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NEN 7510Checklist

NEN 7510 checklist: are you ready for certification?

This checklist helps you quickly see where you stand against NEN 7510 . For each clause of the standard, it sets out the core question the auditor asks and the evidence they expect. Use it to prepare for your internal audit or as a final check before the certification audit. The requirements of the standard explain each point in substance.

NEN 7510:2024 is the current version. Does your organisation still work with an older version? Then the same clauses apply, but check whether your documentation matches the revised list of measures.

How do you use this checklist?

Go through the table for each clause. Mark each point as ready, partly ready or still to do. Points you mark as “partly ready” or “still to do” are the gaps you must address before the audit.

A tip: do not go through the checklist only at your desk. Walk through the practice too. Does a random employee know what to do with a phishing email? Are the server rooms really locked? The auditor checks exactly that.

Clause 4: context of the organisation

This clause is about understanding the environment in which you operate. Without that context, you cannot build a good security system.

RequirementEvidence you needReady?
Internal and external factors documentedContext analysis or SWOT-style overview☐
Interested parties and their requirements determinedList of stakeholders (Health and Youth Care Inspectorate (IGJ, Inspectie Gezondheidszorg en Jeugd), patients, insurers) with their requirements☐
Scope of the ISMS determined and documentedScope document, approved by management☐
Boundaries of the scope logical and not artificially drawnAuditor can follow the reasoning☐

Clause 5: leadership

Management commitment is a core requirement. The auditor looks for evidence of real involvement, not a signature on a document.

RequirementEvidence you needReady?
Information security policy approved by managementPolicy document, signed and dated☐
Policy communicated to staffTraining records, intranet, minutes☐
Roles and responsibilities assignedJob descriptions or organisation chart☐
Management demonstrably involved in ISMS decisionsManagement review minutes☐

Clause 6: planning

Planning is about addressing risks before they cause harm.

RequirementEvidence you needReady?
Risk analysis carried out using a documented methodRisk register with likelihood, impact and owners☐
Healthcare-specific risks included (patient data, medical equipment)Risks specific to your care practice in the register☐
Risk treatment determined for each riskRisk treatment plan☐
Statement of Applicability (VvT, Verklaring van Toepasselijkheid) drawn upVvT with justification for each measure☐
Information security objectives setMeasurable objectives per department or level☐

The VvT is one of the first documents the auditor asks for. Make sure each measure in NEN 7510-2 shows whether you selected it and why. Missing justification is a common finding.

Clause 7: support

Do you have the resources and people to keep the system running?

RequirementEvidence you needReady?
Necessary resources available (people, budget, tools)Project plan or budget☐
Staff competences determined and securedJob profiles, diplomas, certificates☐
Awareness training carried out for all staffTraining record with date and attendees☐
Communication plan for information securityPlan or calendar of communication moments☐
Mandatory documents present and up to dateSee the mandatory documents for the full overview☐

Clause 8: operation

Do you do in practice what you have planned?

RequirementEvidence you needReady?
Risk analysis carried out and documentedVersion with date and approval☐
Controls actually implementedTechnical configurations, procedure descriptions☐
Supplier agreements on information security madeProcessor agreements (verwerkersovereenkomsten), contracts☐
Logging of access to patient data active (NEN 7513)Log report or system configuration of the EPD/ECD☐
Medical equipment included in scopeEquipment inventory in the risk analysis☐

Clause 9: evaluation

Do you check whether the system works?

RequirementEvidence you needReady?
KPIs or indicators defined and measuredMeasurement results over at least one quarter☐
Internal audit carried outInternal audit report with findings☐
Internal auditor independent of the processes auditedAudit schedule with assignment and reasoning☐
Management review heldMinutes with agenda, input and decisions☐
Management review led to concrete actionsAction list from the management review☐

Clause 10: improvement

Does the system improve based on what you learn?

RequirementEvidence you needReady?
Nonconformities recorded and analysedNonconformity register or incident log☐
Corrective measures taken and followed upAction list with status and closure☐
Continuous improvement actions demonstrableImprovements in policy, procedures or measures☐

Healthcare-specific points

NEN 7510 includes additions that are specific to healthcare. These are the points the auditor looks at especially closely.

Healthcare-specific pointWhat you must demonstrateReady?
Logging compliant with NEN 7513Automatic logging: who, when, which patient, which action☐
Access based on the treatment relationship arrangedAccess management linked to active treatment relationships☐
Patients can request log dataProcedure or portal function available☐
Security of networked medical equipmentInventory and risk treatment☐
Data exchange in the chain securedAgreements in line with NEN 7512☐
Processors (EPD supplier, hosting provider) have signed agreementsProcessor agreements on file☐

What do you do with the outcome?

All boxes ticked? Then you are well prepared for the certification audit. But honestly, that is rarely the reality on a first run-through.

Set priorities based on your gaps. Large missing pieces (no risk analysis, no management review) are major nonconformities: they block the certificate. Small gaps (one document out of date) are minor nonconformities: annoying, but manageable.

Read more about the mandatory documents you need for certification, or look at the step-by-step plan if you are still in the implementation phase.

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