HIPAA Compliance Checklist for 2025
How confident are you that everyone in your company has exactly the access they need, and nothing more?
In 2024, a study by IBM found that over 25% of data breaches were caused by insider threats, many of them due to excessive or outdated access. That’s not just carelessness; it’s a signal that access controls aren’t keeping up with today’s dynamic workforce.

In SaaS-heavy environments, employees constantly join, change roles, or leave. And with every transition comes the risk of outdated permissions quietly stacking up, exposing sensitive data, and making you vulnerable to compliance violations.
That’s exactly where user access reviews come in.
In this guide, you’ll learn what a user access review is, why it’s a security and compliance must-have in 2025, how to conduct one, and the best practices and tools to make it easier.
TL;DR
- Manual user access reviews are inefficient and error-prone, often leading to security and compliance risks.
- Automating access reviews saves time, reduces manual mistakes, and helps organizations keep up with growing SaaS stacks.
- Tools like CloudEagle, ConductorOne, and Saviynt connect directly to your apps, centralizing user access data for easy management.
- Automated platforms streamline review workflows: Assign reviewers, send reminders, and update permissions, all in one place.
- Audit-ready reporting and policy enforcement make it easy to stay compliant and eliminate privilege creep across your organization.
What is a User Access Review?
A user access review (UAR) is a structured process organizations use to periodically review and validate that users have the correct access to systems, applications, and data, based on their current roles and responsibilities.
In simpler terms: it’s how you make sure the right people have the right access at the right time, and no one has access they shouldn’t.

User access reviews are essential for reducing security risks, preventing insider threats, and maintaining regulatory compliance. They're not just for large enterprises; any business handling sensitive data or scaling its software usage needs to perform them regularly.
In modern SaaS environments, these reviews serve as a critical identity governance process to prevent privilege creep and unauthorized data exposure by ensuring users maintain only the minimum access necessary to perform their duties.
User access reviews support fundamental security principles, including:
- Least privilege access: Users receive only the essential permissions needed for their role
- Role-based access control (RBAC): Access granted based on job functions rather than individual requests
- Joiner-mover-leaver (JML) processes: Validating that access changes properly reflect employee lifecycle events—new hires receiving appropriate permissions, role changes triggering access modifications, and departing employees having access promptly revoked
Systems commonly reviewed:
- SaaS applications (Salesforce, Microsoft 365, Slack)
- Single sign-on platforms and identity providers (Okta, Azure AD)
- Human resources information systems (HRIS)
- Finance applications
Types of User Access Reviews
There are several ways to conduct a review, depending on your organization’s needs:
- Periodic Reviews: These are scheduled at regular intervals (e.g., quarterly or annually) to assess all users.
- Event-Based Reviews: Triggered by changes like role transitions, terminations, or system upgrades.
- High-Risk Access Reviews: Focused on users with privileged or admin-level access.
Why User Access Reviews Matter More Than Ever
In today's remote and hybrid work environments, employees access an ever-growing number of SaaS tools and platforms. Without regular user access reviews, outdated permissions accumulate, creating significant security and compliance risks for your organization.
User access reviews are periodic audits that verify employees have appropriate permissions aligned with their current job roles. These reviews are critical for:
- Security risk mitigation: Identifying and removing unnecessary access prevents unauthorized data exposure and potential breaches
- Compliance readiness: Meeting regulatory requirements like SOC2, GDPR, and ISO 27001 through documented access controls
- Internal threat reduction: Eliminating excessive privileges that could be exploited by former employees or compromised accounts
- Cost optimization: Reclaiming unused licenses and downgrading over-provisioned access to reduce SaaS spend
Organizations that neglect access reviews face manual, time-consuming audits when compliance deadlines approach. Proactive access management keeps your security posture strong and your organization audit-ready year-round.
What Are the Risks of Not Performing User Access Reviews?
Skipping regular user access reviews exposes your organization to serious risks:
- Security breaches: Former employees retaining access to critical systems create serious vulnerabilities.
- Compliance violations: Frameworks like SOX and HIPAA mandate strict access governance—failing reviews can result in fines.
- Privilege creep: Users accumulate excessive permissions over time without visibility into who has access to what.
- Audit failures: Incomplete documentation and poor access records will delay or derail audit processes.
What Effective User Access Reviews Should Look Like in Practice
An effective user access review process transforms from a reactive compliance exercise into a strategic security enabler. In mature organizations, access reviews operate through automated platforms that deliver:
- Unified data consolidation: User data from identity providers, HRIS systems, and individual applications flows into a single dashboard
- Risk-based prioritization: Program owners define scoping that focuses on high-privilege users, sensitive applications, and dormant accounts
- Clear ownership structure: Specific reviewers are assigned to relevant user populations with defined responsibilities
- Time-bound campaigns: Built-in escalation paths ensure reviews complete within defined windows
- Contextual decision-making: Intuitive interfaces provide reviewers with user roles, last activity, and business justification for access
Modern vs. Traditional Access Reviews
This streamlined approach stands in stark contrast to traditional ad hoc reviews that rely on:
- Scattered spreadsheets and manual data exports
- Email-based approvals across disconnected systems
- Review cycles take months to complete
- "Rubber-stamp" approvals due to reviewer fatigue
Modern platforms reduce review cycles from months to days through automated workflows, risk scoring, and one-click remediation. Automated revocation capabilities immediately implement reviewer decisions, while comprehensive audit trails capture every action with timestamps and justifications, creating defensible evidence for compliance auditors.
Continuous Governance Operating Model
The target operating model delivers continuous governance rather than periodic fire drills, enabling organizations to maintain least-privilege access while reducing the administrative burden on both IT teams and business reviewers through intelligent automation and contextual decision-making tools.
Common Challenges in User Access Reviews
Conducting effective user access reviews presents significant obstacles for IT and security teams:
- Fragmented data across systems: Teams must manually export data from SSO platforms, HRIS databases, and individual SaaS applications, then piece together approval chains across scattered channels like email, Slack, and ticketing systems.
- Manual verification burden: IT must log into dozens of applications individually to gather comprehensive access information and verify user permissions.
- Review fatigue and rubber-stamping: Managers frequently approve access requests without thorough evaluation, especially when reviews are infrequent (often quarterly at best).
- Compliance documentation gaps: Evidence must be manually gathered and attached from various systems, making it difficult to maintain audit-ready documentation.
- Shadow IT blind spots: Unapproved software usage escapes detection during traditional review processes.
- Scale and timing issues: Infrequent reviews mean risky users and ex-employees may retain inappropriate access for extended periods between audits.
- Unsustainable manual processes: Modern SaaS environments spanning hundreds of applications and thousands of users make manual review approaches a compliance bottleneck that delays security improvements.
Who Needs to Conduct User Access Reviews?
Key stakeholders in the review process:
- IT teams: Manage technical workflows and system integrations
- Security teams: Enforce policies and monitor compliance
- Application owners: Understand specific tool requirements
- Department managers: Validate business need for access
- Auditors: Review documentation for regulatory compliance
Which Frameworks Require User Access Reviews for Compliance?
User access reviews are mandatory compliance requirements across multiple regulatory frameworks and industry standards. Organizations must regularly verify and certify that users have appropriate access levels to systems and data.

Key frameworks mandating user access reviews include:
- SOC 2: Requires periodic access reviews to demonstrate effective access controls and user provisioning processes. Organizations must document review procedures and maintain audit trails of access certifications.
- ISO 27001: Mandates regular reviews of user access rights as part of access control policies. Access reviews must be conducted at defined intervals and whenever there are changes to employment status.
- GDPR: Requires organizations to ensure only authorized personnel can access personal data. Regular access audits help demonstrate compliance with data minimization and security principles.
- HIPAA: Healthcare organizations must implement procedures for reviewing and modifying user access to electronic protected health information (ePHI). Access reviews are essential for the Security Rule's access management requirements.
- PCI DSS: Requires quarterly reviews of user accounts and access privileges for systems handling cardholder data. Organizations must remove unnecessary accounts and restrict access based on job responsibilities.
- NIST Cybersecurity Framework: Recommends periodic reviews of access authorizations to ensure least privilege principles are maintained across information systems.
Regular access reviews not only ensure regulatory compliance but also reduce security risks by identifying unauthorized access, orphaned accounts, and excessive privileges that could lead to data breaches.
How to Conduct a User Access Review (Step-by-Step)
Conducting a user access review isn't just a compliance checkbox; it’s a security-critical process. Here’s how to do it right, step by step:
Define the Scope
Before jumping in, clearly outline what and who you're reviewing.
- Identify all systems, platforms, and apps involved, starting with high-risk tools like HR software, cloud storage, DevOps platforms, or finance systems.
- Clarify which departments, teams, or business units will be covered.
- Define the user types, employees, contractors, third parties, or service accounts.
Gather User Access Data
Pull access information for all in-scope systems.
- Use your identity provider (e.g., Okta, Azure AD) or user access review software to extract current permissions and access logs.
- Ensure data includes roles, permissions, group memberships, and login activity.
- Capture metadata like when access was granted and by whom.
Identify Access Owners
Determine who is responsible for reviewing each user's access.
- Usually, this will be department heads, team managers, or application owners who understand role responsibilities and access requirements.
- Access owners must be clearly accountable and given a deadline to complete their part of the review.
- You can use role-based reminders or automated notifications to keep them on track.
Review Access Rights
This is the core of the process: evaluating whether current access matches current responsibilities.
- Each reviewer should check if the user’s access is:
- Still needed for their role
- Overly permissive or excessive
- In conflict with SoD (Segregation of Duties) policies
- Look out for red flags:
- Inactive users with access
- Admin privileges for junior staff
- Cross-department access that isn’t justified
Document the Review Process
Compliance frameworks (like SOX, HIPAA, ISO 27001) require audit-ready documentation.
- Record:
- Who reviewed what and when
- The access status (approved, modified, revoked)
- Justifications for keeping unusual access (if any)
- Use audit logs generated by your access review tool or create a structured review report.
Revoke Unnecessary Access
Act on your review findings promptly.
- Remove access for users who no longer need it, either manually or by using automation rules.
- For high-risk apps, apply immediate revocation.
- Update role-based access groups if systemic changes are needed (e.g., department-wide cleanups).
Set a Review Cadence
User access reviews are not one-time events; they should be ongoing and repeatable.
- Best practice:
- Quarterly reviews for sensitive systems (e.g., finance, HR, customer data)
- Bi-annual or annual reviews for low-risk tools
- Build this into your broader IT compliance calendar and notify reviewers ahead of time.
- Automate reminders, reviewer assignments, and approvals with user access review tools.
12 Steps to Build an Effective User Access Review Program
- Define program objectives and scope - Establish clear compliance requirements (SOX, HIPAA, ISO 27001), security goals, and which systems and user populations will be included in your review program.
- Assign executive ownership and accountability - Designate a program owner at the director or VP level with clear authority to enforce policies and drive cross-functional collaboration.
- Inventory all systems and data classifications - Catalog every application, database, and system requiring access reviews, documenting data sensitivity levels and business criticality.
- Perform risk-based system classification - Prioritize systems by risk level to determine appropriate review frequencies and depth of scrutiny required for each application type.
- Define access control policies - Establish role-based access control (RBAC) frameworks, segregation of duties (SoD) rules, and clear principles for least privilege access.
- Select and implement access review tooling - Deploy platforms like CloudEagle.ai to automate data collection, reviewer assignments, and workflow orchestration across your SaaS and enterprise applications.
- Design review types and cadences - Create standardized processes for periodic, event-driven, and high-risk access reviews with appropriate frequencies based on system classification.
- Integrate with HR and identity systems - Connect your review platform to HRIS and identity providers to automate user lifecycle data and streamline reviewer assignments.
- Pilot and refine workflows - Test review processes with a subset of applications, gather feedback from reviewers, and optimize approval chains and escalation procedures.
- Train reviewers and stakeholders - Educate managers, application owners, and IT staff on their responsibilities, review criteria, and how to use the review platform effectively.
- Establish program KPIs and metrics - Define success measures including review completion rates, time-to-remediation, compliance scores, and access reduction percentages.
- Implement continuous improvement processes - Schedule regular program assessments, automate reporting, and establish feedback loops to enhance efficiency and effectiveness over time.
Must-Have User Access Review Checklist in 2026
A user access review checklist is a practical tool that helps organizations verify users have only the access they need to systems and data. The checklist typically involves setting the review scope, identifying all users, checking their permissions, and keeping a record of the review process.
Here’s what a strong checklist should include:
- Identify target systems and applications
- Pull the latest user access data
- Confirm active employees vs. terminations
- Match access with role-based responsibilities
- Involve department heads for verification
- Flag excessive or admin-level permissions
- Document approvals and removals
- Revoke unnecessary access
- Archive review logs for audits
- Schedule the next review cycle
This user access review checklist standardizes your process, reduces human error, and keeps your organization audit-ready.
How Often Should User Access Reviews Be Performed?
There’s no one-size-fits-all frequency, but here are industry benchmarks to guide you:
- Quarterly: Ideal for fast-growing or regulated companies.
- Bi-Annually: Suitable for mid-sized teams with moderate change rates.
- Annually: Minimum standard for low-risk or smaller organizations.
Events like employee offboarding, role changes, or new vendor integrations should also trigger ad-hoc reviews.
When you automate user access reviews, increasing frequency becomes much easier and more effective.
How to Automate User Access Reviews
If you’re doing manual reviews with spreadsheets and email approvals, you're probably spending more time than you need and introducing risk.
That’s where automating user access reviews becomes a game-changer.
Challenges of Manual User Access Reviews
- Tedious data collection from multiple platforms
- Inconsistent documentation
- Delayed access revocations
- Difficulties tracking review completion
Automation platforms solve this by syncing with your SaaS tools, consolidating access data, assigning reviewers, and documenting everything automatically.
How to Automate User Access Reviews
- Connect an automation platform (like CloudEagle.ai, ConductorOne, or Saviynt) to your SaaS and cloud apps via integrations or APIs.
- The platform automatically pulls user and access data into a unified dashboard.
- Set up review schedules and assign reviewers within the tool.
- Reviewers receive automated notifications and can approve or revoke access directly in the platform.
- The system documents all actions, updates permissions, and maintains audit trails automatically.
Benefits of Automation:
- Saves time and reduces manual errors
- Ensures timely reviews and compliance
- Makes it easy to scale reviews across dozens of apps
- Provides detailed audit logs
Tools like CloudEagle.ai, ConductorOne, and Saviynt offer automation features that remove the burden from IT and enable faster, smarter reviews.
Top User Access Review Tools in 2025
As user access reviews grow in complexity, the need for purpose-built user access review software has become critical. Manual spreadsheets and email reminders just don’t cut it anymore.
Here are five top-rated tools leading the access review space in 2025:
1. CloudEagle.ai
- Strengths: Seamless SaaS integration, automated procurement, custom workflow automation, and detailed audit logs.
- Ideal For: Mid-to-large enterprises looking to combine user access reviews with SaaS cost optimization.
- Bonus: Centralizes vendor data, tracks app ownership, and ensures complete SaaS lifecycle governance.
- Why It Stands Out: CloudEagle.ai doesn’t just perform access reviews; it ties them into contract management, budgeting, and compliance.
2. ConductorOne
- Strengths: Built specifically for identity security with deep integrations into Okta, Google Workspace, and GitHub.
- Ideal For: Security-first organizations or DevSecOps teams needing strict control over IAM processes.
- Why It Stands Out: Offers fine-grained access policies, approval chains, and access request workflows, great for regulated industries
3. Saviynt
- Strengths: Enterprise-scale identity governance with broad cloud and on-prem integration capabilities.
- Ideal For: Large enterprises with hybrid environments, legacy systems, or complex internal hierarchies.
- Why It Stands Out: Strong compliance alignment (SOX, HIPAA), access analytics, and zero trust support.
4. Zluri
- Strengths: SaaS Management Platform (SMP) with built-in user access review automation and cost optimization.
- Ideal For: IT and procurement teams managing hundreds of SaaS apps.
- Why It Stands Out: Combines access reviews, license tracking, and usage analytics in a single platform, great for cleaning up shadow IT.
5. SailPoint
- Strengths: Industry veteran in identity governance, offering robust lifecycle management and AI-driven recommendations.
- Ideal For: Heavily regulated sectors like finance and healthcare.
- Why It Stands Out: Advanced role mining and machine learning-based risk scoring set it apart for complex environments.
What to Look For in User Access Review Tools
Modern user access review software should deliver comprehensive functionality across several critical areas. Here are the essential capabilities to evaluate:
- Native SaaS & Identity Integrations: Connects directly with apps like Salesforce, GitHub, Google Meet, and Microsoft 365, plus identity providers (Okta, Azure AD) and HRIS systems to automatically pull real-time access data without manual exports.
- Rich Permissions & Role Visibility: Displays not just basic access but granular permissions, group memberships, last login activity, role hierarchies, and supports custom role definitions so reviewers can verify permissions based on job functions.
- Comprehensive Audit Trails & Evidence Capture: Captures every reviewer's action, who approved, revoked, or escalated, and stores it in a searchable log with automated documentation of all review decisions for audit defense.
- Configurable Review Campaigns: Supports customizable schedules, automated reviewer assignments, built-in escalation paths when reviews aren't completed on time, and automated reminders to managers and stakeholders.
- Risk Scoring & Prioritization: Automatically flags high-risk users, inactive accounts, ex-employees, and excessive privileges for focused review, enabling reviewers to prioritize based on security impact.
- One-Click Remediation Workflows: Allows instant permission changes and automated deprovisioning from the same dashboard, no need to jump between admin consoles.
- Continuous Monitoring: Supports both periodic quarterly/annual reviews and real-time access changes for immediate risk detection.
- Scalability & Performance: Works across large enterprises with complex org structures and multiple access tiers.
- Compliance Templates: Pre-built workflows for SOX, ISO 27001, HIPAA, GDPR, and PCI DSS streamline your setup and reviews with pre-built reports for auditors.
Automated Access Reviews via CloudEagle.ai
Automated access reviews replace manual, spreadsheet-driven processes by continuously synchronizing data from SaaS applications, identity providers, and HRIS systems.
These platforms feature configurable review campaigns with built-in workflows for assigning reviewers, sending reminders, and escalating overdue tasks.
Key capabilities include:
- Continuous data sync and risk-based prioritization that flags high-privilege users and ex-employees
- One-click revocation and automatic evidence capture for compliance
- Flexible review cadences—annual comprehensive audits, quarterly or monthly reviews for high-risk applications, and event-driven reviews triggered by organizational changes
- Intelligent risk scoring that focuses reviewers on critical access while automatically documenting decisions
This enables organizations to complete user access reviews quickly while meeting SOC2, ISO 27001, and other regulatory requirements.
User Access Review Best Practices to Follow
To build a sustainable and secure review program, follow these best practices:
- Establish clear ownership for every app and data set
- Standardize your review cadence based on risk level
- Document every step to maintain compliance readiness
- Continuously improve the process based on past audits
- Use automation tools to reduce errors and save time
- Align with role-based access control (RBAC) principles
- Educate stakeholders so they understand the ‘why’ behind reviews
By embedding these practices into your IT governance, you'll build a resilient, scalable access review process.
Integrate Access Reviews into the Employee Lifecycle
Integrating user access reviews into employee lifecycle management transforms access governance from a reactive, periodic process into a proactive, event-driven security control.
Rather than waiting for quarterly reviews, organizations should embed access validation directly into joiner-mover-leaver workflows, triggering targeted reviews during key lifecycle events.
This lifecycle-integrated approach delivers several critical benefits:
- Real-time alignment: Permissions automatically sync with current job responsibilities as employees transition between roles
- Reduced security exposure: Stale permissions from previous roles are identified and removed immediately during role changes
- Prevention of privilege creep: Each lifecycle event triggers a fresh evaluation of access needs, preventing unnecessary permission accumulation
- Cost optimization: Automated license reclamation during offboarding eliminates wasted spend on departed employees
- Continuous compliance: Event-driven reviews create an always-audit-ready posture without the burden of constant manual checks
Trigger user access reviews automatically at critical lifecycle milestones: onboarding, role changes, transfers, and offboarding. Integrating HRIS and identity provider data with review workflows ensures permissions remain appropriate throughout employment.
Review and Remediate Access After Each Campaign
After reviewers complete a user access review campaign, immediate action is critical. Teams must validate review decisions and prioritize high-risk findings including:
- Excessive privileges and elevated permissions
- Dormant or inactive accounts
- Segregation of duties violations
- Ex-employees with retained access
Automated flagging systems can streamline the deprovisioning process by identifying high-risk users and former employees, enabling IT to promptly revoke or downgrade unnecessary access.
Coordinate with application owners and HR to ensure proper follow-up actions, particularly for role changes or departures requiring additional system updates beyond standard access removal.
Verification that technical changes were actually applied across all systems—not just identity providers—is essential.
Modern SaaS management platforms can orchestrate remediation workflows from user assignment through deprovisioning, automatically generating audit evidence and compliance reports throughout the process.
Finally, update RBAC groups and access policies based on review findings to prevent recurring issues. This ensures the next review cycle addresses systemic access problems rather than repeating the same manual corrections.
Final Takeaway
Taking back control of user access is no longer a luxury; it’s a necessity for security and compliance. Manual reviews can’t keep up with the pace of today’s growing SaaS stacks and evolving regulatory demands.
Automating access reviews ensures that only the right people have the right permissions at the right time.
CloudEagle.ai streamlines this entire process, offering automated reviews, centralized visibility, and audit-ready reporting from a single platform. Its seamless integrations and policy-driven controls help organizations eliminate privilege creep and reduce SaaS risk effortlessly.
Book a free demo with CloudEagle.ai today and discover how easy and effective access governance can be.
Frequently Asked Questions
1. What is the user access review process?
The user access review process involves regularly evaluating and validating user access rights to ensure individuals have only the permissions needed for their roles, enhancing security and compliance.
2. Who should be performing a user access review?
User access reviews should be performed by IT administrators, security teams, and department managers to ensure appropriate access levels and maintain compliance across systems and applications.
3. How to conduct a user access review?
To conduct a user access review, follow a user access review checklist: define the scope, list users and access, verify permissions, adjust as needed, and document the review process.
4. How do you automate an access review?
To automate user access reviews, use software that integrates with your systems, consolidates access data, assigns reviewers, sends reminders, and automatically documents all actions for compliance.
5. What is sod in user access review?
In user access review software, SoD (Segregation of Duties) ensures no single user has conflicting responsibilities that could lead to fraud or errors, enhancing compliance and internal controls.





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