Squeezing more value from certification audits



Finding weaknesses/concerns and improvement opportunities in the organisation's information risk, security and related arrangements is a valid and potentially valuable outcome of an ISO/IEC 27001 certification audit. Arguably, however, that is what the management reviews and internal audits are supposed to achieve.  

Certification auditing is primarily intended to provide assurance for the organisation and third parties that the organisation has correctly interpreted and implemented the standard, a specific key objective.

One way to resolve this conundrum is for certification auditors to distinguish:
  1. "Major nonconformities" - demonstrable and substantial failures to fulfil any of the mandatory requirements of 27001; from

  2. "Minor nonconformities" - insubstantial failures and/or failures against the discretionary requirements of 27001; and 

  3. "Observations" - anything else noted in the audit that the auditor believes is worth bringing to management's attention.
Of those three, only majors are grounds for refusing to issue the certificate.

The rating/categorisation of audit findings is therefore critical and may be worth challenging during the audit clearance/acceptance - an important phase in the audit process where findings are considered and management decisions are made about:
  • Addressing the findings; 
  • Planning, prioritising and resourcing the resolutions; and 
  • Moving forward - not just changing for change sake or 'because the auditor insists' but materially improving the organisation in some way, increasing its chances of achieving its business objectives.
Every major should:
  1. Explicitly identify the mandatory requirements that are not met, normally by specifying the particular main-body clauses from the standard; and
     
  2. Be supported by reasonably solid, credible, substantial evidence of the failures - potentially a tricky thing to do: how do you 'prove' the absense of something? 
Minors and observations are less important but, even so, they should still be based on analysis traceable to credible, factual, objective evidence gathered during the audit fieldwork. "Facts" are (in theory at least) the auditor's friends, the backstop, the undeniable basis for arguing that changes are necessary.

The audit analysis is more subjective and open to interpretation than the facts. This is where the auditors' experience and skills come into play: they need to construct a credible argument and persuade management to act appropriately - meaning in the best interests of the organisation meeting its business objectives, just one of which might be achieving 27001 certification. There are several other business objectives relating to information risk, security etc., hence several ways to evaluate audit findings. There are options here.

27001 certification audits can be a worthwhile means of identifing weaknesses in the organisation's information risk, security and related arrangements. Management has the opportunity to improve the organisation's overall security posture as well as being certified conformant, squeezing additional value from the certification audit process. 

Pragmatic bottom line: rather than being fixated on the audit remit/purpose, do whatever is best for the business.  Work it out and move on. 

PS I blogged at some length about how to challenge audit findings and about treating the audit clearance as a negotiation in 2019. Evidently my thinking has not really progressed since then. The bloggings will continue until morale improves.

Popular posts from this blog

Pragmatic ISMS implementation guide (FREE!)

Image
Early this morning ( very  early!) I remotely attended an ISO/IEC JTC 1/SC 27/WG 1 editing meeting in London discussing the planned revision of ISO/IEC 27003:2017 . Overall, the meeting was very productive in that we got through a  long  list of expert comments on the preliminary draft standard, debated the objectives of the project and the standard and reached consensus on most points. In summary: 27003 is to be revised to align with the current 2022 releases of ISO/IEC 27001 , 27002 and 27005 : These changes are  mostly  minor aside from the new section 6.3 on ISMS changes.
Read more

Two dozen information risks that ISO forgot

Image
Selecting the wrong controls - controls that are inappropriate, ineffective, too costly, impracticable, fragile, unnecessary, counterproductive or whatever, often as a result of blind faith in fads and fashions of the day and FOMO e.g. MFA, AI, cyber Failing to select the right controls - controls that are ideal for the particular situation, both now and in perpetuity, for whatever reason - mostly ignorance and prejudice Selecting and implementing controls at the wrong time or in the wrong way (where 'wrong' includes ineffective, inappropriate, sub-optimal e.g. bolting on controls rather than designing and building them in) Inept and inaccurate identification, analysis and quantification of risk, including reliance on p oor quality (incomplete, inaccurate, out of date, misleading, unreliable ...) information about actual risks, particularly subtle and emerging risks plus those involving deliberate concealment and misdirection e.g. fraud, misinformation, disinformation, propagan
Read more

Philosophical phriday - compliance risk

Image
According to a vendor's promotional video interview I saw recently, the 'cybersecurity compliance burden' has allegedly become so significant that [customer] organisations are eagerly buying [their] software tools and services to help them manage and fulfil their obligations. The vendor's argument goes that, instead of accumulating a ragtag bunch of policies and other controls relating to user Identification and Authentication (I&A), for instance, it makes sense to:  Identify all the cybersecurity-related laws, regulations and standards that apply to the organisation; Examine them for any security control requirements relating to, say, I&A; Rationalise the I&A controls down to the smallest set that satisfies all the requirements - the lowest common denominator; Design, implement, use, manage and maintain those I&A controls; Have the I&A controls checked or audited to gain assurance that the compliance requirements are met.  OK so far? Sounds reasonab
Read more

ISMS internal audit priorities

Image
A thread on the ISO27k Forum sparked my imagination over coffee this morning. Hope had previously asked for assistance with an ISO/IEC 27001:2022 audit plan.  Bhushan offered a lengthy and generally sound response explaining how to use a spreadsheet with tabs to plan and record the audit work performed on 100% of the main body clauses and 50% of the 93 Annex A controls, day-by-day. That's OK ... except it wasn't entirely clear that he was interpreting and elaborating on the standard's actual requirements. ISO/IEC 27001 does not explicitly require, for example, that (as Bhushan stated) "ALL the management system clauses from 4 to 10 AND their sub-clauses need to be listed and audited" in an ISMS internal audit, although evidently he interprets it in that way. In clause 9.2.1, the standard states a requirement for internal audits to provide information on whether the ISMS conforms to the organization’s own requirements for the ISMS plus the requirements of the stan
Read more

Reading between the lines of ISO27001 [L O N G]

Image
ISO/IEC 27001 is a succinct, formally-worded standard for two key reasons: It is deliberately generic, being applicable to all manner of organisations regardless of difference in location/s, size, industry, maturity, structure, information risk and security status ... and so on. In effect, it specifies the lowest common denominator - the things that ALL organisations should be doing to manage their information security controls, as a minimum. The hurdle is set low enough that every organisation ought to find value in designing, implementing and operating an I nformation S ecurity M anagement S ystem as laid out in the standard. It is a certifiable standard, explicitly specifying the characteristics that every certified organisation's ISMS is expected to have. Again, it is a minimal specification with no concept of typical, average or maximum security: that is entirely down to the organisations themselves to determine, following the information risk management processes minimally de
Read more

Passionate dispassion

Image
Someone who is actively involved in, or is managing, an activity is patently not independent of it. They may well make a conscious, rational and determined effort to be objective, dispassionately reviewing evidence etc ., but their subconscious/emotional biases/prejudices and beliefs/value-systems will inevitably influence what they do. With the best will in the world, they will struggle to challenge and assess their past decisions and activities, especially if they were "certain" or "determined" or genuinely believed they were "doing the right thing". Furthermore, it is very hard for anyone to review the things they did not do, decisions they did not make or options they did not even consider. Mostly, they remain out of sight or out of the question.
Read more

45 ISO Management Systems Standards

Image
The ISO website  currently lists 45 published M anagement S ystems S tandards: 1. ISO 7101:2023 Healthcare organization management — Management systems for quality in healthcare organizations — Requirements 2. ISO 9001:2015 Quality management systems — Requirements 3. ISO 10012:2003 Measurement management systems — Requirements for measurement processes and measuring equipment 4. ISO 13485:2016 Medical devices — Quality management systems — Requirements for regulatory purposes 5. ISO 14001:2015 Environmental management systems — Requirements with guidance for use 6. ISO 14298:2021 Graphic technology — Management of security printing processes
Read more

Philosophical phriday - a noncompliance ramble

Image
In a previous philosophical phriday post , I moaned about vendors of security compliance support/management tools and services over-promising and under-delivering - an admittedly biased, even cynical opinion piece about the compliance imperative . A recent article in Corporate Compliance Insights notes that "CISOs are not just defenders against cyber threats but also champions of compliance and operational resilience". Hmmm, are CISOs 'compliance champs', really? Today, I'm discussing alternatives to being compliance-driven. How else can organisations drive their information risk, security and related concerns in a positive direction?
Read more

Adaptive SME security Crowdstrike special

Image
As if on cue, along comes a golden opportunity to consider what the Adaptive SME security  approach has to say regarding the Crowdstrike incident: That's not 20/20 hindsight but foresight: I've picked out the most relevant rows from the security controls table published in the guide 24 hours before the incident.  Although Crowdstrike primarily supplies much larger enterprises than SMEs, the incident could equally have afflicted other security software, or indeed operating systems such as Windows and assorted cloud apps commonly used by SMEs. Regardless of the details, it is a wake-up call, an opportunity to consider and respond to the information risks ... and to adapt , accordingly.
Read more