How should identity teams use activity monitoring to improve access reviews?

Identity teams should use activity monitoring as evidence inside access reviews so approvers can see whether access is actually being used. That context helps reduce rubber-stamping, supports least privilege decisions, and makes revocation easier to justify when a user has not touched a system for a long period. The goal is better decisions, not more review volume.

Why Activity Data Improves Access Review Decisions

Access reviews become more useful when approvers can see whether access is actually being used, not just whether it exists on paper. Activity monitoring adds evidence about recency, frequency, and scope of use, which helps distinguish dormant access from active operational need. That matters because entitlement lists alone often create false confidence: a role can look appropriate while the underlying account has drifted, accumulated privilege, or stopped serving a real business function.

For identity teams, the practical value is not surveillance for its own sake. It is decision quality. Activity signals help reviewers challenge inherited access, reduce rubber-stamping, and justify removal when a user or service has not touched a system for a long period. When that evidence is absent, reviews tend to become checkbox exercises that preserve access by default rather than confirm current need.

In practice, many organisations discover that stale access persists longest in the reviews that appear most routine.

How Activity Monitoring Works in the Review Workflow

The strongest pattern is to attach activity evidence to each review item in a way that a reviewer can interpret quickly. That usually means showing the last access date, the type of activity performed, the system or dataset touched, and whether the activity matches the entitlement being reviewed. If the account is a non-human identity, the evidence should also distinguish human login activity from workload or API use, because those behaviours imply different ownership and review logic.

Current guidance suggests using activity data as a decision aid, not as an automatic approval or denial trigger. A recent, relevant access event may support retention, but only if the event is consistent with the access scope and the account owner can explain the need. Likewise, no activity is not always proof of unnecessary access, especially for emergency, seasonal, or low-frequency administrative access. The review process should therefore ask whether the access is still required, whether the activity is tied to a legitimate business process, and whether the entitlement remains bounded to the smallest practical scope.

Teams usually get better results when they pair activity monitoring with clear review thresholds. For example, they can flag access that has seen no use for 90 days, mark repeated access outside normal job patterns, and require stronger justification for privileged or cross-environment access. The Ultimate Guide to NHIs is useful here because it frames visibility, lifecycle, and revocation as linked controls rather than separate tasks.

A useful review packet should also preserve context. Activity evidence should be time-bounded, role-aware, and easy to audit later, so approvers can see why a decision was made. That matters especially when access spans multiple systems, because activity in one place may not justify broad entitlement elsewhere. The OWASP Non-Human Identity Top 10 provides a strong reference point for why machine and service access needs lifecycle and visibility controls, not just periodic attestation.

NHIMG research has repeatedly shown why this matters operationally: 80% of identity breaches involved compromised non-human identities such as service accounts and API keys, which means review quality directly affects exposure when review evidence is weak or stale. These controls tend to break down in environments where access is shared, heavily automated, or spread across multiple owners because reviewer context becomes too thin to support a defensible decision.

Common Variations and Edge Cases

Tighter review rules often increase analyst effort, so teams have to balance better evidence against review fatigue. A single activity feed is rarely enough in complex environments because “use” can mean very different things for interactive users, privileged admins, service accounts, and API-driven workloads. Best practice is evolving, but there is no universal standard for how much activity is enough to justify retention across every account type.

One common edge case is low-frequency but legitimate access, such as break-glass accounts or quarterly operational tasks. Another is automation that generates activity without confirming business need, which can make dormant entitlements look active. Identity teams should also avoid treating any recent event as proof of necessity; that shortcut can preserve excessive privilege just as easily as a blind review can. Where access is cross-functional or third-party managed, the reviewer may need ownership confirmation before trusting the activity record.

When activity evidence is noisy, the better question is whether the pattern supports the specific entitlement being reviewed. A limited set of meaningful signals is more defensible than a broad dump of logs that no approver can interpret. The Top 10 NHI Issues is a helpful companion for understanding how visibility gaps and over-privilege show up together in practice. In mixed human and machine environments, reviews work best when the evidence explains both who used the access and whether that use still matches the account’s current purpose.

Risk and Threat Considerations

Access reviews that ignore activity data can leave dormant or over-scoped access in place long after business need has faded. That creates exposure because attackers and insiders often benefit most from accounts that look legitimate, remain unchallenged, and are rarely exercised.

Failure mechanism: When reviewers rely on entitlement lists alone, stale access can survive repeated certifications, especially if approvals are rubber-stamped, ownership is unclear, or logs are too sparse to show that access is no longer needed. Over time, that weakens least privilege and preserves an easier path for misuse.

Impact: The result can be broader blast radius, slower revocation, and greater difficulty proving that access was justified. In high-value systems, that also increases the chance that a compromised account or service credential will remain usable long enough to matter.

Standards & Framework Alignment

This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.

OWASP Non-Human Identity Top 10 address the attack and risk surface, while CIS Controls v8 and NIST CSF 2.0 set the governance and control requirements practitioners need to meet.

Framework	Control / Reference	Relevance
CIS Controls v8	5 — Account Management	Access reviews and activity evidence support timely account review and removal.
	6 — Access Control Management	Activity monitoring helps confirm whether granted access remains justified.
Recommendation — Use access activity to revalidate accounts and remove unnecessary access promptly. Review usage evidence before renewing access and tighten permissions that show no need.
NIST CSF 2.0	PR.AA-01 — Identity Management, Authentication, and Access Control	Activity evidence strengthens access decision-making and least-privilege enforcement.
	DE.CM-07 — Continuous Monitoring	Monitoring provides the evidence base for detecting stale or excessive access.
Recommendation — Incorporate usage evidence into access reviews to validate current authorization need. Collect access activity telemetry to surface dormant, unusual, or excessive use.
OWASP Non-Human Identity Top 10	NHI-04 — Secrets and Credential Lifecycle	Machine access reviews depend on visibility into actual credential and token use.
Recommendation — Track credential use and revoke non-human access that shows no legitimate activity.

Practitioner Guidance

What to prioritise: Focus first on access classes where misuse would be hardest to detect and costliest to recover from, such as privileged, dormant, shared, or cross-environment access. Those are the reviews where activity evidence changes decisions most often.

What to verify: Confirm that the activity signal actually matches the entitlement being reviewed. A login event is not the same as real use, and workload automation can make an account look active even when the business justification has expired.

Decision rule: If the reviewer cannot connect recent activity to a current business purpose, treat the access as requiring explicit justification rather than default renewal. If the account is low-risk and low-frequency, use that same evidence more cautiously and avoid overreacting to sparse usage alone.

Practitioner takeaway: The goal is not to prove that access was used; it is to prove that it is still needed, still bounded, and still attributable to a real operational purpose.