What evidence do auditors commonly ask for on A.3.9 Access rights?

Current user profile record supporting attribution of access and change; Individual identifiers enforced on systems processing PII, with shared accounts prohibited; Administrative means provided to customers to manage access, and the responsibility split documented; Access review records.

What is the most common gap auditors find on A.3.9?

Shared or generic accounts on systems holding PII

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

`A.3.9` Access rights

The organization shall keep a correct and current register of the user profiles set up for people permitted to use information systems and the PII held in them, each profile holding the user details, the user identifier among them, that the technical access controls rely on. Every user shall have a personal identifier, so that suitably configured systems can show which person viewed PII and which records that person added, removed or altered; this protects individual users as well as the organization. Where the organization delivers PII processing as a service and the customer handles part or all of access management, the organization shall, as appropriate, give the customer the tools to do so, for example administrator rights to grant, change or revoke access, and shall document those arrangements.

Source: ISO/IEC 27701:2025, A.3.9. 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

Identity provider / directory

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

Current user profile record supporting attribution of access and change · Identity provider / directory
Access review records · Identity provider / directory

governing documentDocuments that govern the control

Individual identifiers enforced on systems processing PII, with shared accounts prohibited · Policy repository / GRC workspace
Administrative means provided to customers to manage access, and the responsibility split documented · Policy repository / GRC workspace

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

Shared or generic accounts on systems holding PII
Customer unable to remove a departed employee's access without a support ticket

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.3.8 Identity management · A.3.10 Addressing information security within supplier agreements