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ISO 27001Internal audit

ISO 27001 internal audit

The internal audit is a mandatory requirement of ISO 27001  (clause 9.2) and one of the smartest investments in your ISMS. You discover for yourself what is wrong before the external auditor sees it. The NEN version of the standard  states that you carry out internal audits at planned intervals to check whether the ISMS meets the requirements and works effectively. The full audit process, including the external certification audit, is described on the audit process page.

The external auditor expects evidence of internal audits. No internal audit report means a major nonconformity. Plan the internal audit well ahead of the certification audit or surveillance audit, so you have time to resolve findings.

What does the internal audit check?

The internal audit checks whether the ISMS meets:

  1. The requirements of ISO 27001: clauses 4 to 10
  2. The organisation’s own requirements: policies, procedures and objectives that you have set yourself
  3. The selected Annex A controls: whether the controls in your SoA have demonstrably been implemented

The audit checks both conformity (do you meet the requirement?) and effectiveness (does it work?). A procedure that exists but is never followed is a finding.

Planning the internal audit

Set up an audit programme

The audit programme describes all the internal audits you plan for the coming year. ISO 27001 does not necessarily require one audit a year, but it does require that all parts of the ISMS are audited regularly. Many organisations spread the audits across the year, for example half in quarter 2 and the other half in quarter 3.

Include in the audit programme which parts are audited, when, by whom and on the basis of which criteria. Keep the programme, because the external auditor will want to see it.

Set audit criteria

The audit criteria are the standards you test against: the standard itself, your own policies, procedures and the selected Annex A controls. Describe the criteria per audit area in the audit plan.

Appoint an independent auditor

The internal auditor may not audit their own work. This is a firm requirement. The IT manager does not audit their own IT processes. The ISMS owner does not audit the ISMS they have built.

For small organisations, this often means one of the following options:

OptionSuitable forPoint of attention
Employee from another departmentOrganisations with 20 or more employeesTraining in audit techniques needed
External internal auditorAll organisationsCost; no trusted employees needed
Partly externalHybrid approachFlexible, popular with small and medium-sized businesses

Set up an audit plan for each audit

The audit plan describes the scope, the purpose, the criteria, the planned activities and the duration. Send the plan to the auditees in advance, so they know what is expected and which documents need to be ready.

Carrying out the internal audit

Document review

Start by reviewing the documentation: is the scope up to date, is the information security policy current, are the procedures available and of the right version? Check whether the documents have been approved and are properly version controlled.

Interviews

Speak with employees who are responsible for ISMS processes. Ask open questions: “How do you handle a security incident?”, “When did you last update a risk assessment?”, “How do employees know which data they must not forward?” The answers show whether processes are actually being followed.

Observation and evidence

Ask for evidence. Training records, incident logs, access logs, backup reports. If a procedure says backups are checked weekly, you want to see the check record. If it is missing, that is a finding.

Use the checklist below as a guide.

Internal audit checklist for ISO 27001

Clause or controlCheckFinding
4.3 ScopeIs the scope documented and up to date?
5.2 PolicyIs the policy approved, dated and communicated?
6.1.2 Risk assessmentIs the risk assessment recent and have risk owners been assigned?
6.1.3 SoADoes the SoA cover all Annex A controls with justification?
7.2 CompetenceIs training documented for relevant employees?
7.3 AwarenessDo employees know the policy and how to report?
9.2 Internal auditAre previous audit results available and have findings been resolved?
9.3 Management reviewAre minutes available and have actions been followed up?
A.6.3 AwarenessIs there an awareness programme and are participants recorded?
A.5.24-5.28 IncidentsIs there an incident register? Are incidents analysed?
A.8.5 AuthenticationIs MFA used for systems with sensitive access?

Reporting the internal audit

The audit report records the findings. ISO 27001 does not prescribe how extensive the report must be, but it must contain at least:

  • The date and scope of the audit
  • The processes and people audited
  • The criteria used
  • Findings per clause or control (conformity, observations, nonconformities)
  • A corrective action per nonconformity, with an owner and a deadline

Share the report with management and use it as input for the management review. The external auditor will request the report at the certification audit. A worked example with findings and actions is available on the internal audit report page.

A report without findings is suspicious. A well-functioning ISMS always has areas for improvement. Auditors value honesty: a report with three minor findings that have been resolved is stronger than an empty report.

Do it yourself or outsource?

Do it yourselfOutsource
CheaperMore independent judgement
Requires internal knowledge of the standardExternal party knows the standard well
Independence is a challenge in small teamsReady to deploy immediately
Builds internal competenceLess transfer of knowledge

For a first certification, many organisations choose external support for the internal audit. After certification, you build internal audit capacity so you can lower the costs of later cycles.

Internal audit and the step-by-step plan

The internal audit belongs in phase 8 of the step-by-step plan: after building the ISMS and implementing controls, but well before the external certification audit. Plan at least four to six weeks between the internal audit and the certification audit, so you have time to resolve findings and gather evidence.

Repeat the internal audit every year as part of your maintenance strategy after certification.

More information