Specified driver could not be loaded due to system error 127: The specified procedure could not be found. (...SQORA32.DLL).

Question

I recently upgraded from 10g to 11g and upon this upgrade, a website of mine stopped working.
It is a classic ASP website.  I added a "testdatabase" page to the website to test the basic functionality of opening a connection.  I've pasted the testdatabase page below.  Anyways, upon running this page, I get this error:
Specified driver could not be loaded due to system error 127: The specified procedure could not be found. (Oracle in OraClient11g_home1_32bit, D:\app\oracleadm\product\11.2.0\client_1\BIN\SQORA32.DLL).
I have two other environments where I have done the same upgrade and the site works just fine.  I have compared all the IIS settings in my other environments to that of the one suffering from the error.  Also, in the IIS settings, I have made sure that "Allow 32bit" was checked.
D:\app\oracleadm\product\11.2.0\client_1\BIN\SQORA32.DLL is actually where this DLL resides. 
I have also checked to make sure the environment variables are correct.
The very first environment variable in the PATH setting is D:\app\oracleadm\product\11.2.0\client_1\bin; and there are no other references to oracle in the PATH environment variable.
I have done a google search and I've seen that people also tell me to check ORACLE_HOME to make sure it's correct.  I've checked this in both of the working environments and there is nothing there.  There is also nothing there in the broken environment.  What should be there?  If anything?
I don't know where else to look.  What could be causing this error?
<%
Option Explicit
Response.Expires = 0
Response.Buffer  = true
Dim conn
Err.Clear
On Error Resume Next
Set conn = Server.CreateObject("ADODB.Connection")
conn.Open "DSN=RPS11;UID=FFXQM;PWD=ffxqm6prd$"
If Err.Number <> 0 Then
Response.Write (Err.Description & "<br><br>")
Response.End
conn.Close
Set conn = Nothing
End If
conn.Close
Set conn = Nothing
On Error GoTo 0
%>

Answer 1

As a temporary solution, add the Administrators group to the IUSR and IWAM userids and see if that works. If it solves the problem, then it IS a matter of setting the users privledges correctly.