What evidence do auditors commonly ask for on A.3.8 Identity management?

Registration and de-registration procedures covering credential compromise; Evidence identifiers on systems processing PII are never reissued; Documented split of identifier management responsibility with customers; Checks for unused credentials at the frequency the jurisdiction requires.

What is the most common gap auditors find on A.3.8?

Identifiers reissued to new joiners so historical access records point at the wrong person

ISO/IEC 27701:2025 · Annex A Table A.3 information security controls with PII-specific guidance

`A.3.8` Identity management

The procedures for enrolling and removing users who run or administer PII-processing systems and services shall cover what happens when those users' access controls are compromised, for example when passwords or other enrolment details are corrupted or exposed. The organization shall never reassign a user identifier that has been deactivated or has expired on such systems and services. When PII processing is supplied to customers as a service, a customer may assume part or all of identifier management, and those arrangements shall be recorded in the documented information. Certain jurisdictions set particular rules on how often PII-processing systems must be checked for authentication credentials that are no longer used.

Source: ISO/IEC 27701:2025, A.3.8. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27701:2025 in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Document repository

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Evidence identifiers on systems processing PII are never reissued · Document repository
Checks for unused credentials at the frequency the jurisdiction requires · Identity provider / directory

governing documentDocuments that govern the control

Registration and de-registration procedures covering credential compromise · Policy repository / GRC workspace
Documented split of identifier management responsibility with customers · Document repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Identifiers reissued to new joiners so historical access records point at the wrong person
Customer-managed identities assumed, with nothing documented and no dormancy check

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

A.3.7 Information transfer · A.3.9 Access rights