According to ISO/IEC 27001:2022, which specifies the requirements for establishing, implementing, maintaining and continually improving an information security management system (ISMS), clause 9.3 requires top management to review the organization’s ISMS at planned intervals to ensure its continuing suitability, adequacy and effectiveness1. Clause 9.2 requires the organization to conduct internal audits at planned intervals to provide information on whether the ISMS conforms to its own requirements and those of ISO/IEC 27001:2022, and is effectively implemented and maintained1. Therefore, when reviewing the audit process and audit findings as a final check before the external certification body arrives, an internal ISMS auditor should verify that these clauses are met in accordance with the audit criteria.

Six of the following statements would cause concern in respect of conformity to ISO/IEC 27001:2022 requirements:

The audit programme shows management reviews taking place at irregular intervals during the year: This statement would cause concern because it implies that the organization is not conducting management reviews at planned intervals, as required by clause 9.3. This may affect the ability of top management to ensure the continuing suitability, adequacy and effectiveness of the ISMS.

The audit programme does not take into account the relative importance of information security processes: This statement would cause concern because it implies that the organization is not applying a risk-based approach to determine the audit frequency, methods, scope and criteria, as recommended by ISO 19011:2018, which provides guidelines for auditing management systems2. This may affect the ability of the organization to identify and address the most significant risks and opportunities for its ISMS.

Although the scope for each internal audit has been defined, there are no audit criteria defined for the audits carried out to date: This statement would cause concern because it implies that the organization is not establishing audit criteria for each internal audit, as required by clause 9.2. Audit criteria are the set of policies, procedures or requirements used as a reference against which audit evidence is compared2. Without audit criteria, it is not possible to determine whether the ISMS conforms to its own requirements and those of ISO/IEC 27001:2022.

Audit reports to date have used key performance indicator information to focus solely on the efficiency of ISMS processes: This statement would cause concern because it implies that the organization is not evaluating the effectiveness of ISMS processes, as required by clause 9.1. Effectiveness is the extent to which planned activities are realized and planned results achieved2. Efficiency is the relationship between the result achieved and the resources used2. Both aspects are important for measuring and evaluating ISMS performance and improvement.

The audit programme does not take into account the results of previous audits: This statement would cause concern because it implies that the organization is not using the results of previous audits as an input for planning and conducting subsequent audits, as recommended by ISO 19011:20182. This may affect the ability of the organization to identify and address any recurring or unresolved issues or nonconformities related to its ISMS.

Top management commitment to the ISMS will not be audited before the certification visit, according to the audit programme: This statement would cause concern because it implies that the organization is not verifying that top management demonstrates leadership and commitment with respect to its ISMS, as required by clause 5.1. This may affect the ability of top management to ensure that the ISMS policy and objectives are established and compatible with the strategic direction of the organization; that roles, responsibilities and authorities for relevant roles are assigned and communicated; that resources needed for the ISMS are available; that communication about information security matters is established; that continual improvement of the ISMS is promoted; that other relevant management reviews are aligned with those of information security; and that support is provided to other relevant roles1.

The other statements would not cause concern in respect of conformity to ISO/IEC 27001:2022 requirements:

Audit reports are not held in hardcopy (i.e. on paper). They are only stored as ".POF documents on the organisation’s intranet: This statement would not cause concern because it does not imply any nonconformity with ISO/IEC 27001:2022 requirements. The standard does not prescribe any specific format or media for documenting or storing audit reports, as long as they are controlled according to clause 7.5.

The audit programme mandates auditors must be independent of the areas they audit in order to satisfy the requirements of ISO/IEC 27001:2022: This statement would not cause concern because it does not imply any nonconformity with ISO/IEC 27001:2022 requirements. The standard does not prescribe any specific requirement for auditor independence, as long as the audit is conducted objectively and impartially, in accordance with ISO 19011:20182.

The audit programme does not reference audit methods or audit responsibilities: This statement would not cause concern because it does not imply any nonconformity with ISO/IEC 27001:2022 requirements. The standard does not prescribe any specific requirement for referencing audit methods or audit responsibilities in the audit programme, as long as they are defined and documented according to ISO 19011:20182.

The audit process states the results of audits will be made available to ‘relevant’ managers, not top management: This statement would not cause concern because it does not imply any nonconformity with ISO/IEC 27001:2022 requirements. The standard does not prescribe any specific requirement for communicating the results of audits to top management, as long as they are reported to the relevant parties and used as an input for management review, according to clause 9.3.

References: ISO/IEC 27001:2022 - Information technology – Security techniques – Information security management systems – Requirements, ISO 19011:2018 - Guidelines for auditing management systems