Independent thinking. Informed defence.

CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

Access Review Scope & System Inventory

Establishes which systems are in scope, who owns each, and how entitlement data is extracted — the step whose absence derails most first campaigns.

Available soon

Format
Excel
Size
86 KB
Length
10 sheets
Version
1.0
Updated

What's inside

  • Instructions
  • Inventory
  • Extract Readiness
  • Summary
  • Lists
  • Definitions
  • Framework References

Preview

The workbook's sheets as you will receive them, with its example rows and the values its formulas calculate. Highlighted [[text]] is for you to replace; rows marked EXAMPLE are for you to delete. Wide sheets scroll sideways. The cover, document control and changelog sheets are in the file.

Instructions

How to use this workbook

StepWhat to do
1Set the As-at date on the Summary sheet. The EXAMPLE uses 2026-09-30; replace it with today's date, or type =TODAY() to keep it current. Review status and days past due are measured against it.
2Add one row per system that holds or gives access to information you must protect (AR-01): every in-scope system must have a named system owner and a documented way to extract who has access. Give each a System ID (SYS-01, SYS-02 …) that never changes, and name the system owner: [[the manager accountable for the system]]. Start with the systems behind your critical services and every system with administrator access; add the rest as you find them.
3Choose each system's Review scope from the list. Review every calculates from it (privileged and administrator access, all systems: every 3 months; systems supporting a critical service: every 6 months; all other in-scope systems: every 12 months; Access must be reviewed at least as often as its scope requires (FREQUENCY), AR-02). A system with both administrator and ordinary access needs two rows, or one row reviewed at the shorter interval: administrator access is reviewed every 3 months on every system.
4Record the kinds of account on the system besides personal accounts, using the account types reviewers see in the extract: privileged (administrator), generic or shared, service (used by software, not a person), and third-party (a supplier's staff). Privileged, generic and service accounts must each have a named owner and must be reviewed by the system owner and information security. (AR-06)
5Describe how the list of who has access is extracted: the method, who runs it, the format, and whether it gives each field a reviewer needs (AR-03): name, role, permissions and last sign-in. If a field is missing, find where it comes from (the directory usually has last sign-in) before the campaign, not during it.
6Test every extract before the campaign's extract date on the Extract Readiness sheet: count the entries, reconcile them with the count the system itself shows, and answer the checks. Enter the test date and result (OK or Issue) here. A system whose extract is not Ready is not ready for review.
7After each campaign, enter the Last review date (the campaign's close date) and the campaign ID. Next review due and Review status calculate: In date; Due soon (due within 30 calendar days, the time a campaign takes to run); Overdue; Never reviewed. Plan the next campaign from the earliest due date on the Summary sheet.
8Link each system to the other registers: the supplier that runs or supports it (P06 Supplier Security Risk Register, SUP-nnn) and any risk it carries (P05 Information Security Risk Register, R-nn). Clear every Record check that does not say OK.
9Delete the EXAMPLE rows on the Inventory and Extract Readiness sheets before the inventory is approved. Do not type over the white calculated columns.

Legend

Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.

EXAMPLERows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval.

EXAMPLE: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders. Its five in-scope systems were all last reviewed in campaign UAR-2026-Q3 (extract 2026-09-01, closed 2026-09-29), so all five are In date as at 2026-09-30: ARM-01 is 5 of 5. The ERP (SYS-01) is hosted by the P06 ERP provider, SUP-004, whose support desk runs the extract; the directory administrator groups (SYS-03) carry P05 risk R-07, administrator misuse of privileged access.

Tailoring — small organisation: start with fewer rows, not fewer columns. The directory administrator groups, the finance system and the system your customers use are usually enough for a first campaign; add the others at the next. An extract that is a screenshot of a user list is acceptable if it is dated and shows every field.

Tailoring — regulated entity: NIS2 Art 21(2)(i) expects access control policies and asset management; this inventory is the asset list for access review. DORA Art 9(4)(c) and Delegated Regulation (EU) 2024/1774 Art 21(e) require access rights to be reviewed at least every six months for ICT systems supporting critical or important functions and at least yearly for the others; Art 21(c) limits generic and shared accounts and requires users to be identifiable. Mark those systems with the second scope. PCI DSS 7.2.4 expects user accounts and their privileges, including third-party accounts, to be reviewed at least every six months; 7.2.5.1 expects application and system accounts to be reviewed at a frequency set by a targeted risk analysis; 8.2.6 expects accounts inactive for 90 days to be removed or disabled. Give each system in the cardholder data environment the second scope and record its service accounts.

Tailoring — IT run by a service provider: the provider usually runs the extracts. Name it in Extract run by, agree the lead time in working days on the Extract Readiness sheet, and make the extract a contract deliverable. The system owner and the decisions stay with you. Link the system to the provider's row in the P06 Supplier Security Risk Register.

Scopes and their frequencies are on the Lists sheet, from the Access Review Methodology. If your methodology sets shorter intervals, change them there and nowhere else. A system you decide not to review is a P02 exception, recorded in the Security Exception Register.

Inventory

One row per in-scope system (AR-01). Yellow columns are inputs; white columns calculate. Every colour sits beside a word.

ExampleSystem IDSystemSystem ownerBusiness service supportedReview scopeReview every (months)Privileged accountsGeneric or shared accountsService accountsThird-party accountsEach privileged, generic or service account has a named owner (AR-06)Extract methodExtract run byExtract formatGives nameGives roleGives permissionsGives last sign-inExtract tested onExtract test resultLast reviewLast campaignNext review dueReview statusDays past dueLinked supplier (P06)Linked risk (P05)Record checkNotes
EXAMPLESYS-01ERP (hosted; P06 SUP-004)Chief Financial OfficerFinance and payroll; Warehouse dispatchSystems supporting a critical service (or a critical or important function, DORA; or cardholder data, PCI DSS)6YesNoYesYesYesSupplier-run user report, requested by ticketThe provider's support desk (P06 SUP-004)CSV fileYesYesYesYes1 Sep 2026OK29 Sep 2026UAR-2026-Q329 Mar 2027In dateSUP-004OK
EXAMPLESYS-02Warehouse management systemHead of LogisticsWarehouse dispatchSystems supporting a critical service (or a critical or important function, DORA; or cardholder data, PCI DSS)6YesYesNoYesYesAdmin console exportIT operationsSpreadsheet exportYesYesYesYes1 Sep 2026OK29 Sep 2026UAR-2026-Q329 Mar 2027In dateSUP-010OK
EXAMPLESYS-03Directory administrator groupsHead of ITAll services (directory)Privileged and administrator access, all systems3YesNoYesYesYesGroup membership exportIT operationsCSV fileYesYesYesYes1 Sep 2026OK29 Sep 2026UAR-2026-Q329 Dec 2026In dateSUP-001; SUP-006R-07OK
EXAMPLESYS-04Online ordering admin consoleChief Operating OfficerOnline orderingPrivileged and administrator access, all systems3YesNoNoNoYesAdmin console exportOnline ordering teamCSV fileYesYesYesYes1 Sep 2026OK29 Sep 2026UAR-2026-Q329 Dec 2026In dateOK
EXAMPLESYS-05Shared finance driveChief Financial OfficerFinance and payrollAll other in-scope systems12NoNoNoNoN/APermissions reportIT operationsSpreadsheet exportYesYesYesYes1 Sep 2026OK29 Sep 2026UAR-2026-Q329 Sep 2027In dateOK

Extract Readiness

Can we get a complete list of who has access, per system? Test each extract before the campaign's extract date: the step whose absence derails most first campaigns.

ExampleSystem IDSystemExtract methodRun byLead time (working days)Entries in the extractControl count shown by the systemCounts reconcileFields reviewers need (AR-03)Every account includedThird-party accounts includedAccounts can be matched to peoplePermissions readable by a reviewerDated and kept unchangedExtract tested onReadinessWhat was done to make it usable
EXAMPLESYS-01ERP (hosted; P06 SUP-004)Supplier-run user report, requested by ticketThe provider's support desk (P06 SUP-004)5164164Yes4 of 4YesYesYesYesYes1 Sep 2026ReadyRequested from the provider by ticket 5 working days before the extract date. The report gives role codes: the finance team's role catalogue translates them for reviewers.
EXAMPLESYS-02Warehouse management systemAdmin console exportIT operations1212212Yes4 of 4YesYesYesYesYes1 Sep 2026ReadyThe admin console export includes the handheld scanner accounts (generic); each has a named owner, the shift manager.
EXAMPLESYS-03Directory administrator groupsGroup membership exportIT operations11414Yes4 of 4YesYesYesYesYes1 Sep 2026ReadyMembership of every administrator group, with nested groups expanded to people; the service accounts are listed with their owners.
EXAMPLESYS-04Online ordering admin consoleAdmin console exportOnline ordering team199Yes4 of 4YesN/AYesYesYes1 Sep 2026ReadyConsole accounts are local, not in the directory: they are matched to people by email address. This is how the orphan account was found.
EXAMPLESYS-05Shared finance drivePermissions reportIT operations19696Yes4 of 4YesN/AYesYesYes1 Sep 2026ReadyThe permissions report lists groups: they are expanded to people with the directory's group export, and last sign-in is taken from the directory.

Summary

Inventory summary

Every figure is calculated from the Inventory and Extract Readiness sheets as at the date below. Use them to plan the next campaign and for the campaign report (AR-12).

As-at date30 Sep 2026EXAMPLE date. Replace it with today's date, or type =TODAY().
Due soon: calendar days before the due date30At least the time a campaign takes (the EXAMPLE campaign ran 28 calendar days from extract to close).

Headline measure

MeasureResultTargetStatusWhat it means
ARM-01 Reviews on time5 of 5AllOn targetIn-scope systems reviewed within their frequency, out of all in-scope systems. Due soon counts as on time; Overdue and Never reviewed do not. Access must be reviewed at least as often as its scope requires (FREQUENCY).

Systems by review scope

Review scopeReview every (months)SystemsIn dateDue soonOverdueNever reviewedWhy this interval
Privileged and administrator access, all systems322000The access that can do most harm, and changes most often.
Systems supporting a critical service (or a critical or important function, DORA; or cardholder data, PCI DSS)622000Regulated minimum for these systems.
All other in-scope systems1211000Regulated minimum for all other systems.
All scopes55000
No scope chosen yet0Choose a scope: until then the system has no review interval.

Next campaign

ItemValueNote
Earliest next review due29 Dec 2026Plan the next campaign's extract date at least the due-soon window before this date.
System due firstSYS-03Its System ID on the Inventory sheet. Where several share the date, the first in the list.
Systems whose extract is Ready5 of 5From the Extract Readiness sheet. Every system should be Ready before the extract date.
Longest extract lead time (working days)5Request extracts at least this many working days before the extract date.

Account types to review twice (AR-06)

Systems withSystemsNote
Privileged accounts4Reviewed by the system owner and information security (AR-06), every 3 months.
Generic or shared accounts1Each needs a named owner (AR-06).
Service accounts2Each needs a named owner (AR-06).
Third-party accounts3Supplier and contractor accounts are reviewed like any other; link the supplier's row in the P06 Supplier Security Risk Register.
Accounts without a named owner0Rows whose first open record check is a missing account owner.

Record checks to resolve

CheckSystems
Name the system owner (AR-01)0
Choose the review scope (AR-02)0
Record how access is extracted (AR-01)0
Extract lacks a field reviewers need (AR-03)0
Test the extract before the campaign0
Fix the extract issue0
Name an owner for each privileged, generic or service account (AR-06)0
Review overdue (AR-02)0
Never reviewed: schedule it (AR-02)0
All rows with a check to resolve0

Each row shows only its first unresolved check; clear it and the next one, if any, appears.

Lists

ScopeScopeMonthsYesNoYesNoNATestResultReviewStatus
Privileged and administrator access, all systems3YesYesOKIn date
Systems supporting a critical service (or a critical or important function, DORA; or cardholder data, PCI DSS)6NoNoIssueDue soon
All other in-scope systems12N/AOverdue

Never reviewed

Definitions

Definitions

TermMeaning in this workbook
SystemAn application, platform, directory group or file store that grants access to information. Each has one row and one owner.
System IDYour unique reference for the system, such as SYS-01. It stays the same while the system is in the inventory.
System owner[[the manager accountable for the system]]. Decides which permissions are right for each job and signs off the system's review (AR-01, AR-06).
Business serviceThe service the organisation provides that depends on the system, such as online ordering or payroll.
Review scopePrivileged and administrator access, all systems: every 3 months. Systems supporting a critical service (or a critical or important function, DORA; or cardholder data, PCI DSS): every 6 months. All other in-scope systems: every 12 months.
Privileged accountAn account that can change the system, its security settings or other people's access, such as an administrator.
Personal accountAn account used by one named person for their own work. Every system has them, so there is no column for them.
Generic or shared accountAn account not tied to one person, such as a shared login or a device account. Each needs a named owner (AR-06).
Service accountAn account used by software or an integration, not by a person. Each needs a named owner (AR-06).
Third-party accountAn account used by a supplier's staff, such as the provider's support desk. In the extract their employment status is Third party.
No match in HRThe employment status an extract shows for an account that matches nobody in HR records: an orphan account unless a named owner explains it.
EntitlementWhat an account is allowed to do on a system: its roles, groups and permissions.
ExtractThe list of every account on a system with its entitlements, taken on a stated date for review (AR-03).
Control countThe number of accounts the system itself reports, such as its user or licence count. The extract must reconcile to it.
Counts reconcileThe number of entries in the extract equals the control count. A difference means the extract is incomplete: find out why before anyone reviews it.
Check: every account includedThe extract lists every account, enabled and disabled, of every type: personal, privileged, generic or shared, service and third-party, including local accounts not in the directory.
Check: third-party accounts includedSupplier and contractor accounts are in the extract and marked as such (N/A where there are none).
Check: accounts can be matched to peopleEach account carries an identifier (employee number or email address) that matches the HR list or a named owner, so its employment status shows, and leavers, third parties and accounts with no match in HR stand out.
Check: permissions readable by a reviewerPermissions are shown as roles or in business terms, or a translation of the codes is attached, so a line manager can decide.
Check: dated and kept unchangedThe file is saved as received, named with the system, the extract date and who ran it, before anyone edits a copy (AR-03, AR-10).
Last sign-inThe date the account last signed in. Reviewers use it to find dormant accounts.
Dormant accountAn account that has not signed in for [[90]] days (the quality check in the methodology).
Orphan accountAn account that cannot be matched to a current person or a named owner.
Lead timeWorking days (Monday to Friday, excluding public holidays) between asking for an extract and receiving it.
Next review dueLast review plus the scope's interval. Blank until the system has been reviewed once.
Review statusIn date: next review due more than the due-soon window away. Due soon: due within the window (30 calendar days by default). Overdue: the due date has passed. Never reviewed: no review recorded.
ReadinessReady when the counts reconcile, the extract gives all 4 fields, every check is answered with no No, and the extract has been tested.
Record checkA calculated prompt showing the first missing or inconsistent item on the row. OK means nothing is outstanding.
As-at dateThe date review status is measured against. Set on the Summary sheet.
EXAMPLE rowA worked example: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, as at 2026-09-30. Delete before approval.
AR-nn, ARM-nnRule and measure numbers in the Access Review Methodology.

Framework References

Framework references

These references indicate relevance only and do not reproduce the text of any standard.

FrameworkReferenceSupported by
ISO/IEC 27001:2022Annex A 5.9 — Inventory of information and other associated assetsInventory sheet: the systems that hold information, each with an owner and the service it supports
ISO/IEC 27001:2022Annex A 5.18 — Access rightsReview scope, Review every, Last review, Next review due and Review status: access rights reviewed at planned intervals
ISO/IEC 27001:2022Annex A 5.16 — Identity managementExtract Readiness sheet: accounts matched to people, and generic, service and third-party accounts identified with an owner
NIST CSF 2.0ID.AM-02 — “Inventories of software, services, and systems managed by the organization are maintained”Inventory sheet: the inventory of systems, maintained with its owners and linked supplier
NIST CSF 2.0PR.AA-05 — “Access permissions, entitlements, and authorizations are defined in a policy, managed, enforced, and reviewed, and incorporate the principles of least privilege and separation of duties”Scope, frequency and status: access permissions reviewed; ARM-01 on the Summary sheet
DORA — Delegated Regulation (EU) 2024/1774Article 21(e) — account management: roles for granting, reviewing and revoking access; privileged access on a need-to-use basis; removal without undue delay; review at least every six months for systems supporting critical or important functions and at least yearly for othersReview scope list: six-monthly review for systems supporting critical or important functions and yearly for others; privileged access reviewed separately
PCI DSS v4.0.1Requirement 7.2.4 — user accounts and their access privileges, including third-party accounts, reviewed at least every six monthsThird-party accounts column and the six-monthly scope for systems in the cardholder data environment

Editions referenced: ISO/IEC 27001:2022 incl. Amd 1:2024; NIST CSF 2.0; Directive (EU) 2022/2555 (NIS2); Regulation (EU) 2022/2554 (DORA); Delegated Regulation (EU) 2024/1774; PCI DSS v4.0.1