I found the solution.

This is from a DB2 UDB security document:

"Beginning in DB2 UDB Version 8.2, additional security was added to DB2
UDB in the Windows environment. A new option exists as part of the DB2
UDB installation to create two additional groups in the operating
system, DB2USERS and DB2ADMNS. Once these groups are created, only user
accounts that are members of these groups will have access to the DB2
UDB files on the system (including commands as well as user data files
created by DB2 UDB)."

The fix:

On your Windows server, go to >Control Panel >Administrative Tools
>Computer Management
On the tree view, go to >Computer Management (Local) >System Tools
>Local Users and Groups >Groups
Right-click on DB2USERS and select Properties
Add the users that will be accessing the DB2 Drivers. This will most
likely be the ID that is running the IIS server.



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