The user access review template, column by column

The review record itself, header first, then eleven columns, then a worked row for the account that should not have been there.

A user access review template is one row per account in one named system, under a header that says where the account list came from. Each row carries the person, the access held, a decision of keep, reduce or remove, and the ticket that carried it out.

The whole record is below. Header, eleven columns, then a worked row. No form and no email.

The header that fixes the population

Six fields sit above the rows. They settle the question a reader asks before reading a single decision: which accounts were in front of the reviewer, and how anyone knows that was all of them.

Header fieldWhat it settles
System reviewedOne application or environment, named as your inventory names it
Review periodStart and end dates. Coverage is decided by date
Population sourceThe report that produced the list, the tool, the timestamp
Row countAccounts the export returned, so none fall out unnoticed
ReviewerThe person deciding, by name and role. Not a team
Completed and approvedWhen the last row was decided, and who accepted it

The eleven columns

One row per account. The third column is the one your sheet will not have: the defect that makes a filled cell useless.

ColumnWhat it is forWhat fails the row
Account identifierOne row, one identity, as the export writes itA display name. Two people called Chris Martin merge
Person and statusEmployee, contractor, terminated, or service accountA blank. Status decides which rule applies
Access heldThe role as the system names it, say AdministratorAccessA paraphrase like normal access. Nothing gets decided
PrivilegedYes or no, by the definition in your policyEvery row no. Then the definition is wrong
Granted on, granted byWhen the access was given, and who approvedAn empty cell. Unknown is a value; blank is not
Business justificationThe work this access exists to doNeeds access. A reason fitting everyone justifies no one
DecisionKeep, reduce or remove. One per rowA checkmark. It records attention, not a decision
ReasonWhy, for every reduce, remove and privileged keepBlank on a removal. The next reviewer inherits nothing
Action ticketThe ticket that carries out the decisionThe word done. A status references nothing
Completed onThe date the change landed in the systemThe day you closed the ticket, not the day access went
Verified byWho confirmed the change, and the record readThe reviewer name again, where policy wanted two people

A worked row

A contractor whose production access outlived the engagement, as the row would sit in the sheet.

ColumnValue
Headeraws-prod-payments, 2026-04-01 to 2026-06-30. IAM credential report exported 2026-07-08 09:14 UTC, 41 rows. Reviewer Priya Raman, VP Engineering
Account identifierdana.okafor@acme.io
Person and statusDana Okafor, contractor, terminated 2026-05-02
Access heldAdministratorAccess, via the sso-engineering group
PrivilegedYes
Granted on, granted by2025-11-14, approved by Priya Raman in TICKET-2291
Business justificationPayments migration, statement of work closed 2026-05-02
DecisionRemove
ReasonAccess survived offboarding by 67 days. Offboarding covered the identity provider, not the group
Action ticketSEC-412, opened 2026-07-08
Completed on2026-07-08, group membership removed 16:12 UTC
Verified byMarcus Lee, from the RemoveUserFromGroup event in the audit log
Leave the failing row in

Do not delete the account quietly and file the review as clean. Catching a 67 day gap and saying so is the control working. A year of reviews that found nothing describes a company nobody joined or left.

Where the account list comes from

A review of a list you typed proves you typed a list. The population has to come out of the system, at a stated moment, from a named report you can run again.

Keep the raw export beside the record and carry its row count across. If the export has 41 rows and the sheet has 38, the missing three are the review. The same rule runs through the evidence request list, which asks for whole populations.

The reviewer is not the person who granted the access

An administrator reviewing their own grants is making the same judgment twice. Nothing new gets tested. The control wants a second opinion from someone who knows what the job needs, not what the console allows.1

At five people the pool is small and the reviewer may be a founder. Fine, and testable, as long as the record names both people and the names differ. What a small team actually has to do takes that substitution through the rest of the controls that assume more staff than you have.

What reviewed has to mean in writing

A decision, a reason, a name and a date, per row. Blank means not reviewed. Where a privileged account is kept, the reason column answers why an ex-migration contractor still held it.

A clean quarter is a legitimate outcome and gets written the same way. State the population and say that all 41 accounts were kept.

Silence is not a decision.

Terminated users, service accounts, shared credentials

Three row types break the pattern. The person the row is about is not the person holding the account.

Terminated users
They should not be in the active export at all, and this review is what catches them when they are. Check it against your leaver list. A leaver who appears gets a row carrying the termination date, the removal date and the gap in days.
Service accounts
Each needs a named human owner, the system it serves, and the dates its credential was last rotated and last used. No owner means nobody to ask. No recent use makes it a removal candidate, and saying so tells the next reviewer it was considered.
Shared credentials
List everyone holding it and say whether the system can attribute an action to one of them. If it cannot, put that in the reason column. A shared login with named holders and a written blind spot is a smaller finding than one nobody counted.

The evidence the review leaves behind

Five artifacts, dated in this order. Rebuilt from memory afterwards they carry the date of the rebuild, and the dates carry the test.

  1. The source export, unedited, tool and timestamp visible.
  2. The completed record, every row decided, reviewer named, dated.
  3. One ticket per action, referenced by identifier from its row.
  4. A system record per change: the log line showing access went.
  5. A dated approval, signed after the last row was decided.

One habit protects all five. Do not re-save the record after the approval date. A sheet modified three months after the sign off invites a question the document cannot answer.

Which criteria this maps to

The logical access common criteria.1 CC6.1 covers the access controls protecting the system. CC6.2 covers registering and authorizing users before credentials are issued, and removing access when it is no longer appropriate. CC6.3 covers authorizing, modifying and removing access by role, with least privilege and segregation of duties considered.

Your engagement fixes the exact mapping in its control matrix. Cadence is your choice, and your approved policy becomes the standard you are tested against.2 The policy list covers how a promise inherited from a template turns into a deviation you never needed.

Where this fits with Polara G.R.C.

Polara G.R.C. takes this record as evidence against the access control criteria and indexes it into the package your independent partner auditor reviews. Scope is Security only, fixed rather than a setting. Type 1 is $4,000 one time, first examination and auditor engagement fee included. Type 2 is $600 per month on a 12-month term, and an examination is $5,000 once the 3-month observation window completes on an active subscription.

Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.

Questions

What is a user access review?
A periodic check of every account that can reach a named system. Someone other than the person who granted the access looks at each account, decides keep, reduce or remove, and records the reason, the ticket and the date. The removals it produces are part of the record rather than a separate task.
What columns does a user access review template need?
Eleven at minimum: account identifier, the person and their employment status, the access held, whether it is privileged, when it was granted and by whom, the business justification, the decision, the reason, the action ticket, the date the change landed, and who verified it in the system. Above the rows sits a header naming the system, the review period, the export the account list came from, its generation time and its row count.
Who should perform a user access review?
Someone other than the person who granted or holds the access. A reviewer needs to know what the job requires, not what the console allows, so a manager or business owner is a better reviewer than the administrator who provisioned the account. At a company of five that may be a founder. Either way the record names the person.
How often should user access reviews happen?
At whatever interval your own policy states, because that is the standard your examination tests you against. Quarterly and annual are both defensible. A policy promising quarterly reviews and a year that produced two of them creates a deviation an annual policy would never have produced.
What evidence does a user access review have to leave behind?
Five dated artifacts. The source export with its generation timestamp and row count, the completed record carrying every decision and reason, a ticket for each reduce and remove, a system record showing each change landed, and a dated sign off. A completed record with no export behind it is evidence of the record.

Sources

  1. TSP Section 100, Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy AICPA. The criteria themselves, including the common criteria every SOC 2 report covers. Checked 1 August 2026.
  2. Statements on Standards for Attestation Engagements AICPA. The attestation standards a SOC 2 examination is performed under. Checked 1 August 2026.

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Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms in our network; the audit opinion is theirs alone and is not regulated by Polara Labs. We generate custom policies, evidence checklists, and remediation guidance. You remain responsible for implementing controls and owning audit outcomes. Replace placeholders with your actual controls and have final documents reviewed by qualified professionals before your audit.

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