or endorsement of any product.
What the standards sources establish
The AICPA describes the Trust Services Criteria as a means to evaluate and report on controls relevant to the applicable trust services categories. CSA’s IAM-08 is a separate control specification in its AICMv1.1 implementation guidance for cloud service providers. Keeping those sources distinct matters: CSA’s stated cadence and implementation examples should not be presented as exact AICPA or universal SOC 2 requirements.
Sources: AICPA & CIMA SOC Suite of Services; 2017 Trust Services Criteria with Revised Points of Focus – 2022; Cloud Security Alliance AICMv1.1 Implementation Guidelines for Cloud Service Providers, IAM-08.
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