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Deepfakes and Voice Phishing: How to Prepare Employees?

Deepfakes and voice phishing mean employees can no longer rely only on voice, video appearance, phone number or an urgent request from a “CEO”, “customer” or “supplier”. The best protection is not detecting AI by ear, but simple procedures: second-channel verification, safety phrases, two-person approval, payment limits, training, ready scenarios and fast reporting of suspicious contacts.

Prepared by: CCyber Editorial Team

Short answer

Employees should be prepared for deepfakes and voice phishing so they do not have to guess whether a voice or video is real. In practice, the most important rule is: do not make financial, access or data decisions only based on a phone call, voice message, video conference or urgent request. Every unusual request must be verified through a second channel, using a previously known contact method, two-person approval and suspicious-contact reporting. Training should teach not only how to recognize deepfakes, but above all the procedure: stop, verify, confirm, report.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • HR and training owners
  • IT, security, CISO and vCISO teams
  • finance, accounting and payment approvers
  • sales, customer service and support
  • executive assistants and office managers
  • teams using video conferencing, messaging tools and AI tools
  • SMEs preparing a cybersecurity awareness programme
  • companies preparing for ISO 27001, SOC 2, NIS2, cyber insurance or customer audit

Key takeaways

  1. Deepfakes and voice phishing are not only a technology problem. They are mainly a problem of decisions made under time pressure.
  2. Do not train employees to “detect AI by voice”. That is too risky. Train them to verify unusual requests using an agreed procedure.
  3. The biggest risks involve payments, bank account changes, data sharing, password resets, access granting and sending confidential documents.
  4. The best controls are: second-channel verification, known contact numbers, two-person approval, payment limits, safety phrases, exception lists and fast reporting.
  5. Training should be practical. Employees should practice scenarios: a call from the “CEO”, a deepfake online meeting, fake supplier, urgent payment and request for customer data.

What is a deepfake?

A deepfake is artificially generated or manipulated image, audio or video that may look or sound like a real person. In a business context, a deepfake may mean the CEO’s voice, a CFO video, a customer recording, a supplier voice message or a fake part of an online meeting.

A deepfake can be used to:

  • impersonate a board member
  • request an urgent payment
  • obtain customer data
  • convince an employee to reset a password
  • gain system access
  • confirm a fake bank account change
  • manipulate an employee during a video call
  • create fake evidence or a fake recording
  • damage company or personal reputation

The key point: a deepfake does not have to be perfect. It only needs to appear in a situation of stress, urgency, authority or financial pressure.

What is voice phishing?

Voice phishing, also known as vishing, is fraud conducted by phone, voice message, messenger, audio recording or online call. The goal is to persuade a person to transfer money, disclose data, share a password, provide an MFA code, reveal company information or take an action they normally would not take.

Voice phishing may be a normal conversation with a fraudster, but it can increasingly be supported by AI: voice cloning, automated speech generation, translation, scenario personalization and combining information from the internet.

Typical voice phishing scenarios

  • the “CEO” calls with an urgent payment request
  • the “CFO” asks to confirm a payment
  • a “supplier” asks to change the bank account number
  • a “customer” asks to send documents to a new address
  • “IT” asks for an MFA code or password reset
  • the “bank” asks to approve a transaction
  • a “lawyer” or “auditor” asks for urgent data
  • a “team member” asks for file or system access

Why are deepfakes and voice phishing dangerous?

1. People naturally trust voice

Voice is a strong trust signal. When an employee hears a familiar tone, speech pattern and emotion, they may react faster without additional verification.

2. Time pressure weakens judgment

Attacks often use pressure: “this is urgent”, “do not tell anyone”, “the customer is waiting”, “the board already approved this”, “the payment must go out today”. This is not accidental. Urgency reduces critical thinking.

3. AI removes old warning signs

In the past, phishing was often exposed by language mistakes, strange style and weak personalization. Today, a message, voice or scenario may be fluent, correct and tailored to the company.

4. Attacks can combine multiple channels

The most dangerous scenario combines email, phone, messenger and video call. Example: an employee receives an email from the “CEO”, then a call with a similar voice, then a meeting link.

5. The attacker may know company context

Information from LinkedIn, company website, social media, podcasts, webinars, video recordings, job offers and press releases may help create a convincing scenario.

The most important training rule

Do not train employees that they must independently recognize deepfakes by image or sound quality. This may create a false sense of security. An employee should not be an AI detector.

Teach employees a simple rule:

If the request is urgent, unusual, financial, related to data, password, access or bank account change, stop and verify through a second channel.

Which people in the company are most exposed?

Finance and accounting

The biggest risks are fake payments, bank account changes, urgent invoices, executive impersonation and pressure to bypass procedure.

Board and executive assistants

Their voice, image and communication style may be used for impersonation. Assistants often have access to calendars, documents and contacts.

HR

HR processes personal data, documents, contracts and employee information. It may be targeted with requests for employee lists, payroll data or documents.

IT and administrators

The biggest risks are password resets, MFA codes, access granting, administrator access and pressure from the “board”.

Sales and customer service

An attacker may impersonate a customer, partner or supplier to obtain documents, data, system access or change communication rules.

Marketing and communications

These teams publish image, voices, recordings, videos and events. They may unintentionally increase the amount of material available for impersonation.

How to prepare employees step by step?

Step 1: explain the threat in simple language

Employees do not need to know technical details of AI models. They need to understand that voice, image, video, messages and communication style can now be faked. Behavior matters more than technology.

Explain:

  • what a deepfake is
  • what voice phishing is
  • what social engineering pressure looks like
  • why voice is not enough evidence
  • when to stop a conversation
  • how to report a suspicious contact

Evidence to prepare: short employee instruction: “Do not trust voice alone. Verify through a second channel”.

Step 2: define second-channel verification

The second channel is the most important control. If the request came by phone, confirm it through another channel. If it came by email, confirm it by phone using a known number. Do not use the number provided in the suspicious message.

Examples:

  • a call from the “CEO” should be confirmed through a known number or directly in the company messenger
  • a bank account change should be confirmed with the supplier using the contact from the contract
  • a request for customer data should be confirmed with the customer owner
  • a password reset request should follow the IT procedure
  • a request from a video conference should be confirmed after the meeting through a second channel if it is unusual

Evidence to prepare: second-channel verification procedure for payments, data, access and bank account changes.

Step 3: introduce a safety phrase for high-risk situations

For selected processes, a short safety phrase or verification question can be used, but it should not be based on public information. Questions like “what is the CEO’s dog called” may be easy to find online.

Good rules:

  • only a limited group knows the safety phrase
  • the phrase is changed periodically
  • the phrase is not sent in plain text by email
  • the phrase does not replace payment procedure
  • the phrase is only an additional control

Evidence to prepare: safety phrase procedure for emergency and high-risk situations.

Step 4: introduce two-person approval

Payments, bank account changes, administrator access, sensitive data transfers and critical configuration changes should not depend on one person’s decision under phone pressure.

Two-person approval should cover:

  • payments above a defined limit
  • new payment recipients
  • bank account number changes
  • sending customer data outside the standard process
  • granting administrator access
  • disabling a security control
  • urgent policy exceptions

Evidence to prepare: two-person authorization procedure and limit list.

Step 5: prepare a red flag list

Employees should know warning signs, but they cannot rely only on them. No red flags does not mean the contact is genuine.

Red flags

  • urgency and time pressure
  • request for secrecy
  • bypassing standard procedure
  • request to transfer money to a new account
  • request for an MFA code
  • password reset request
  • unusual request from a person with authority
  • moving communication to a private channel
  • refusal to confirm through a second channel
  • unusual speech style despite familiar voice
  • strange background, delays, unnatural lip movement or video quality

Evidence to prepare: one-page red flag list for employees.

Step 6: practice scenarios

Simply saying “watch out for deepfakes” is not enough. Employees must practice situations where someone applies pressure and requests action.

Scenarios to practice

  • call from the “CEO” requesting an urgent payment
  • voice message from a “customer” requesting documents
  • video meeting with a “director” requesting a process change
  • call from “IT” asking for an MFA code
  • supplier asks to change the bank account number
  • manager asks to send a file to a private address
  • external person claims they already spoke with the board

Evidence to prepare: exercise scenarios and lessons learned report.

Step 7: prepare a fast reporting process

An employee should know where to report a suspicious call, voice message, recording, meeting or request. Reporting should be simple and non-punitive.

The process should answer:

  • where should suspicious contact be reported?
  • what should be attached to the report?
  • can the employee end the call?
  • who decides the next action?
  • how fast do IT or security respond?
  • is reporting handled without blame?

Evidence to prepare: suspicious AI-supported contact reporting procedure.

Step 8: limit public voice and video samples

Not every company can limit publishing, because marketing, sales and recruitment need videos and webinars. However, high-risk materials should be managed consciously.

Check:

  • how many board recordings are publicly available
  • whether recordings contain long voice samples
  • whether travel and calendar information is public
  • whether social profiles reveal work relationships
  • whether the company publishes internal project names
  • whether videos can be shortened or labeled

The goal is not to disappear from the internet. The goal is to understand that public material may be used to create more convincing impersonation.

Evidence to prepare: review of public audio and video materials of high-risk people.

Step 9: secure processes, not only people

The best training is not enough if procedures allow one person to execute a large payment after a phone call. A deepfake should be stopped by the process, even if the employee is tired, stressed or convinced they are speaking with a real person.

Processes to secure:

  • payments
  • supplier data changes
  • password reset
  • access granting
  • customer data transfers
  • IT configuration changes
  • approval of policy exceptions
  • approval of new AI tools

Evidence to prepare: high-risk process list and verification control for each process.

Step 10: connect the topic with MFA and access control

Voice phishing often does not end with the conversation. The fraudster may try to obtain a password, MFA code, account reset or application access.

Technical minimum:

  • MFA for all accounts
  • stronger MFA for administrators
  • ban on sharing MFA codes by phone
  • password reset procedure with identity verification
  • logging unusual access attempts
  • administrator review
  • supplier access control

Evidence to prepare: MFA report, password reset procedure and account takeover playbook.

What should a good verification procedure look like?

Rule 1: break the pressure

An employee has the right to say: “I need to confirm this according to procedure”. A good security culture supports this behavior even if the request looks urgent.

Rule 2: use a known channel

Do not call back the number provided in a suspicious message. Use a number from the contract, CRM, company contact book or previously confirmed channel.

Rule 3: do not confirm in the same thread

If the request came by email, replying to the same email is not enough. If it came by phone, continuing the same conversation is not enough.

Rule 4: document exceptions

If the company still decides to take unusual action, the decision should have an owner, justification and approval evidence.

Rule 5: report suspicion

Even if the employee did nothing, the suspicious call itself may indicate a larger campaign against the company.

Minimum checklist for employees

When someone calls or sends a voice message

  • stop if the request is urgent or unusual
  • do not share MFA codes
  • do not change bank account details during the call
  • do not send customer data to a new address without verification
  • do not reset passwords without procedure
  • confirm the request through a known channel
  • report suspicious contact to IT or security

When you are on a video conference

  • watch out for requests involving payment, data or access
  • check whether the meeting was planned
  • check participants and invitation addresses
  • do not share confidential documents in chat without need
  • confirm unusual decisions after the meeting through an independent channel
  • report the meeting if a participant behaved unusually

When someone requests a payment

  • check whether the request follows the process
  • confirm the payment recipient
  • confirm the bank account through a known channel
  • apply two-person approval
  • do not accept secrecy pressure
  • save verification evidence

How to train specific teams?

Finance and accounting

Training should focus on fraudulent payments, bank account changes, executive impersonation, time pressure and supplier verification.

  • exercise: “CEO calls with urgent payment”
  • exercise: “supplier changes bank account”
  • exercise: “law firm requests a secret transfer”
  • procedure: second channel and two people

IT and administrators

Training should focus on password resets, MFA codes, access granting, administrator access and pressure from the “board”.

  • exercise: “director asks for immediate password reset”
  • exercise: “supplier needs admin account for one hour”
  • exercise: “employee shares MFA code by phone”
  • procedure: identity verification and change register

HR

Training should cover personal data protection, fake requests for documents, payroll data, CVs, contracts and employee identity verification.

  • exercise: “manager requests payroll list”
  • exercise: “employee asks for documents to a private email”
  • exercise: “candidate sends suspicious portfolio link”
  • procedure: verification and secure sending channel

Sales and customer service

Training should cover customer impersonation, contact changes, fake document requests, contract pressure and verification of unusual instructions.

  • exercise: “customer asks to send data to a new address”
  • exercise: “partner asks for file access”
  • exercise: “urgent change of contact person”
  • procedure: confirmation by customer owner

Board

The board should understand that its public image, voice and communication style can be used. It should also clearly support employees who pause urgent unusual requests.

  • define rules for urgent financial decisions
  • define safety phrase or second channel
  • do not bypass procedures “because it is urgent”
  • communicate that verification is expected

30, 60 and 90-day action plan

First 30 days

  • assign owner for deepfake and voice phishing readiness
  • identify high-risk processes: payments, data, access, passwords, suppliers
  • prepare a short instruction for all employees
  • introduce second-channel verification
  • introduce the rule: never share MFA codes by phone
  • check who approves payments and bank account changes
  • define a suspicious-contact reporting channel
  • run short training for finance, IT and executive assistants

Days 31 to 60

  • prepare exercise scenarios for teams
  • introduce two-person approval for payments and bank account changes
  • define known contact channels for key people and suppliers
  • prepare safety phrase procedure if the company wants to use it
  • review public audio and video recordings of high-risk people
  • update incident reporting procedure
  • prepare suspicious call playbook
  • prepare fake video meeting playbook

Days 61 to 90

  • run a tabletop exercise with finance, IT and the board
  • run a simulation of an urgent payment request
  • check whether employees know where to report suspicious contacts
  • measure response time to a suspicious request
  • update training based on exercise results
  • prepare a board report
  • add deepfake topic to onboarding
  • define recurring training at least annually or after a material incident

What documents and evidence should be prepared?

Training documents

  • deepfake and voice phishing training agenda
  • training materials
  • participant list
  • short knowledge test results
  • exercise scenarios
  • exercise report
  • post-training remediation action list

Procedures

  • second-channel verification procedure
  • bank account change procedure
  • urgent payment approval procedure
  • password reset procedure
  • access granting procedure
  • suspicious-contact reporting procedure
  • suspicious deepfake handling procedure

Technical and organizational evidence

  • MFA report
  • administrator account list
  • phishing and suspicious-call report register
  • public audio and video material list for high-risk people
  • known contact channel list for key people
  • supplier and verification contact list
  • exception register
  • board report

How to measure readiness effectiveness?

Training metrics

  • number of trained employees
  • training completion rate
  • knowledge test result
  • number of teams covered by exercises
  • number of high-risk people trained separately

Behavior metrics

  • number of reported suspicious calls
  • number of reported suspicious voice messages
  • number of unusual requests stopped
  • time to report suspicious contact
  • number of cases confirmed through a second channel

Process metrics

  • percentage of high-risk payments approved by two people
  • number of bank account changes verified through a second channel
  • number of process exceptions
  • number of password resets outside procedure
  • number of high-risk access grants after approval

Risk metrics

  • number of public recordings of high-risk people
  • number of impersonation-related incidents
  • number of fake payment attempts
  • number of MFA code theft attempts
  • number of remediation actions closed after exercise

Common company mistakes

Mistake 1: relying on “voice recognition”

An employee should not decide based on whether the voice sounds real. Procedure matters more than impression.

Mistake 2: no second-channel verification

If the request came by phone, it must be confirmed independently. Continuing the same conversation is not verification.

Mistake 3: too much board pressure for speed

If the board rewards bypassing procedures “because it was urgent”, employees will be afraid to stop suspicious requests.

Mistake 4: training only finance

Finance matters, but deepfakes may target IT, HR, sales, support, suppliers and the board too.

Mistake 5: no video meeting procedure

Many companies have procedures for emails, but no rules for unusual requests made during online meetings.

Mistake 6: using public information as verification questions

Questions about family, school, job title, pet or city may be available online. They should not be the only verification method.

Mistake 7: punishing false alarms

A false report is better than a real incident without a report. Employees should feel allowed to pause and check.

Mistake 8: no exception documentation

Every procedure bypass should have an owner, reason and approval. Otherwise exceptions quickly become the new normal.

Business example

A services company has 70 employees. The finance director receives a voice message from someone who sounds like the CEO. The request concerns an urgent transfer to a new supplier, and the caller asks not to involve anyone else because the matter is confidential.

The finance employee knows the procedure. They do not execute the payment during the call. They end the contact, check the number in the company contact book and call the CEO through a known channel. It turns out the CEO did not request the payment. The team reports the fraud attempt to IT and security.

After analysis, the company sees that the attacker used public webinar recordings of the CEO and information about a new project posted on LinkedIn. The company updates training, introduces two-person approval for new bank accounts, adds deepfake awareness to onboarding and creates a suspicious-call playbook.

The key result: the employee did not have to decide whether the voice was synthetic. It was enough to follow the procedure.

How can ccyber.io help?

ccyber.io helps companies prepare employees for deepfakes, voice phishing and AI-supported scams. We do not limit the work to a threat presentation. We build procedures, scenarios, exercises and evidence that actually reduce the risk of wrong decisions under pressure.

We can support your organization with:

  • deepfake and voice phishing employee training
  • AI scams training for boards and finance teams
  • deepfake tabletop exercise
  • second-channel verification procedure
  • bank account change procedure
  • urgent payment procedure
  • suspicious-call playbook
  • fake video meeting playbook
  • public audio and video material review
  • audit-ready training evidence pack
  • awareness programme effectiveness metrics

The best first step is an AI Social Engineering Readiness Workshop. In a short workshop, the company can identify processes most exposed to deepfakes, prepare a verification procedure and plan first training for finance, IT, HR, sales and the board.

FAQ

Can an employee recognize a deepfake by voice?

Sometimes they may notice strange elements, but they should not rely on this. Better protection is a procedure: stop, check through a second channel, do not act under pressure and report suspicion.

What is the difference between a deepfake and voice phishing?

A deepfake is artificially generated or altered image, voice or video. Voice phishing is fraud conducted through a call or voice message. Voice phishing may use deepfakes, but it does not have to.

Which teams should be trained first?

Start with finance, accounting, IT, administrators, HR, executive assistants, sales and people with access to customer data or authority to approve payments.

What should I do if I receive a call from the CEO with an urgent request?

Do not carry out an unusual request during the call. End the conversation and confirm it through a known channel. If the request concerns money, data or access, follow the procedure and report the event.

Is a safety phrase enough?

Not alone. A safety phrase can help, but it should be an additional control. Second-channel verification, two-person approval and exception documentation matter most.

Should public board recordings be limited?

At least understand which recordings are public and who is most exposed. The goal is not to stop marketing, but to manage materials that may make impersonation easier.

Can a deepfake appear in a video conference?

Yes. That is why unusual decisions from online meetings, especially about money, access or data, should be confirmed after the meeting through an independent channel.

How often should employees be trained?

At least annually and during onboarding. High-risk teams such as finance, IT and HR should be trained more often and after new incidents or procedure changes.

Summary

Deepfakes and voice phishing change trust rules inside companies. Voice, face, phone number and urgent message can no longer be enough proof of identity. This is especially true when the request concerns money, data, access, passwords or bypassing procedures.

The best protection is not that an employee “recognizes AI”. The best protection is that the employee knows what to do: stop, confirm through a second channel, use two-person approval and report suspicious contact.

Companies that prepare procedures, train high-risk teams and practice realistic scenarios will be much more resilient against AI-supported fraud. A deepfake may look and sound convincing, but a well-designed process should stop it before a payment, data leak or access grant happens.

Sources

Zero Trust for SMEs: A Simple Explanation

Zero Trust for SMEs does not mean buying one expensive tool. It is a practical rule: do not automatically trust a user, device, network or application just because it is “inside the company”. Every access should be verified, limited to the required role, monitored and removable. For SMEs, Zero Trust starts with MFA, access reviews, secure devices, supplier control, backup and logs.

Prepared by: CCyber Editorial Team

Short answer

Zero Trust is a cybersecurity approach based on a simple rule: do not trust automatically, always verify. In practice, the company does not assume that a user, computer, phone, supplier, application or network is safe only because it belongs to the organization or connects through VPN. Every access to data and systems should be checked, limited to the minimum, policy-based, monitored and regularly reviewed. For SMEs, Zero Trust does not need to mean a large enterprise project. The best start is MFA, account cleanup, access review, administrator control, secure devices, backup, logs and response procedures.

Last updated

July 2026

Who this article is for

  • small and medium business owners
  • SME boards
  • CISOs, vCISOs, CTOs and IT directors
  • Microsoft 365, Google Workspace, Azure, AWS and Google Cloud administrators
  • companies using remote work, cloud, SaaS, CRM, ERP and IT suppliers
  • companies after phishing, account takeover or ransomware incidents
  • software houses, SaaS companies and technology providers
  • organizations preparing for NIS2, KSC, ISO 27001, SOC 2, DORA or cyber insurance
  • companies that want to implement Zero Trust practically, without excessive theory and without buying tools blindly

Key takeaways

  1. Zero Trust is not a product, but a way to manage access and risk. Tools help, but they do not replace principles, processes and decisions.
  2. For SMEs, Zero Trust starts with the basics: MFA, strong identity, access reviews, least privilege, secure devices, backup and monitoring.
  3. The most important mindset change is: a company network, VPN or work laptop is not automatically trusted. Access must be checked in context.
  4. Zero Trust is especially important for remote work, cloud, Microsoft 365, Google Workspace, IT suppliers, administrator accounts and customer data.
  5. The best SME plan is staged implementation: first accounts and MFA, then permissions, devices, suppliers, applications, logs and time-bound access.

What is Zero Trust?

Zero Trust is a security approach where the company does not grant trust automatically. Every access request should be checked based on identity, device, application, location, risk, user role and resource type.

The simplest explanation:

Zero Trust does not mean you do not trust people as people. It means the system should not automatically trust any account, device or connection.

Example: an employee signs in to CRM. In a classic model, the company may assume that if the user knows the password and is on VPN, access is safe. In Zero Trust, the company asks more questions:

  • does the user have MFA?
  • are they signing in from a typical location?
  • is the device company-managed and updated?
  • does the user really need CRM access?
  • do they need all data, or only data for their region?
  • should the session be monitored?
  • should access expire after a defined time?

Zero Trust in one sentence

Zero Trust is a model where every access request is verified, permissions are minimal, risk is evaluated contextually and the company assumes that an account, device or network may be compromised.

What Zero Trust is not

Zero Trust is not one tool

You cannot buy “Zero Trust” as one product that solves everything. You can buy tools that support Zero Trust: MFA, Conditional Access, IAM, PAM, EDR, ZTNA, MDM, DLP, SIEM or CASB. But tools without rules and processes are not enough.

Zero Trust does not mean lack of trust in employees

Zero Trust is not a message that “we do not trust people”. It is a message that “we do not rely only on a password, network location or good intentions”. We protect employees and the company from the impact of account takeover, phishing, malware and mistakes.

Zero Trust does not mean blocking everything

Well-implemented Zero Trust should support work, not paralyze it. The goal is the right access for the right person, from the right device, to the right resource, at the right time.

Zero Trust does not replace backup and response

Zero Trust reduces access takeover risk, but it does not replace backup, incident response planning, training or ransomware recovery.

Why does an SME need Zero Trust?

Small and medium companies increasingly operate as distributed organizations: remote work, cloud, SaaS applications, external IT, suppliers, personal phones, cloud folders, business accounts used outside the office, integrations and automations.

In such an environment, the old “inside the network means safe” model no longer works. The company boundary is not only the office. Data is in Microsoft 365, Google Workspace, CRM, online accounting, cloud, laptops, phones and supplier applications.

Zero Trust helps SMEs reduce risks

  • email takeover through phishing
  • administrator account takeover
  • excessive access for former employees
  • supplier access after project completion
  • data leakage from cloud folders
  • ransomware spreading across the network
  • uncontrolled access from personal devices
  • lack of log visibility
  • excessive permissions in SaaS and cloud
  • misuse of service accounts or API tokens

Three main Zero Trust principles

1. Verify explicitly

The company should check access based on multiple signals, not only a password. Signals may include user, MFA, device, location, application, risk level and data type.

Examples:

  • require MFA for email and critical applications
  • require stronger MFA for administrators
  • block sign-ins from unusual countries if the company does not operate there
  • require a managed device for sensitive data
  • require additional verification for risky sign-ins

2. Use least privilege

The user should have only the access needed for work. Not “just in case”, not “because they needed it once”, not “because it is easier”.

Examples:

  • sales does not need access to all finance folders
  • a developer does not always need production access
  • a supplier should not have permanent VPN without an end date
  • an administrator should not have the highest role always active
  • a service account should not have administrator permissions if read access is enough

3. Assume breach

Zero Trust assumes that an account, device or network may be compromised. Therefore, the company should limit impact, monitor actions, segment access and have a response plan.

Examples:

  • log administrator actions
  • monitor unusual sign-ins
  • limit data access by role
  • protect backup from deletion by an attacker
  • maintain an incident response plan
  • review suppliers and external access

Zero Trust for SMEs: where to start?

Step 1: inventory users, devices, applications and data

You cannot implement Zero Trust if the company does not know who has access to what. The first step is a simple environment map.

List:

  • employees
  • administrators
  • guests and suppliers
  • service accounts
  • laptops and phones
  • SaaS applications
  • critical systems
  • customer data
  • shared folders
  • code repositories
  • cloud and hosting

Evidence to prepare: simple list of users, devices, applications, suppliers and critical data.

Step 2: enable MFA

MFA is the most important first Zero Trust step for SMEs. A password can be stolen, but MFA makes it harder to use the password alone to take over an account.

MFA should cover:

  • business email
  • Microsoft 365 or Google Workspace
  • administrators
  • banking
  • CRM and ERP
  • hosting and domain
  • VPN and remote access
  • code repositories
  • backup system
  • payment tools

Evidence to prepare: MFA report and list of accounts without MFA with plan to close exceptions.

Step 3: reduce administrators

Administrative accounts are the riskiest. If an attacker compromises a normal account, the impact may be limited. If they compromise an administrator, they may change configuration, add users, disable controls and access data.

Check:

  • how many global administrators exist
  • whether administrators have separate accounts
  • whether they have stronger MFA
  • whether roles are standing or time-bound
  • whether administrator actions are logged
  • whether emergency accounts exist

Evidence to prepare: administrator report and decisions to reduce roles.

Step 4: perform an access review

Zero Trust requires access to be justified and current. An access review shows who has access to data, applications and roles, and whether that access is still needed.

Review first:

  • administrators
  • former employees
  • guests and suppliers
  • customer data
  • finance and HR folders
  • backup
  • code repositories
  • cloud access control

Evidence to prepare: access review report with decisions: keep, reduce, remove, expire.

Step 5: secure devices

Zero Trust is not only about the user. The device is part of the decision too. A company laptop with updates and encryption is not the same as a personal computer without control.

Device minimum:

  • system and application updates
  • disk encryption
  • endpoint protection
  • screen lock
  • no local administrators where not needed
  • ability to remotely block or wipe a device
  • company device inventory

Evidence to prepare: device list, update status, encryption status and endpoint protection status.

Step 6: control remote access and VPN

VPN is not automatically secure. In many companies, VPN creates a false sense of security: once connected, the user has too much network access.

Check:

  • who has VPN access
  • whether VPN has MFA
  • whether suppliers have standing access
  • whether access is limited to specific systems
  • whether sessions are logged
  • whether some access can be replaced by application-level access or ZTNA

Evidence to prepare: remote access report and VPN user list.

Step 7: secure data and folders

Zero Trust should protect not only systems, but data. In SMEs, the biggest risk often involves cloud folders, customer files, contracts, HR data, finance and technical documentation.

Check:

  • which folders contain customer data
  • which links are public
  • who has access to finance data
  • who has access to HR data
  • whether access is granted through groups
  • whether sharing history exists
  • whether downloading or sharing sensitive data can be restricted

Evidence to prepare: review of access to sensitive data and sharing links.

Step 8: monitor sign-ins and actions

Zero Trust assumes that you must observe what is happening. Without logs, the company does not know whether an account was compromised, whether someone downloaded files or whether an administrator made an unusual change.

Minimum monitoring:

  • email and cloud sign-ins
  • unusual locations
  • administrator sign-ins
  • role and group changes
  • new account creation
  • email forwarding rules
  • public file sharing
  • backup changes

Evidence to prepare: list of log sources and basic high-risk alerts.

Step 9: control suppliers

Suppliers are part of the Zero Trust model. External IT, software house, agency, integrator or consultant should not have unlimited access only because they are a “trusted partner”.

Supplier rules:

  • named account instead of shared account
  • MFA
  • access only to required systems
  • access expiration date
  • system owner approval
  • session logging
  • access removal after project completion

Evidence to prepare: supplier register with access to systems and data.

Step 10: prepare incident response

Zero Trust limits incident impact, but it does not remove the need for response. The company should know what to do if an account is compromised, a laptop is lost, ransomware encrypts files or a supplier reports an incident.

Minimum:

  • incident response plan
  • account takeover playbook
  • ransomware playbook
  • emergency contact list
  • account blocking procedure
  • session revocation procedure
  • backup recovery procedure
  • customer and supplier communication procedure

Evidence to prepare: response plan and tabletop exercise report.

Zero Trust for SMEs: 12 practical actions

1. Enable MFA for everyone

Start with email, administrators, banking, CRM, cloud, hosting, domain, backup and financial systems.

2. Block legacy authentication

Legacy protocols and sign-in methods may bypass MFA. Check them especially in email and Microsoft 365.

3. Reduce administrators

Keep only the administrators who truly need the role. Use stronger MFA and reviews for high-risk roles.

4. Remove inactive accounts

Former employees, interns, contractors and suppliers should not remain in systems after cooperation ends.

5. Perform access reviews

Review access to customer data, finance, HR, backup, cloud and critical applications.

6. Organize devices

Device inventory, updates, encryption, endpoint protection and response to lost laptops are basic controls.

7. Limit public file sharing

Check public links, shared folders and guest access to cloud documents.

8. Control suppliers

A supplier should have a named account, MFA, access scope, owner and end date.

9. Protect backup

Backup should be separated, tested and protected from deletion by a compromised administrator account.

10. Monitor sign-ins and changes

Collect logs for sign-ins, role changes, mail rules, administrator actions and file sharing.

11. Prepare an account takeover playbook

The most common SME Zero Trust scenario is a compromised account. The company must quickly block the account, revoke sessions and check access scope.

12. Review quarterly

Zero Trust is not a one-time project. Every quarter, check MFA, accounts, administrators, guests, suppliers, devices, backup and logs.

Zero Trust and Microsoft 365 or Google Workspace

For many SMEs, Zero Trust starts in Microsoft 365 or Google Workspace. This is where email, files, meetings, identities, guests and applications live.

What to check in Microsoft 365?

  • whether all users have MFA
  • how many Global Administrators exist
  • whether administrators have stronger MFA
  • whether legacy authentication is blocked
  • whether Conditional Access is configured
  • whether guests have owners
  • whether SharePoint and OneDrive have public links
  • whether email forwarding rules exist
  • whether applications have excessive data permissions
  • whether logs are available and reviewed

What to check in Google Workspace?

  • whether two-step verification is enforced
  • who has administrator roles
  • whether former employee accounts are blocked
  • whether file sharing is controlled
  • whether external applications have data access
  • whether access to the admin panel is limited
  • whether security logs are monitored
  • whether mobile devices are managed

Zero Trust and cloud

In cloud, Zero Trust means that access to resources should not be standing, excessive or based on long-term keys without control.

In Azure, AWS and Google Cloud, check

  • administrator accounts
  • owner and contributor roles
  • access keys
  • service accounts
  • public access to storage
  • cross-account or cross-project access
  • permissions to logs and backup
  • permissions to secrets
  • unusual custom roles

Zero Trust principles in cloud

  • grant least privilege
  • avoid static keys where time-bound roles can be used
  • monitor unused permissions
  • protect logs against modification
  • protect backup against deletion
  • review IAM regularly

Zero Trust and IT suppliers

In SMEs, the IT supplier often has broad access to email, devices, servers, backup, cloud and business systems. This is convenient, but risky.

Minimum supplier requirements

  • named account for each person
  • MFA
  • no shared administrator passwords
  • access only to required systems
  • approval for high-risk access
  • action logging
  • access end date
  • incident notification obligation
  • access removal after cooperation ends

Zero Trust and backup

Backup is part of Zero Trust thinking because you assume an account, server or network may be compromised. An attacker may try to delete or encrypt backups.

Backup in a Zero Trust model should have

  • separate permissions
  • separate backup administrator accounts
  • MFA
  • deletion protection
  • version history
  • recovery test
  • change logs
  • emergency recovery procedure

The most important rule: a person who can manage normal systems should not automatically be able to delete all backups.

What documents and evidence should be prepared?

Basic documents

  • critical systems and data list
  • user and administrator list
  • device list
  • supplier access list
  • access policy
  • access review procedure
  • onboarding and offboarding procedure
  • incident response plan

Technical evidence

  • MFA report
  • accounts without MFA report
  • administrator report
  • access review report
  • device and health status report
  • public file link report
  • supplier access report
  • backup and recovery test report
  • log and alert report

Decision evidence

  • decisions to keep, reduce or remove access
  • exception approvals
  • supplier access decisions
  • administrator role decisions
  • residual risk acceptances
  • 12-month Zero Trust roadmap

30, 60 and 90-day action plan

First 30 days

  • assign Zero Trust programme owner
  • prepare user, administrator, supplier and system list
  • enable MFA for email, administrators, banking and critical systems
  • remove former employee accounts
  • check guest and supplier accounts
  • check administrator count
  • check backup and latest recovery test
  • prepare the first access risk list

Days 31 to 60

  • enable MFA for remaining accounts
  • reduce administrators
  • perform the first access review
  • secure company devices
  • check public file links and shares
  • review supplier access
  • configure basic sign-in and administrator action alerts
  • prepare account takeover playbook

Days 61 to 90

  • prepare Zero Trust report for the board
  • implement recurring access review
  • define time-bound access rules for administrators and suppliers
  • test backup recovery
  • run an account takeover tabletop exercise
  • update access policy and offboarding procedure
  • prepare the next 12-month roadmap
  • decide whether the company needs PAM, ZTNA, MDM, EDR or vCISO

Common Zero Trust mistakes in SMEs

Mistake 1: buying a tool without a process

A tool can help, but without an owner, policies, access review and evidence, the company does not implement Zero Trust. It only buys another license.

Mistake 2: treating VPN as complete security

VPN gives network access, but it does not always limit access to specific applications and data. VPN without MFA, segmentation and logging may increase risk.

Mistake 3: MFA only for some accounts

The attacker chooses the weakest account. MFA should cover everyone, and administrators should have stronger protection.

Mistake 4: ignoring suppliers

Suppliers often have more access than employees. Lack of supplier control contradicts practical Zero Trust.

Mistake 5: no access review

Zero Trust without regular access review becomes outdated quickly. Permissions accumulate and stop matching real duties.

Mistake 6: no logs

If the company has no logs, it does not know whether Zero Trust works. It also does not know what happened after account takeover.

Mistake 7: starting too ambitiously

An SME does not need to start with a full enterprise architecture. It is better to implement 10 basic controls than plan a perfect model for a year.

Mistake 8: no employee communication

Zero Trust changes sign-in and access. Employees should understand that additional verification protects their work, customers and the company.

How to measure Zero Trust progress?

Identity metrics

  • percentage of accounts with MFA
  • number of accounts without MFA
  • number of administrators
  • number of inactive accounts
  • number of guests without owner
  • number of service accounts without owner

Access metrics

  • number of systems covered by access review
  • number of removed permissions
  • number of reduced permissions
  • number of supplier accesses with end date
  • number of access policy exceptions

Device metrics

  • number of inventoried devices
  • percentage of devices with updates
  • percentage of devices with disk encryption
  • percentage of devices with endpoint protection
  • number of devices without owner

Monitoring and response metrics

  • number of log sources
  • number of high-risk alerts
  • time to block a compromised account
  • time to revoke active sessions
  • date of latest tabletop exercise

Business example

A services company has 45 employees. It uses Microsoft 365, CRM, online accounting, cloud drive, external IT provider and several SaaS applications. The company has VPN and believes that access is secure because of it.

After a short review, it turns out that MFA works only for some users, there are five Global Administrators, two former suppliers still have guest accounts, public file links have been active for months and backup can be deleted by the same administrator who manages Microsoft 365.

The company does not start with a large project. In the first 30 days, it enables MFA, removes old accounts, reduces administrators and checks backup. In the next 60 days, it performs access review, organizes supplier access, secures devices and enables alerts for unusual sign-ins. After 90 days, it has the first Zero Trust dashboard for the board.

The result: the company still uses the same tools, but access is better controlled. One account takeover no longer gives such broad access, suppliers do not have standing permissions, and the board sees measurable progress.

How can ccyber.io help?

ccyber.io helps SMEs implement Zero Trust in a practical and staged way. We do not start from theory or tool purchasing. We start from what reduces risk the most: MFA, accounts, administrators, permissions, suppliers, devices, backup and logs.

We can support your organization with:

  • Zero Trust readiness assessment
  • Microsoft 365 Zero Trust baseline
  • Google Workspace security review
  • MFA implementation
  • Conditional Access review
  • access review
  • PAM assessment
  • supplier access review
  • device security baseline
  • backup and recovery review
  • incident response playbooks
  • 30, 60, 90-day and 12-month Zero Trust roadmap
  • board dashboard

The best first step is a Zero Trust Discovery Workshop. In a short workshop, the company can identify the biggest access risks, critical accounts and systems, quick actions and a realistic roadmap without wasting budget.

FAQ

Does Zero Trust make sense for a small company?

Yes. A small company also uses email, cloud, suppliers, laptops, CRM and customer data. Zero Trust helps reduce the impact of account takeover, phishing, ransomware and excessive permissions.

Does Zero Trust require expensive tools?

Not at the start. Many actions can begin with features already available in Microsoft 365, Google Workspace, cloud and endpoint tools. First organize rules, accounts and access.

Where should an SME start with Zero Trust?

Start with MFA, a list of users and administrators, inactive account removal, access review, supplier control, backup and basic logs.

Is VPN enough as Zero Trust?

No. VPN can be part of remote access, but it does not equal Zero Trust. MFA, access limitation, policies, logs, device control and access reviews are needed.

How is Zero Trust different from traditional security?

The traditional model often trusted the internal network. Zero Trust assumes the network may be untrusted, and every access should be verified and limited.

Does Zero Trust replace backup?

No. Zero Trust reduces access risk, but backup is still needed for ransomware, outages, human error or data loss.

How should Zero Trust implementation be measured?

Measure MFA, administrator count, inactive accounts, access reviews, supplier access, device health, logs, backup and response time for compromised accounts.

Does Zero Trust help with audits?

Yes. Zero Trust provides practical evidence for ISO 27001, SOC 2, NIS2, DORA, cyber insurance and enterprise customers: MFA, access review, logs, supplier control, backup, monitoring and board decisions.

Summary

Zero Trust for SMEs does not have to be a complex enterprise project. The simplest rule is: do not automatically trust an account, device, network or supplier. Verify access, limit permissions, monitor actions and prepare incident response.

The best start is MFA, administrator review, inactive account removal, access review, supplier control, device security, backup and logs. These actions can be implemented in stages and materially reduce risk.

Zero Trust is not about making work harder. It is about ensuring that the right people have the right access at the right time, and that one account takeover does not mean takeover of the entire company.

Sources

How to Perform an Access Review in a Company?

An access review checks who has access to which systems, data, applications, administrative roles, service accounts and cloud resources, and whether that access is still needed. A good review ends with a decision: keep, reduce, remove, expire or move access into an approval process.

Prepared by: CCyber Editorial Team

Short answer

An access review should answer one question: does every person, technical account, application, supplier and administrator have exactly the access they still need to work? The simplest process is: prepare the system list, export users and roles, assign business owners, assess access by risk, make decisions, remove unnecessary permissions and keep evidence. A good access review is not only an IT report. It is a business control that reduces the risk of account takeover, data leakage, ransomware, administrator misuse and audit findings.

Last updated

July 2026

Who this article is for

  • boards and business owners
  • CISOs, vCISOs, CTOs and IT directors
  • Microsoft 365, Google Workspace, Azure, AWS and Google Cloud administrators
  • IAM, PAM, compliance and audit owners
  • SMEs that want to organize access without a large security team
  • companies preparing for ISO 27001, SOC 2, NIS2, KSC, DORA or cyber insurance
  • software houses, SaaS companies and IT providers
  • companies after account takeover, data leakage or departure of a key employee
  • organizations with many suppliers, guests, administrators, service accounts or SaaS applications

Key takeaways

  1. An access review is not about sending an Excel file to IT. The business system owner must confirm who really needs access.
  2. Review high-risk access first: administrators, service accounts, suppliers, cloud, backup, finance, HR, CRM, code repositories and systems with customer data.
  3. Every access should have an owner, justification, scope, review date and decision: keep, reduce, remove, expire or move to time-bound access.
  4. The most common risks are excessive permissions, inactive accounts, former employees, guests, shared accounts, standing administrator roles and service accounts without owners.
  5. Auditors will expect evidence: review scope, user list, owner decisions, removed permissions, exceptions, risk acceptance and final report.

What is an access review?

An access review is a control that checks whether users, administrators, suppliers, applications and technical accounts still have justified access to company systems, data and resources. The goal is to remove access that is no longer needed and reduce access that is too broad.

An access review should answer:

  • who has access?
  • what do they have access to?
  • why do they have this access?
  • who approved the access?
  • is the access still needed?
  • is the access excessive?
  • does the account have MFA?
  • should access be removed, reduced or kept?
  • was the decision documented?

Simply put: an access review is access hygiene. Just as a company periodically checks finances, contracts and suppliers, it should periodically check who has access to data and systems.

Why is an access review important?

Access grows over time. An employee changes team, receives new roles, replaces someone in a project, tests an application, helps during an outage, and old permissions remain. After months or years, many people have more access than they actually need.

This creates risk:

  • a compromised account has a larger attack scope
  • a former employee may retain access
  • a supplier keeps access after the project ends
  • an employee sees data they should not see
  • an administrator has standing privileges without need
  • a service account has excessive permissions
  • an audit shows lack of access control
  • a data leak affects a larger scope than necessary

An access review reduces the attack surface. It does not prevent every incident, but it limits the impact of account takeover, human error and access misuse.

When should a company perform access reviews?

Frequency depends on risk. Critical systems and administrative roles should be reviewed more often than supporting applications.

Minimum frequency

  • administrators and privileged roles: monthly or quarterly
  • systems with customer data: quarterly
  • finance and HR systems: quarterly
  • code repositories and CI/CD: quarterly
  • external suppliers: quarterly or after project completion
  • SaaS applications: semiannually or annually
  • guests and external accounts: monthly or quarterly
  • service accounts and secrets: quarterly or after system changes

Out-of-cycle review

Access should also be reviewed after events such as:

  • employee departure
  • role or team change
  • project completion
  • IT supplier change
  • account takeover incident
  • data leakage
  • new system deployment
  • audit preparation
  • organizational change
  • cloud migration

What should be included in an access review?

1. Employee accounts

Review active employees, their roles, groups, applications and data access. Pay special attention to people who changed job, team or project.

2. Former employee accounts

A former employee should not have active access to email, cloud, CRM, repositories, VPN, social media, domain, hosting panel or SaaS applications.

3. Guest and partner accounts

Guests in Microsoft 365, Google Workspace, Slack, Teams, SharePoint, GitHub, Jira or CRM often remain after cooperation ends. This is a common audit issue.

4. External suppliers

IT providers, software houses, agencies, integrators, accountants, consultants and support providers should have access only to what they need, only during cooperation and only through controlled accounts.

5. Administrators

Administrator accounts are the riskiest. Review Global Administrators, cloud administrators, domain administrators, backup administrators, database administrators, repository owners and people who can grant access to others.

6. Groups and roles

Do not review only users. Many permissions come from groups. Check who is in high-risk groups and whether groups are assigned to overly broad roles.

7. Service accounts

Service accounts, service principals, applications, bots, integrations, API tokens and automations may have broad permissions. Often nobody knows who owns them.

8. SaaS applications

Review CRM, ERP, accounting, HR, project tools, marketing automation, helpdesk, electronic signature, cloud drives, AI tools and communication tools.

9. Cloud and infrastructure

In Azure, AWS and Google Cloud, review subscription owners, IAM roles, groups, technical accounts, access keys, public access, cross-account access and data permissions.

10. Data and folders

Review access to folders with contracts, customer data, financial documentation, HR, source code, backup, technical documentation and strategic information.

How to perform an access review step by step?

Step 1: define review scope

First define what exactly you are reviewing. Do not try to review everything at once if the company has never done it before. Start with highest-risk systems.

Scope may include:

  • Microsoft 365 or Google Workspace
  • Azure, AWS or Google Cloud
  • CRM
  • ERP
  • finance system
  • HR system
  • code repositories
  • CI/CD
  • backup
  • VPN
  • production systems
  • folders with customer data

Evidence to prepare: access review scope card.

Step 2: assign system owners

IT can prepare user exports, but it does not always know who truly needs access from a business perspective. The system owner or data owner should make the decision.

Example owners:

  • CRM: sales director
  • finance system: CFO or chief accountant
  • HR: HR manager
  • code repositories: CTO or engineering manager
  • Microsoft 365: IT manager or IT process owner
  • customer folders: customer support leader
  • backup: IT manager or business continuity owner

Evidence to prepare: system list with business and technical owners.

Step 3: export current access state

Prepare a list of users, groups, roles, technical accounts and applications. Without the current state, there is no reliable review.

The export should include:

  • user or account
  • email address or ID
  • department
  • manager
  • system
  • role or group
  • permission level
  • last login date if available
  • MFA status where relevant
  • account type: employee, guest, supplier, administrator, service account

Evidence to prepare: access state export as of the review start date.

Step 4: mark high-risk access

Not every access has the same priority. Start with permissions whose misuse can cause the greatest harm.

High-risk access

  • Global Administrator
  • cloud subscription owner
  • backup administrator
  • email administrator
  • finance system administrator
  • access to customer data
  • access to HR data
  • production access
  • code repository access
  • access to secrets, keys and tokens
  • external supplier access
  • roles that allow granting permissions to others

Evidence to prepare: high-risk access list.

Step 5: prepare decision criteria

The system owner must know how to assess access. Without criteria, the review becomes subjective: “let’s keep it, maybe it will be useful”.

Criteria to keep access

  • the user still works in the role
  • access is needed for current duties
  • access has a business owner
  • permission level matches the role
  • access is protected by MFA where relevant

Criteria to reduce access

  • the user only needs read access
  • the user does not need an administrator role
  • the group grants excessive permissions
  • access should be time-bound
  • access should require approval

Criteria to remove access

  • the user left the company
  • the user changed role
  • the supplier finished the project
  • the account is inactive
  • there is no access owner
  • there is no business justification
  • the account is shared and uncontrolled

Evidence to prepare: access assessment rules and decision criteria.

Step 6: run the review with owners

System owners should confirm access. Ideally, each decision has a status and comment.

Possible decisions

  • keep unchanged
  • keep with justification
  • reduce
  • remove
  • expire on a specified date
  • move to time-bound access
  • requires further explanation
  • risk acceptance by owner

If the owner does not respond, do not leave it without a process. Define a rule: manager escalation, reminder, default decision for high-risk access or temporary block until clarified.

Evidence to prepare: system owner decision sheet.

Step 7: implement changes

A review without implemented changes has little value. After decisions, access must actually be removed, reduced or changed.

Document:

  • who made the change
  • when the change was made
  • in which system
  • which access was removed or reduced
  • whether the user was informed
  • whether the change was confirmed by the owner

Evidence to prepare: register of changes made after the review.

Step 8: handle exceptions

Not every access can be removed immediately. Sometimes an exception is needed, but exceptions must be controlled.

An exception should have:

  • justification
  • owner
  • expiration date
  • risk
  • compensating controls
  • approval by the right person
  • next review date

Evidence to prepare: access exception register.

Step 9: prepare the final report

The final report shows that the review was performed and produced results. It is a key document for audit, board, customer or insurer.

The report should include:

  • review scope
  • review date
  • systems in scope
  • number of users
  • number of roles and groups
  • number of accesses kept
  • number of accesses removed
  • number of accesses reduced
  • number of exceptions
  • top risks
  • remediation actions
  • owners and deadlines

Evidence to prepare: final access review report.

Step 10: schedule the next review

An access review should not be a one-time project before an audit. It is a recurring control. After the first review, schedule the next ones.

Evidence to prepare: recurring access review schedule.

How to review access in Microsoft 365?

In Microsoft 365, administrative roles, groups, guests, SharePoint, Teams, Exchange, enterprise applications and access to sensitive data are especially important.

Check

  • Global Administrators
  • Exchange Administrators
  • SharePoint Administrators
  • Security Administrators
  • users without MFA
  • external guests
  • groups with access to customer data
  • public sharing links
  • email forwarding rules
  • applications with access to data
  • inactive accounts

Decisions

  • reduce Global Administrators
  • enable stronger MFA for administrators
  • remove guests without active business need
  • limit public file sharing
  • remove inactive accounts
  • move administrative roles to time-bound access where the company has that capability

How to review cloud permissions?

In cloud environments, access is often more complex than in office applications. Roles may be assigned at organization, account, subscription, project, resource, group or policy level.

In Azure, check

  • Owner
  • Contributor
  • User Access Administrator
  • Global Administrator
  • Privileged Role Administrator
  • roles assigned to groups
  • service principals
  • managed identities
  • applications with broad permissions

In AWS, check

  • root account
  • IAM users
  • IAM roles
  • policies with administrator permissions
  • access keys
  • unused credentials
  • cross-account access
  • public resource access
  • permissions to S3, IAM, KMS, CloudTrail and backup

In Google Cloud, check

  • Owner
  • Editor
  • IAM Admin
  • service accounts
  • service account keys
  • roles at organization, folder and project levels
  • access to BigQuery, Cloud Storage and Secret Manager
  • public or external access to resources

Key cloud principles

  • avoid standing broad privileges where not needed
  • limit access according to least privilege
  • prefer time-bound roles over long-term keys
  • regularly remove unused roles and credentials
  • monitor public and cross-account access
  • protect logs and backups from deletion by attackers

How to review service accounts?

Service accounts are often harder than human accounts. Nobody logs in manually, but applications, integrations, scripts and automations use them to work. They may have broad permissions and passwords that have not been rotated for years.

Check for each service account

  • what it is used for
  • who the business owner is
  • who the technical owner is
  • which permissions it has
  • when it was last used
  • where credentials are stored
  • whether the secret is rotated
  • whether the account has administrator permissions
  • whether access is logged
  • what will happen if the account is disabled

Decisions

  • remove unused account
  • reduce permissions
  • move secret to vault
  • implement secret rotation
  • replace account with time-bound role or managed identity
  • add owner and next review date

Evidence to prepare: service account, secret and owner register.

How to review supplier access?

Suppliers often have access to systems, data and production environments. Supplier access review should be part of access review, especially when the company uses outsourced IT, MSPs, software houses, accountants, marketing agencies, consultants or integrators.

Check

  • which supplier has access
  • to which system
  • what the access purpose is
  • whether the access is named
  • whether access has MFA
  • whether access expires after work ends
  • whether sessions are logged or recorded
  • whether the supplier uses a shared account
  • whether the contract defines access and incident rules
  • who approves supplier access in the company

Decisions

  • remove access for ended suppliers
  • expire access after end date
  • enforce MFA
  • replace shared account with named account
  • limit access to specific systems
  • introduce approval for high-risk access

Evidence to prepare: supplier access register and owner decisions.

What documents and evidence should be prepared?

Basic documents

  • access review procedure
  • review schedule
  • review scope
  • system and owner list
  • decision criteria
  • role matrix
  • exception register

Technical evidence

  • user export
  • group export
  • administrative role export
  • MFA report
  • last login report
  • inactive account report
  • guest account report
  • service account report
  • applications with data access report

Decision evidence

  • system owner decisions
  • justifications for kept access
  • list of removed access
  • list of reduced access
  • list of time-bound access
  • risk acceptances
  • no-response escalations

Implementation evidence

  • permission removal confirmations
  • role change confirmations
  • service tickets
  • administrative change logs
  • owner confirmations
  • final report

Common access review mistakes

Mistake 1: IT performs the review alone

IT can prepare data and implement changes, but the business owner should confirm who really needs access.

Mistake 2: decisions are not implemented

The company performs a review but does not remove permissions. This creates a false sense of control and weak audit evidence.

Mistake 3: keeping access “just in case”

Access that may be useful someday should usually be removed and granted again after approval if a real need appears.

Mistake 4: no guest account review

Guests and partners often remain in systems long after cooperation ends. This is an easy-to-fix gap.

Mistake 5: ignoring service accounts

Service accounts may have more permissions than humans. Without an owner and secret rotation, they create high risk.

Mistake 6: no prioritization

Reviewing a low-risk support application is less urgent than reviewing administrators, backup, cloud, finance and customer data.

Mistake 7: no evidence

The auditor will ask not only whether the review happened, but also who made decisions, what changed and which exceptions were accepted.

Mistake 8: no recurring process

A one-time review before an audit helps only briefly. Access must be reviewed regularly because the organization changes constantly.

30, 60 and 90-day action plan

First 30 days

  • assign access review process owner
  • prepare system and owner list
  • select 3-5 high-risk systems
  • export users, groups and roles
  • check administrators and accounts without MFA
  • check inactive accounts and former employee accounts
  • prepare decision criteria
  • remove the most obvious gaps: former employees, inactive guests, unnecessary administrators

Days 31 to 60

  • run reviews with system owners
  • review access to customer data, finance and HR
  • review supplier access
  • review service accounts and secrets
  • reduce administrator roles
  • remove or reduce approved access
  • prepare exception register
  • prepare the first final report

Days 61 to 90

  • implement recurring review schedule
  • automate exports where possible
  • prepare access review dashboard for board or IT
  • define review process for role changes
  • connect access review with onboarding and offboarding
  • prepare access review procedure for audit
  • decide which roles should become time-bound access
  • schedule the next review for the next quarter

How to measure access review effectiveness?

Scope metrics

  • number of systems in review scope
  • number of users reviewed
  • number of roles and groups reviewed
  • number of service accounts reviewed
  • number of suppliers reviewed

Risk metrics

  • number of administrators
  • number of accounts without MFA
  • number of inactive accounts
  • number of guest accounts without owner
  • number of service accounts without owner
  • number of high-risk roles

Decision metrics

  • number of accesses kept
  • number of accesses removed
  • number of accesses reduced
  • number of exceptions
  • number of decisions without owner response
  • time to close decisions

Audit metrics

  • number of reviews completed according to schedule
  • number of missing evidence items
  • number of overdue actions
  • time to prepare audit report
  • number of audit findings related to access

Business example

A services company has 80 employees and uses Microsoft 365, CRM, finance system, code repositories, Azure cloud and an external IT provider. Access reviews were performed only before audits, manually and without business owners.

The first real review shows that Microsoft 365 has six Global Administrators, two former suppliers still have guest accounts, the sales team has access to a folder with financial contracts, and a CRM integration service account has administrator permissions without an owner. Some users also have access to projects they have not worked on for over a year.

The company implements a simple process. IT prepares exports, system owners make decisions, and security maintains an exception register and final report. Within 60 days, the company removes former supplier access, reduces administrators, removes inactive accounts, cleans up groups and assigns owners to service accounts.

The result: fewer high-risk accounts, better audit evidence, lower data leakage risk and easier answers to enterprise customer questions. Access review becomes a quarterly control, not an emergency action before audit.

How can ccyber.io help?

ccyber.io helps companies perform practical access reviews across Microsoft 365, Google Workspace, cloud, SaaS applications, critical systems and external supplier environments. We combine IAM, PAM, cloud security, compliance and audit perspectives.

We can support your organization with:

  • access review assessment
  • Microsoft 365 access review
  • Google Workspace access review
  • Azure, AWS and Google Cloud IAM review
  • administrator review
  • service account and secret review
  • supplier access review
  • role and permission matrix
  • recurring access review procedure
  • report for ISO 27001, SOC 2, NIS2, DORA, cyber insurance or enterprise customer
  • 30, 60, 90-day and 12-month IAM and PAM roadmap

The best first step is an Access Review Discovery Workshop. In a short workshop, the company can determine which systems carry the highest risk, who should own decisions, which data must be exported and how to run the first review without chaos.

FAQ

What is an access review?

It is a process that checks who has access to systems, data, applications and roles, and whether that access is still needed and aligned with the user’s role.

How often should access reviews be performed?

High-risk access such as administrators, suppliers, customer data, backup and cloud should be reviewed monthly or quarterly. Other applications can be reviewed semiannually or annually depending on risk.

Who should approve access?

Ideally, the system owner or data owner. IT can prepare the report and implement changes, but the business decision should belong to the person responsible for the process.

Is access review required in audits?

Often yes. ISO 27001, SOC 2, NIS2, DORA, cyber insurance and customer requirements often expect access control, regular reviews and evidence of unnecessary permissions removed.

Where should a company start if it has never done a review?

Start with administrators, former employee accounts, guests, suppliers, Microsoft 365 or Google Workspace, backup, finance, CRM and customer data.

Should service accounts be reviewed too?

Yes. Service accounts often have broad permissions and unclear owners. They should have an owner, justification, permission scope, secret rotation and next review date.

What should be done if the owner does not confirm access?

Define an escalation rule. For high-risk access, lack of confirmation should not automatically mean keeping access unchanged.

What evidence should be kept after the review?

Keep review scope, user and role exports, owner decisions, change list, exception register, access removal confirmations and final report.

Summary

Access review is one of the most important controls in identity, access and cloud security. It helps verify whether employees, administrators, suppliers, applications and service accounts still have access they truly need.

The best review starts with high-risk systems: administrators, cloud, backup, customer data, finance, HR, code repositories and suppliers. Then it requires owner decisions, implemented changes and retained evidence.

A company that regularly reviews access reduces the risk of account takeover, data leakage, access misuse and audit findings. The key is to make the review a recurring risk management process, not a one-time action before an audit.

Sources

How to Prepare Your Company for a Post-Incident Audit?

A post-incident audit checks not only what happened, but also how the company responded, what evidence was preserved, which decisions were made, whether data and customer impact were assessed correctly, and whether remediation actions were implemented. Preparation starts with the incident timeline, decision log, technical reports, data breach assessment, communications, backups, logs and improvement plan.

Prepared by: CCyber Editorial Team

Short answer

A company prepares for a post-incident audit by organizing facts, evidence, decisions and remediation actions. An auditor, customer, insurer, regulator or board will want to see when the incident was detected, what the scope was, which systems and data were affected, who made decisions, what actions were taken, whether logs were preserved, whether data breach impact was assessed, whether communication was controlled and whether the company implemented fixes. The most important documents are the incident timeline, decision log, technical reports, data impact assessment, recovery report, communications, notification evidence, post-incident review and remediation plan.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • CISOs, vCISOs, CTOs and IT directors
  • security, compliance, risk and audit leaders
  • companies after ransomware, phishing, account takeover or data breach incidents
  • SMEs using IT providers, cloud, Microsoft 365, Google Workspace, CRM or ERP
  • software houses and SaaS companies
  • companies preparing evidence for a customer, regulator, auditor or cyber insurer
  • organizations preparing for NIS2, KSC, DORA, ISO 27001, SOC 2 or customer audit

Key takeaways

  1. A post-incident audit does not start after the incident is closed. It starts in the first minutes of response, when the company records decisions, actions, evidence and people involved.
  2. The most important evidence includes the timeline, logs, message copies, technical report, affected systems list, board decisions, data breach assessment and remediation actions.
  3. The company should separate facts from assumptions. During an audit, it must show what is known, what is unknown, what was checked and what the analysis limitations are.
  4. If the incident affected personal data, the company must document GDPR assessment, the decision to notify or not notify, and any communication to affected individuals.
  5. The best post-incident audit result is not only a report, but an improvement plan: action owners, deadlines, priorities, budget and evidence of closed gaps.

What is a post-incident audit?

A post-incident audit is a review of facts, decisions, impact and remediation actions after a cyber incident. It may be performed internally by the company, by a customer, auditor, insurer, regulator or external cybersecurity team.

The audit may cover many questions:

  • what exactly happened?
  • when did the company detect the incident?
  • when might the incident have actually started?
  • which systems, accounts and data were affected?
  • were customer data or personal data at risk?
  • how did the company contain impact?
  • were actions aligned with procedures?
  • was evidence preserved?
  • were the right parties notified?
  • could the company recover operations?
  • what was improved after the incident?

A post-incident audit should not be about blaming people. It should be a controlled way to establish facts, close gaps and show that the company manages the situation responsibly.

Who may perform a post-incident audit?

Board

The board may request a post-incident report to understand the impact on operations, customers, finances, risk and reputation. This report should be business-focused, not only technical.

Customer

A customer may request evidence if the incident may have affected its data, service, integration, availability or contractual requirements. In B2B relationships, a post-incident audit often also checks whether contractual notification duties were met.

Insurer

A cyber insurer may require documentation of the event, costs, decisions, loss scope and evidence that the company met policy conditions such as MFA, backups, updates or an incident response plan.

Regulator

A regulator may expect information on a data breach, service security, incident notification, remediation actions and compliance evidence. This is especially relevant for GDPR, NIS2, KSC, DORA or sector rules.

Internal or external auditor

An auditor may assess whether the company responded according to procedures, whether controls worked, whether evidence is complete and whether remediation actions were implemented.

The key rule: document from the first hour

The worst time to build evidence is one week after the incident. By then, some logs may be overwritten, people do not remember exact decisions, communication is scattered, and the team tries to reconstruct the timeline from messages and memory.

From the start, maintain:

  • incident timeline
  • decision log
  • technical action log
  • list of people involved
  • list of evidence sources
  • list of missing data and analysis limitations
  • copies of key communications
  • list of systems, accounts and data affected by the incident

Evidence to prepare: central incident register maintained from the first report to closure of remediation actions.

How to prepare for a post-incident audit step by step?

Step 1: define audit scope

First determine what the audit concerns. An audit for a customer, insurer, regulator and board each requires a different preparation.

Determine:

  • who is performing the audit?
  • what is the audit objective?
  • which period is covered?
  • which systems are in scope?
  • which data is in scope?
  • does the audit include suppliers?
  • does the audit include contractual compliance?
  • does the audit include GDPR, NIS2, KSC, DORA, ISO 27001 or SOC 2?

Evidence to prepare: post-incident audit scope card.

Step 2: prepare the incident timeline

The timeline is the most important post-incident document. It shows what happened in sequence and when the company took action.

The timeline should include:

  • first possible compromise time
  • first detected signal
  • incident reporting time
  • incident classification time
  • escalation to the board
  • start of technical actions
  • containment actions
  • account resets or system isolation
  • supplier contact
  • contact with legal, customer, insurer or regulator
  • business recovery time
  • incident closure time

The timeline should clearly separate facts from hypotheses. If something is unknown, mark it as undetermined instead of filling gaps with assumptions.

Evidence to prepare: incident timeline with times, information sources and owner for each entry.

Step 3: preserve technical evidence

Technical evidence is the foundation for establishing what happened. It may also be needed for customers, insurers, regulators or law enforcement.

Typical technical evidence:

  • login logs
  • email logs
  • email headers
  • VPN and remote access logs
  • Microsoft 365 or Google Workspace logs
  • Active Directory or Entra ID logs
  • EDR or antivirus logs
  • firewall and proxy logs
  • DNS logs
  • cloud system logs
  • application logs
  • screenshots
  • copies of malicious files where safe to preserve
  • disk images or selected artifacts where required

Do not delete or overwrite evidence without consulting the person leading the analysis. In a serious incident, determine whether evidence must be preserved in a form suitable for legal proceedings.

Evidence to prepare: evidence register with location, date, owner and file integrity where used.

Step 4: prepare the technical report

The technical report should explain what is known based on evidence. It does not need to use board language, but it should include a business summary.

The technical report should cover:

  • incident type
  • entry point, if determined
  • affected accounts
  • affected devices
  • affected systems
  • affected data
  • attacker actions
  • indicators of compromise
  • analysis scope
  • data sources
  • analysis limitations
  • containment actions
  • remediation actions
  • conclusions and recommendations

If the report goes to a customer or regulator, remove information that could unnecessarily disclose sensitive security details or data of other parties. The external version should be reviewed by legal, compliance and communications owners.

Evidence to prepare: technical report and board or customer version where needed.

Step 5: prepare data impact assessment

If the incident may have affected personal data, customer data, trade secrets, financial data or contract-protected data, a separate data impact assessment is needed.

The assessment should determine:

  • which data categories were within incident scope
  • whether data was only at risk or actually disclosed
  • whether data may have been downloaded
  • how many customers, employees or users may be affected
  • whether data was encrypted or protected
  • whether logs confirm or exclude access
  • what consequences may affect individuals or customers
  • whether notification to a supervisory authority is required
  • whether affected individuals or customers must be notified

Under GDPR, the company must document the facts, effects and remedial actions. If the company decides notification is not required, that decision should also be documented.

Evidence to prepare: data breach assessment and decision to notify or not notify.

Step 6: prepare the decision log

A post-incident audit often checks whether decisions were conscious, documented and made by the right people. Lack of written decisions is a problem, especially when explaining why a system was shut down, why backup was not restored immediately or why a customer was informed at a specific time.

The decision log should include:

  • date and time of decision
  • decision maker
  • decision description
  • justification
  • available information at the time of decision
  • risks of alternatives
  • people consulted
  • decision outcome

Evidence to prepare: crisis decision log.

Step 7: organize communication

The audit may cover internal communication, customer communication, supplier communication, insurer communication, legal, regulator or media communication.

Collect:

  • employee communications
  • customer communications
  • supplier communications
  • insurer notifications
  • CERT or CSIRT notifications if made
  • data protection authority notifications if made
  • answers to customer questions
  • crisis meeting notes
  • message approvals

Communication should be consistent with facts. Do not state that no data was leaked if the company does not yet have evidence. It is better to say what is confirmed, what is being investigated and what actions were taken.

Evidence to prepare: post-incident communication register and approved message versions.

Step 8: show containment and remediation actions

The auditor will want to know whether the company only analyzed the incident or actually limited its impact.

Example actions:

  • account block
  • password reset
  • active session revocation
  • device isolation
  • system network disconnection
  • domain or IP block
  • email forwarding rule removal
  • suspicious payment stop
  • backup protection
  • supplier access suspension
  • additional monitoring enabled

For each action, keep date, person, system and execution evidence.

Evidence to prepare: containment, remediation and recovery action log.

Step 9: document business recovery

If the incident affected system availability, the audit will ask how the company returned to operation. A statement like “we restored the system” is not enough.

Document:

  • which systems were unavailable
  • how long downtime lasted
  • which backup was used
  • whether the backup was confirmed clean
  • who approved returning the system
  • whether recovered data was complete
  • which functions worked in emergency mode
  • which problems appeared during recovery
  • which remediation actions resulted from the test or real recovery

Evidence to prepare: business recovery report and confirmation that systems returned to operation.

Step 10: prepare the post-incident review

The post-incident review should answer what the company learned and what will change. It is one of the most important audit elements because it shows that the organization not only survived the incident, but improves resilience.

The review should cover:

  • what happened
  • why it happened
  • what worked well
  • what did not work well
  • which data was missing
  • which decisions were delayed
  • whether communication worked
  • whether the incident response plan was useful
  • whether suppliers responded as expected
  • which security controls need improvement

Evidence to prepare: post-incident review report and remediation action list.

What evidence is usually needed in a post-incident audit?

Organizational evidence

  • incident response plan
  • emergency contact list
  • roles and responsibilities
  • escalation matrix
  • incident register
  • incident timeline
  • decision log
  • crisis meeting notes
  • board report

Technical evidence

  • login logs
  • email logs
  • cloud system logs
  • endpoint logs
  • network logs
  • application logs
  • EDR or antivirus report
  • vulnerability report
  • technical analysis report
  • indicators of compromise

Data evidence

  • affected data list
  • systems containing data
  • data breach assessment
  • decision to notify or not notify
  • supervisory authority notification if made
  • communication to affected individuals if made
  • evidence of encryption or access restrictions

Communication evidence

  • internal messages
  • customer messages
  • customer question responses
  • supplier communication
  • insurer communication
  • legal communication
  • CERT or CSIRT communication

Recovery evidence

  • backup report
  • test or real recovery report
  • recovered system list
  • downtime duration
  • confirmation that systems were clean before restoration
  • approval to return to production

Remediation evidence

  • list of gaps that enabled the incident
  • remediation plan
  • action owners
  • deadlines
  • evidence of action closure
  • residual risk
  • board decisions

How to prepare a report for the board?

The board needs a report showing business impact, decisions and the improvement plan. It should not receive only a technical log description.

The board report should include

  • incident summary
  • business impact
  • customer impact
  • data impact
  • downtime
  • direct costs and estimated indirect costs
  • key decisions
  • what worked well
  • what needs improvement
  • residual risks
  • 30, 60 and 90-day action plan
  • budget decisions required from the board

Key board questions

  • is the incident closed?
  • has the attacker been removed from systems?
  • was customer data affected?
  • does the incident need to be reported to a regulator or customers?
  • how much did the incident cost?
  • what could have prevented the incident?
  • what are we doing to prevent recurrence?
  • what budget is needed?

How to prepare a report for a customer?

A customer report should be concrete but careful. It should answer legitimate customer questions without disclosing excessive technical detail and without speculation.

A customer report may include

  • brief incident description
  • impact on customer services
  • impact on customer data, if applicable
  • when the incident was detected
  • which containment actions were taken
  • whether the service was restored
  • which remediation actions are being implemented
  • who the contact point is
  • which further updates the customer will receive

Do not send a working technical report to the customer without legal and communication review. The customer version should be aligned with facts, contract and legal duties.

How to prepare documents for a cyber insurer?

The insurer may ask for evidence concerning loss, costs, cause, scope, actions and meeting policy conditions.

Prepare

  • policy number
  • claim notification date
  • incident timeline
  • technical report
  • cost list
  • supplier invoices and quotes
  • incident response action confirmations
  • evidence of MFA, backup, EDR or other required controls
  • communication with insurer
  • insurer approvals for costs if required

Do not assume all costs will be covered. Check policy terms, exclusions, limits, sublimits, deductible and prior approval requirements.

How to prepare for a GDPR audit after an incident?

If the incident affected personal data, the company must prepare a personal data breach assessment. Even if the breach was not notified to the supervisory authority, the decision should be documented.

Prepare

  • breach description
  • detection date
  • date of becoming aware of the breach
  • data categories
  • categories of affected individuals
  • approximate number of individuals and records
  • likely consequences
  • remedial actions
  • decision to notify or not notify
  • decision justification
  • communication to individuals if required

The key is that the decision should be based on facts and risk to people, not on avoiding formalities.

How to prepare for a NIS2 or KSC audit after an incident?

If the company is or may be covered by NIS2 or national rules implementing it, a post-incident audit may check not only technical response, but also oversight, reporting, decisions, risk management measures and evidence.

Prepare

  • incident classification
  • assessment whether the incident is significant
  • evidence of early warning if required
  • evidence of 72-hour notification if required
  • final report or final report draft
  • description of impact on services
  • description of mitigating measures
  • description of root cause or likely root cause
  • board decisions
  • remediation action plan

If national obligations are still being implemented or interpreted, the company should check current requirements with legal counsel or an appropriate advisor.

Common mistakes before a post-incident audit

Mistake 1: no timeline

Without a timeline, it is hard to answer basic questions: when the incident was detected, when response started, when the customer was informed and when the system was restored.

Mistake 2: mixing facts and assumptions

In an audit, confirmed evidence-based findings must be separated from hypotheses. Speculation can harm communication and report credibility.

Mistake 3: deleting evidence

Formatting computers, deleting emails, clearing alerts or restoring systems without evidence copies can make analysis and regulator or customer response harder.

Mistake 4: no decision log

After an incident, many decisions seem obvious, but an auditor may ask who made them and on what basis. This must be recorded.

Mistake 5: no data impact assessment

The company must know whether data was only potentially exposed or actually disclosed. Missing data impact assessment is a common problem.

Mistake 6: chaotic communication

Different message versions for customers, board and employees may create inconsistency. Communication should be approved and archived.

Mistake 7: no remediation closure

A report without remediation actions looks like a problem description, not risk management. The auditor will ask what was improved.

Mistake 8: no supplier involvement

If the incident involved a supplier system, cloud, hosting or MSP, the company must collect supplier evidence, timeline, actions and confirmations.

30, 60 and 90-day action plan

First 30 days

  • assign the post-incident audit preparation owner
  • define audit scope and stakeholders
  • prepare the incident timeline
  • preserve logs and technical evidence
  • collect internal and external communication
  • prepare initial technical report
  • perform data impact assessment
  • prepare decision log
  • identify urgent remediation actions

Days 31 to 60

  • finalize the technical report
  • prepare board-level report
  • prepare customer version if needed
  • close the most urgent remediation actions
  • prepare system recovery evidence
  • collect evidence from backup, MFA, EDR, logs and access review
  • prepare cost and invoice register if insurance is involved
  • agree communication with legal, compliance and the board

Days 61 to 90

  • perform formal post-incident review
  • approve remediation action plan
  • assign owners and deadlines
  • prepare board dashboard
  • update incident response plan
  • update playbooks and contact list
  • run a tabletop exercise for a similar scenario
  • prepare the final audit evidence pack

What documents and evidence should be prepared?

Basic pack

  • incident timeline
  • incident register
  • decision log
  • list of people involved
  • list of affected systems
  • list of affected data
  • technical report
  • board report
  • remediation action plan

Technical pack

  • login logs
  • email logs
  • endpoint logs
  • network logs
  • application logs
  • screenshots
  • indicators of compromise
  • EDR report
  • vulnerability report
  • remediation report

Legal and regulatory pack

  • data breach assessment
  • decision to notify or not notify
  • authority notification if made
  • communication to individuals if made
  • CSIRT or CERT notification if made
  • insurer communication evidence
  • contractual customer obligation analysis

Communication pack

  • employee messages
  • customer messages
  • supplier messages
  • message approvals
  • customer Q&A
  • crisis meeting notes

Security improvement pack

  • root cause analysis
  • gap list
  • remediation plan
  • action owners
  • deadlines
  • evidence of closure
  • residual risk
  • budget decisions

How to measure post-incident audit readiness?

Evidence metrics

  • percentage of required evidence collected
  • number of missing logs
  • number of systems without evidence owner
  • time to prepare timeline
  • number of unconfirmed hypotheses

Response metrics

  • time from detection to classification
  • time from detection to escalation
  • time to block compromised account
  • time to isolate infected device
  • time to recover critical system

Communication metrics

  • time to approve first message
  • number of message versions
  • number of customer questions
  • number of messages requiring correction
  • time to answer customer or auditor questions

Improvement metrics

  • number of remediation actions
  • number of actions closed on time
  • number of residual risks accepted by the board
  • number of procedures updated after the incident
  • number of exercises performed after the incident

Business example

A SaaS company serving B2B customers detects a Microsoft 365 administrator account takeover. The attacker had access to email and some files for several hours. The company quickly blocks the account, revokes sessions, removes suspicious mail rules and starts log analysis.

A major customer asks whether its data was affected. The cyber insurer asks for event documentation. The board wants to know whether a data breach must be notified and which actions will reduce recurrence risk.

The company prepares an audit pack: timeline, log report, affected accounts list, file access analysis, data breach assessment, decision log, customer communication, MFA report, remediation action plan and board report. The largest gap turns out to be lack of stronger MFA for administrators and excessive administrative roles.

After 60 days, the company implements phishing-resistant MFA for administrators, reduces roles, introduces quarterly access review, updates the account takeover playbook and runs a tabletop exercise. The post-incident audit does not only answer the customer, but actually improves resilience.

How can ccyber.io help?

ccyber.io helps companies prepare for post-incident audits in an organized, practical way aligned with board, customer, regulator and insurer expectations. We help collect facts, organize evidence, prepare reports, assess data impact and plan remediation actions.

We can support your organization with:

  • post-incident audit readiness
  • incident timeline preparation
  • technical evidence review
  • board report
  • customer report
  • data impact assessment
  • incident response plan review
  • remediation action plan preparation
  • ransomware readiness review
  • backup and recovery review
  • post-incident tabletop exercise
  • evidence pack for audit, customer or cyber insurer

The best first step is a Post-Incident Audit Readiness Workshop. It helps quickly determine which evidence is missing, which questions the customer or auditor will ask, how to prepare the report and which remediation actions must be closed first.

FAQ

What is a post-incident audit?

It is a review of facts, evidence, decisions, impact and remediation actions after a cyber incident. It may be performed by the company, customer, auditor, regulator, insurer or external cyber team.

Which documents are most important after an incident?

The most important documents are timeline, decision log, technical report, data impact assessment, communication register, recovery report, post-incident review and remediation plan.

Do we need a separate customer report?

Often yes. A customer report should be shorter, business-focused, fact-based and reviewed by legal and communications owners.

Does every incident need to be reported to the data protection authority?

No. The company must assess whether a personal data breach occurred and whether it may create risk to individuals’ rights and freedoms. The decision must be documented.

Can an auditor ask for logs?

Yes. Logs are often critical to confirm or exclude access, incident scale, duration and attacker actions.

What if logs are missing?

Be transparent about analysis limitations, describe alternative evidence sources and prepare remediation actions such as longer log retention or enabling missing sources.

Is a post-incident review needed?

Yes. It is one of the best practices. The review helps establish what worked, what did not and what must change.

Where should post-incident audit preparation start?

Start with audit scope, timeline, evidence preservation, decision log, data impact assessment and remediation action list.

Summary

A post-incident audit checks more than the technical details of the attack. It checks whether the company knew what it was doing, preserved evidence, made conscious decisions, assessed customer and data impact, and implemented remediation actions.

The most important preparation is the timeline, decision log, technical evidence, data breach assessment, communication register, recovery report, post-incident review and improvement plan. These documents should be created from the first hours of response, not only when a customer or regulator asks for explanations.

The best post-incident audit does not end with a report. It ends with risk reduction: better MFA, backups, logs, incident response plan, supplier control, training, monitoring and clear board decisions.

Sources

How to Document Cybersecurity Training for Audit Purposes?

Documenting cybersecurity training for audit purposes is not only about an attendance list. A company should have a training programme, training scope, target groups, materials, participant list, test results, completion confirmations, effectiveness metrics, remediation actions and evidence of recurring improvement. Auditors want to see that training is planned, measurable, repeatable and linked to company risk.

Prepared by: CCyber Editorial Team

Short answer

Cybersecurity training for audit purposes should be documented in a way that proves three things: the training happened, the right people participated and the training was aligned with company risk. An attendance list alone is usually not enough. A good evidence pack should include the training programme, date, trainer, target group, scope, materials, participant list, completion confirmations, knowledge test results, effectiveness metrics, remediation actions and evidence that training is regularly updated. The key is to connect training with employee roles, risk, incidents and audit requirements.

Last updated

July 2026

Who this article is for

  • business owners
  • boards
  • HR and onboarding owners
  • IT, security, CISO and vCISO teams
  • compliance, risk and internal audit teams
  • companies preparing for ISO 27001, SOC 2, NIS2, KSC, DORA, GDPR or customer audits
  • SMEs that want to organize cybersecurity training
  • companies that must show training evidence to a customer, auditor, insurer or supervisory authority

Key takeaways

  1. An attendance list matters, but it is not enough. The auditor should also see training scope, materials, results, metrics and post-training actions.
  2. Training should be role-based. The board, office staff, IT, administrators, HR, finance, sales and product teams have different risks.
  3. Training evidence should answer: who, when, what, why, with which result and what the company did with the results.
  4. Training documentation contains personal data, so data minimization, reasonable retention and access control are required.
  5. The best training programme is recurring. Auditors want to see not only one training session, but a process: plan, delivery, measurement, improvement and review.

Why is training documentation important?

Cybersecurity training should reduce the risk of human mistakes, phishing, payment fraud, data leakage, unsafe AI use, weak password management and poor incident response. However, an auditor does not assess only whether the company says it trains people. The auditor checks whether the company can prove it.

Good training documentation helps to:

  • show compliance with audit requirements
  • prove that employees received security instructions
  • show that training is aligned with risk
  • show that the board and employees understand their responsibilities
  • prepare the company better for incidents
  • answer customer security questionnaires
  • prepare cyber insurance evidence
  • learn from phishing tests and incidents

Simply put: training without evidence may be hard to defend in an audit. Evidence without real training is also weak. Both are needed.

What does an auditor want to see?

The auditor usually does not want to see only slides. The auditor wants to understand whether the organization has a controlled training process. Well-prepared documentation should show that training is planned, delivered, measured and improved.

The auditor may ask

  • does the company have a cybersecurity training plan?
  • who owns the training programme?
  • when was the last training delivered?
  • who was covered by the training?
  • was the training mandatory?
  • was the training role-based?
  • are new employees trained during onboarding?
  • does the board receive separate training?
  • is training repeated?
  • does the company measure training effectiveness?
  • what does the company do with people who did not complete training?
  • was training updated after an incident or risk change?

Minimum evidence answer

For each of these questions, the company should have a document, report, system entry, list, confirmation or decision. Audit should not rely on one person’s memory.

Which training should be documented?

Not every training session needs the same level of formality, but every material cybersecurity training should have evidence. The strongest focus should be on mandatory training, high-risk role training and training required by regulations, standards or customers.

Training for all employees

  • cyber hygiene
  • phishing and social engineering
  • secure passwords and MFA
  • secure remote work
  • incident reporting
  • data protection and confidentiality
  • safe AI use

Training for high-risk roles

  • board and decision makers
  • finance and accounting
  • HR
  • sales and customer support
  • IT and administrators
  • developers and product teams
  • employees with access to customer data
  • people approving payments

Regulatory and audit training

  • NIS2 for the board and employees
  • GDPR and personal data protection
  • ISO 27001 awareness
  • SOC 2 security awareness
  • DORA awareness for financial entities and ICT providers
  • secure software development
  • incident response tabletop

Evidence to prepare: training matrix by roles and audit requirements.

What should a complete training evidence pack include?

1. Training plan

The plan shows that training was not random. It should cover a year or at least a quarter.

The plan should include:

  • training name
  • training objective
  • target group
  • training owner
  • date
  • frequency
  • training format
  • required evidence
  • link to risk or audit requirement

Evidence: annual cybersecurity training plan.

2. Agenda and training scope

The agenda shows what participants were supposed to learn. This matters because the auditor may check whether the right topics were covered.

The agenda should include:

  • topics
  • duration
  • learning objectives
  • practical scenarios
  • reference to company risks
  • reference to policies and procedures
  • whether the training ends with a test

Evidence: training agenda and scope description.

3. Training materials

Materials show which content was delivered. They may include slides, recording, workshop scenario, instruction, e-learning, quiz, case study or checklist.

Materials should have:

  • version
  • update date
  • owner
  • target group name
  • information whether they are current
  • link to company policies

Evidence: complete training materials with version number.

4. Participant list

The participant list shows who attended training. It should be accurate but not excessive. Do not collect data you do not need.

The list may include:

  • full name
  • business email address
  • department
  • role or training group
  • participation date
  • completion status
  • electronic signature or system confirmation where available

Evidence: participant list or learning platform report.

5. Completion confirmation

An auditor may distinguish between “invited to training” and “completed training”. Completion status matters more than the invitation itself.

Confirmation may include:

  • certificate of completion
  • e-learning platform report
  • workshop attendance confirmation
  • policy acknowledgment confirmation
  • signed attendance list
  • HR system entry

Evidence: training completion report.

6. Knowledge test

A test is not always mandatory, but it helps strongly in an audit. It shows that the company did not only deliver content, but checked understanding.

The test should show:

  • number of questions
  • pass threshold
  • participant result
  • number of attempts
  • passed or failed status
  • actions for people who did not pass

Evidence: knowledge test results report.

7. Effectiveness metrics

Training should have metrics. Without metrics, the company does not know whether training works.

Example metrics:

  • training completion rate
  • average test score
  • number of people who did not complete training
  • number of test retries
  • number of phishing reports after training
  • phishing simulation results
  • number of incidents related to user mistakes
  • time to report a suspicious message

Evidence: training effectiveness report.

8. Remediation actions

If some employees did not complete training or test results are weak, the company should have a remediation plan. Lack of response to results is a common audit problem.

Actions may include:

  • participant reminders
  • re-training
  • additional material for a selected role
  • meeting with manager
  • training content change
  • additional phishing simulation
  • procedure update

Evidence: post-training remediation action register.

9. Policy and procedure acknowledgment

Training is often linked to policies such as the information security policy, password policy, AI policy, remote work policy or incident reporting procedure. It is useful to have evidence that the employee acknowledged the applicable rules.

Evidence: policy and procedure acknowledgment confirmation.

10. Programme review and update

The auditor may ask whether training is current. If materials have not changed for years, they may not cover new risks such as AI scams, deepfakes, prompt injection, MFA fatigue or new fraud schemes.

Evidence: history of training programme and materials updates.

How to document training by audit type?

ISO 27001

For ISO 27001, the key is to show that training is part of systematic information security management. Evidence should be linked to risk, competence, awareness, policies and control effectiveness.

Prepare:

  • training plan
  • role and competence matrix
  • training completion evidence
  • training materials
  • test results
  • effectiveness report
  • remediation actions
  • evidence of programme review by the ISMS owner

NIS2 and KSC

For NIS2, board training, cyber hygiene, employee training and the ability to identify risks and assess cyber risk management practices are especially important. Documentation should show that training is regular and linked to risk management.

Prepare:

  • NIS2 board training
  • board participant list
  • management training materials
  • post-training decision note
  • employee cyber hygiene training
  • evidence of training recurrence
  • effectiveness metrics
  • link between training and risk register

SOC 2

For SOC 2, the auditor often expects evidence that employees are trained on security, confidentiality, privacy, procedures and responsibilities. Evidence consistency over time matters.

Prepare:

  • learning platform report
  • security onboarding evidence
  • annual training evidence
  • report of people who did not complete training
  • reminder and escalation evidence
  • training materials
  • policy acknowledgment confirmations

GDPR

In the GDPR context, training may concern personal data protection, confidentiality, breach reporting, work with customer data and minimization principles. At the same time, training documentation itself contains personal data and must be protected.

Prepare:

  • data protection training programme
  • participant list
  • confirmation of data protection rules acknowledgment
  • knowledge test if used
  • information about evidence retention period
  • access control for training reports
  • evidence of training people with access to personal data

Cyber insurance

The insurer may ask about phishing training, security awareness, phishing simulations and response procedures. Keep evidence that confirms questionnaire answers.

Prepare:

  • phishing training report
  • knowledge test results
  • phishing simulation report if conducted
  • phishing reporting procedure
  • employee reminder evidence
  • training evidence for finance and payment approvers

Training evidence matrix

The easiest way to manage documentation is an evidence matrix. It shows which training is required, for whom, how often and which evidence must be retained.

Minimum matrix fields

  • training name
  • training owner
  • target group
  • audit requirement or risk
  • frequency
  • format
  • completion evidence
  • required test
  • minimum score
  • retention period
  • evidence location
  • status

Example entry

Name: Phishing and social engineering for employees.

Group: all employees.

Frequency: onboarding and annually.

Evidence: agenda, materials, participant list, knowledge test, completion report, overdue participant list, remediation actions.

Risk: account takeover, fraudulent payment, data leakage, ransomware.

Owner: security or HR in cooperation with IT.

How long should training documentation be kept?

There is no single universal answer for every company and audit. The retention period should follow the purpose, legal, regulatory, contractual and audit requirements. At the same time, training documentation contains personal data.

Practical rule

  • for annual audits, keep evidence at least for the current audit period and the previous one
  • for ISO 27001, retain evidence according to the ISMS documentation policy
  • for customer requirements, check the contract and security requirements
  • for GDPR, define the minimum necessary period and record it in retention rules
  • for cyber insurance, keep evidence corresponding to the policy period and potential claims

The key point: do not keep documentation forever if there is no purpose. Define retention period, owner, storage location and deletion rules.

Where should training evidence be stored?

Evidence should be easy to find during an audit, but protected from unauthorized access. The worst model is evidence scattered across mailboxes, private drives and folders owned by different people.

Good storage locations

  • HR system
  • learning platform
  • controlled compliance folder
  • ISMS repository
  • GRC tool
  • document management system

Access rules

  • access only for people who need it
  • separate access for HR, security and compliance
  • change control
  • material version history
  • backup of documentation
  • clear repository owner

Evidence to prepare: training documentation storage procedure and list of authorized people.

How to document onboarding training?

Onboarding is one of the most important moments. A new employee receives access to email, systems, data and customers. Auditors often check whether new employees were trained before receiving full access or shortly after joining.

Minimum onboarding training

  • information security policy
  • passwords and MFA
  • phishing and incident reporting
  • data protection and confidentiality
  • secure remote work
  • AI usage rules if the company uses AI tools
  • company device usage rules

Onboarding evidence

  • onboarding checklist
  • training date
  • policy acknowledgment confirmation
  • test result
  • completion status before access is granted
  • manager approval for an exception if applicable

How to document board training?

Board training should be documented differently from employee training. The auditor may expect evidence that the board understands risks, makes decisions and oversees the cybersecurity programme.

Board training evidence

  • board training agenda
  • participant list
  • business-focused materials
  • short knowledge test or understanding confirmation
  • list of board questions
  • post-training decision note
  • action list and owners
  • date of next cyber risk review

The greatest value is not the certificate of attendance. The greatest value is evidence that the training led to decisions: budget, roadmap, risk owner, incident plan or gap analysis.

How to document phishing simulations?

Phishing simulations can be a good tool, but they must be run responsibly. The goal is not to shame employees, but to improve organizational resilience.

What should be documented?

  • simulation objective
  • target group
  • date
  • scenario
  • difficulty level
  • number of messages sent
  • number of clicks
  • number of reports
  • reporting time
  • educational actions after the simulation

What should be avoided?

  • publicly naming people who clicked
  • punishing employees for mistakes
  • collecting excessive personal data
  • no communication after the exercise
  • tests without educational purpose

Evidence: phishing simulation report with conclusions and educational actions.

30, 60 and 90-day action plan

First 30 days

  • assign training documentation owner
  • list all cybersecurity training delivered in the company
  • identify audit and regulatory requirements
  • create a role-based training matrix
  • define minimum evidence pack for every training
  • prepare central evidence repository
  • check whether new employees have security onboarding evidence
  • identify people without completed training

Days 31 to 60

  • complete missing participant lists and completion reports
  • update training materials
  • add knowledge tests to key training sessions
  • define pass thresholds and actions after failure
  • prepare a report for the board or ISMS owner
  • define training documentation retention rules
  • restrict access to reports containing personal data
  • prepare training evidence procedure for audit

Days 61 to 90

  • deliver missing training for high-risk groups
  • document board training
  • run a short phishing simulation or incident reporting exercise
  • prepare training programme effectiveness report
  • close post-training remediation actions
  • prepare audit evidence pack
  • plan the next programme update
  • define quarterly training status review

Common training documentation mistakes

Mistake 1: attendance list only

An attendance list says who attended. It does not say what the training covered, whether the participant understood the material and what the company did with the results.

Mistake 2: no link to risk

Training should follow company risk. Accounting exposed to payment fraud, administrators and the board require different training.

Mistake 3: no evidence for absent people

The auditor may ask what the company did with people who did not complete training. A process for reminders, escalation and completion is needed.

Mistake 4: materials without version and date

If materials have no date and version, it is hard to prove which content was current at the training date.

Mistake 5: no effectiveness metrics

Training should not end only with attendance confirmation. Test results, phishing reports, mistakes and remediation actions should be measured.

Mistake 6: keeping personal data too long

Training documentation contains personal data. Define the purpose, data scope, retention period and access.

Mistake 7: documentation scattered in emails

Training evidence should be stored in one controlled place. Scattered evidence makes audits harder and increases the risk of losing documents.

Mistake 8: no update after an incident

If the company had a phishing incident, data leakage or AI-related issue, the training programme should be updated.

How to measure training documentation effectiveness?

Completeness metrics

  • percentage of employees with mandatory training completed
  • number of people without current training
  • number of training sessions without materials
  • number of training sessions without participant list
  • number of training sessions without test or completion confirmation

Quality metrics

  • average knowledge test score
  • number of questions most often answered incorrectly
  • number of material updates
  • number of role-based training sessions
  • number of remediation actions after training

Behavior metrics

  • number of phishing reports
  • time to report a suspicious message
  • number of clicks in phishing simulation
  • number of incidents caused by user mistake
  • number of employee questions to security or IT

Audit metrics

  • number of audit requirements mapped to training evidence
  • number of evidence gaps found before audit
  • time to prepare evidence pack for auditor
  • number of audit findings related to training
  • number of closed post-audit actions

Business example

A SaaS company is preparing for SOC 2 and a large enterprise customer. It has cybersecurity training, but evidence is scattered: some attendance lists are in email, some in HR, some in an e-learning platform, and training materials have no date or version.

During preparation, the company finds that 18 percent of employees do not have annual training completion confirmation, new employees did not always complete onboarding training, and the development team did not have separate secure development training. The board had a NIS2 briefing, but there is no decision note.

The company organizes the process in 60 days. It creates a training matrix, central evidence repository, versioned materials, completion reports, knowledge tests and reminder process. A separate board pack is created: agenda, materials, participant list, decisions and action plan. A secure SDLC training is created for developers.

During the audit, the company does not need to search for documents. It shows the auditor a requirements matrix, completion report, materials, test results, exception list and remediation actions. Training stops being a formality and becomes a measurable security control.

How can ccyber.io help?

ccyber.io helps companies prepare cybersecurity training documentation for audits, customers, cyber insurance and regulatory requirements. We combine security, compliance, HR, board and auditor perspectives.

We can support your organization with:

  • cybersecurity training matrix
  • audit-ready training evidence pack
  • cyber hygiene, phishing, AI security, NIS2 and incident response training
  • board training with documented decisions
  • training for high-risk roles
  • versioned training materials
  • knowledge tests and effectiveness metrics
  • reports for ISO 27001, SOC 2, NIS2, KSC, DORA and cyber insurance
  • training evidence retention procedure
  • pre-audit evidence gap review

The best first step is a Training Evidence Readiness Review. In a short review, the company can check whether evidence is complete, where gaps exist, which training must be completed and how to prepare an audit pack without chaos.

FAQ

Is an attendance list enough as training evidence?

Usually not. Attendance matters, but it is better to have agenda, materials, scope, test results, completion confirmation, metrics and remediation actions.

Does every training session need a knowledge test?

Not every one, but a test helps a lot in audits. For mandatory training, phishing, NIS2, GDPR and high-risk roles, testing is a good practice.

How should online training be documented?

Use a platform report: participant, date, duration, completion status, test score, number of attempts and material version. The report should be exportable for audit.

How should classroom training be documented?

Prepare agenda, materials, participant list, signatures or attendance confirmations, meeting note, knowledge test and post-training report.

How long should training evidence be retained?

It depends on the purpose, regulations, contracts and audit cycle. Define the retention period in a procedure and do not keep data longer than necessary.

Are training test results personal data?

Yes, if they can be linked to a specific person. Access must be restricted, data minimization applied and data retained only as long as justified.

What should be done with people who did not complete training?

Use reminders, escalation to the manager, re-training and documented completion. No response to overdue training can become an audit issue.

Where should documentation cleanup start?

Start with a role-based training matrix, required evidence list, central repository and gap report: who has not completed training, what is missing and by when it must be completed.

Summary

Documenting cybersecurity training for audit purposes should show not only attendance, but the full process: plan, scope, materials, participants, completion, tests, effectiveness, remediation and updates.

The best evidence pack answers simple questions: who was trained, when, on what, why, with which result and what the company did with the results. This makes training a real security control, not just a formality.

Well-prepared documentation makes ISO 27001, SOC 2, NIS2, KSC, DORA, GDPR, cyber insurance and enterprise customer reviews easier. The key is that evidence should be current, complete, stored in one place and linked to company risk.

Sources

We write about regulations such as NIS2, DORA, CRA and ISO 27001, cybersecurity for SMEs and critical infrastructure, as well as cyber hygiene, emerging threats and building security awareness within organisations.

Every article delivers practical knowledge - no jargon, just concrete steps you can act on to effectively protect your data, people and business continuity.