Why UAE Companies Fail ISO 27001 on Access Control Evidence (And How to Fix It)

Access control is one of the most audited parts of ISO 27001. And in the UAE, it’s also one of the most common reasons companies receive nonconformities, observations, or repeated findings during internal audits and certification readiness checks.

The issue is not that UAE companies don’t care about security. Most teams do. The real issue is this: access control is often “done” in systems, but not proven with evidence. Auditors don’t just want to hear that you control access. They want to see consistent proof that access is granted correctly, reviewed regularly, and removed on time.

This article explains why access control evidence fails, what auditors typically ask for, and how UAE businesses can fix it with a practical, step-by-step approach.

What “Access Control Evidence” Means in ISO 27001 (Simple Explanation)

Access control in ISO 27001 is about making sure:

• Only the right people can access the right information
• Access is approved before it’s given
• Access is removed when it’s no longer needed
• Changes are tracked and reviewed
• The organization can prove all of the above

So, even if your company uses Microsoft 365, Active Directory, ERP systems, HR tools, CCTV access cards, or cloud applications, the auditor will still ask the same question:

“Show me how you control access and how you prove it.”

In many UAE audits, failure happens because teams rely on verbal confirmation like:

• “Only IT can give access”
• “We don’t share passwords”
• “HR informs IT when someone leaves”

Those statements are not evidence.

If you want to set up access control evidence properly before the audit, our ISO 27001 implementation support in UAE team can help you structure approvals, reviews, and offboarding records.

For reference, you can also review the official overview of the ISO/IEC 27001 standard on ISO.org, it helps to align your access control evidence with what auditors expect.

Why UAE Companies Fail ISO 27001 Access Control Evidence (Top Reasons)

1) Access is given quickly, but approvals are missing

In fast-moving UAE workplaces, access requests are often handled on WhatsApp, calls, or informal messages. The user gets access, but there is no formal approval trail.

What auditors expect:

• Access request record
• Manager approval
• IT action confirmation
• Date and time stamp
• System name and role assigned

How to fix it:

• Use a simple access request form (even Excel or ticketing tool is fine)
• Make “manager approval” mandatory before IT grants access
• Store approvals in a controlled folder or helpdesk system

2) User access rights don’t match job roles

This is a very common issue in UAE companies with multi-role staff. People move between departments or projects, but their access remains the same.

Examples:

• A resigned accountant still has ERP access
• A procurement staff member has admin rights in shared drives
• A sales executive can access HR folders
• A site supervisor has access to confidential tender pricing files

What auditors expect:

• Role-based access control (RBAC)
• Defined access levels
• Access mapping to job roles

How to fix it:

• Create a simple “Role vs Access” matrix
• Limit admin rights to minimum users
• Review high-risk roles first (Finance, HR, IT, Procurement)

3) No regular access review (or reviews exist but mean nothing)

Many UAE companies create an access review document once a year, just to show something in the audit. But the review is not based on real user lists or real system exports.

What auditors expect:

• Quarterly or periodic access review evidence
• Review includes critical systems and shared drives
• Actions taken (remove, modify, confirm)
• Reviewer is a business owner, not only IT

How to fix it:

• Perform quarterly reviews for critical systems
• Attach system user exports as evidence
• Track changes in a simple log: removed users, changed roles, admin rights reduced

4) Leavers are not removed on time (offboarding gap)

In UAE organizations, employee exit processes can be delayed due to handover, visa matters, or administrative steps. But from ISO 27001 perspective, access must be removed as soon as it is no longer required.

This is one of the fastest ways to get a nonconformity.

What auditors expect:

• HR offboarding checklist
• IT account deactivation record
• Email access removed or forwarded properly
• Shared drive access removed
• VPN access removed
• System access removed

How to fix it:

• Connect HR exit process with IT removal process
• Create a “leaver notification” email template
• Set a target: disable access within 24 hours of last working day

5) Shared accounts and password sharing

For UAE businesses using Microsoft 365, enabling multi-factor authentication is one of the fastest ways to reduce access misuse risk, and Microsoft provides a clear overview of multi-factor authentication (MFA) and how it works.

Some UAE businesses still use:

• shared admin accounts
• generic “reception@” logins for systems
• one password used by multiple staff
• shared Excel files with passwords shared across teams

Auditors will flag this quickly because it breaks accountability.

What auditors expect:

• Unique user IDs
• Strong password policy
• MFA where applicable
• Audit logs enabled

How to fix it:

• Replace shared accounts with named accounts
• Enforce MFA for email, VPN, and cloud systems
• Keep emergency admin access controlled with a log and approval

6) No evidence of privileged access control

Privileged access includes admin access for:

• servers
• Microsoft 365 admin
• ERP admin
• firewall access
• database admin
• cloud console access

Many companies fail because admin access is given but not controlled.

What auditors expect:

• List of privileged accounts
• Approval and justification for admin rights
• Monitoring or review of privileged actions
• Separation of duties where possible

How to fix it:

• Maintain a privileged access register
• Review privileged access monthly or quarterly
• Restrict admin rights to minimum users only

7) Access logs exist, but nobody checks them

A UAE company may have logs in:

• Microsoft 365
• firewall
• VPN
• ERP systems

But if nobody reviews them, the control becomes weak.

What auditors expect:

• Log monitoring procedure
• Evidence of review (weekly/monthly reports)
• Actions taken when suspicious activity occurs

How to fix it:

• Create a simple log review checklist
• Review high-risk systems first (email, VPN, admin portals)
• Keep monthly review screenshots or exported reports as evidence

8) Physical access control is ignored (server rooms and files)

ISO 27001 is not only about IT access. In UAE audits, auditors also check physical access controls, especially for:

• server rooms
• CCTV rooms
• finance record storage
• HR files
• visitor access to restricted areas

What auditors expect:

• Door access control list
• Visitor logbook
• Restricted area signage
• Physical key control evidence

How to fix it:

• Maintain visitor logs for restricted areas
• Keep key issue register if keys are used
• Restrict server room access to authorized persons only

What Auditors Ask for During ISO 27001 Access Control Checks

If you want to prepare quickly, keep these items ready:

• Access control policy
• User provisioning process (joiner / mover / leaver)
• Access request and approval records
• List of active users for key systems
• Privileged access list
• Access review records (quarterly recommended)
• Evidence of access removal for resigned staff
• MFA evidence for email/VPN/cloud
• Password policy enforcement evidence
• Audit logs enabled + log review evidence

In UAE audits, the biggest gap is usually #3, #6, and #7.

A Simple UAE Fix Plan (You Can Implement in 7 Days)

Day 1: Identify your critical systems

List your systems, for example:

• Email (Microsoft 365 / Google Workspace)
• Shared drives
• ERP / accounting
• HR system
• VPN
• CRM
• Project management tools

Day 2: Create a basic access matrix

Make a simple table:

• Role
• System
• Access level
• Approver

Day 3: Standardize access requests

Use:

• ticketing system, or
• email approval, or
• controlled form

The key is: approval must be traceable.

Day 4: Fix leaver process

Add a leaver checklist:

• disable account
• remove system access
• revoke VPN
• remove shared drive permissions
• recover assets (laptop, access card)

Day 5: Control admin access

Create a privileged access register and remove unnecessary admin rights.

Day 6: Do a quarterly access review template

Keep it simple:

• export user list
• confirm valid users
• remove extra rights
• save evidence

Day 7: Train departments (short session)

Train HR, IT, and department managers on:

• how to request access
• how approvals work
• why timely removal matters

Keep attendance record and agenda as evidence.

Common Access Control Nonconformities in UAE

Here are typical audit findings:

• Access granted without documented approval
• Resigned employee accounts still active
• No periodic access review for critical systems
• Admin access not controlled or justified
• Shared accounts used in business systems
• No evidence of access removal and asset return
• HR and IT offboarding not linked
• Sensitive folders accessible to unauthorized staff

If your company has any of these, you can fix them without heavy paperwork. You just need consistent evidence.

How to Prove Access Control is Working (Evidence Checklist)

To pass audits smoothly, keep a folder for access control evidence:

• Access request forms (last 3 months)
• Approval emails or ticket screenshots
• User access list exports
• Quarterly access review report
• Leaver checklist samples
• Admin access register
• MFA enforcement screenshot or report
• Log review checklist (monthly)

This evidence set is usually enough to satisfy auditors across industries in UAE.

Final Thoughts

ISO 27001 access control failures in UAE are rarely technical problems. They are evidence problems. Your systems may already be secure, but if approvals, reviews, and removals are not documented properly, audits will still raise findings.

When access control evidence is structured, consistent, and easy to retrieve, ISO 27001 audits become much smoother and your risk exposure drops immediately.