ISO 27001 Control 5.35 Independent review of information security

What is Control 5.35?

ISO 27001 Control 5.35 focuses on independent reviews of information security. It requires organizations to periodically assess their approach to managing security, ensuring it remains suitable, adequate, and effective.

Control Type

Information Security Properties

Cybersecurity Concepts

Operational Capabilities

Security Domains

1. Intro Control 5.35 - Independent Review of Information Security

When it comes to information security, one thing is certain: complacency is the enemy. That’s why ISO 27001 Control 5.35, Independent Review of Information Security, exists. It’s a powerful control to ensure your organization’s security measures stay sharp, relevant, and effective.


1.1 Why Control 5.35?

Think about it this way: if you were running a marathon, you wouldn’t rely solely on your training from six months ago to get you across the finish line. You’d keep assessing your progress, tweaking your training plan, and seeking feedback from experts to stay competitive. Information security works the same way. Regular independent reviews of your security framework ensure your defenses are keeping up with today’s threats and tomorrow’s challenges.

This control emphasizes the importance of an unbiased perspective in evaluating your organization’s information security approach. By having independent professionals scrutinize your systems, you can uncover blind spots, verify compliance with your policies, and spot opportunities for improvement. It’s like having a trusted advisor who tells you what you need to hear, not just what you want to hear.


1.2 Who Should Care About Control 5.35?

If you’re a business owner, CISO, or IT manager, this control is for you. It’s your lifeline for ensuring that your security posture aligns with both your strategic goals and external requirements.

And here’s a bonus: adhering to this control can also boost your ISO 27001 certification audit readiness. Auditors love to see proactive measures like this—it’s evidence that your organization takes security seriously.

2. Objectives of Independent Reviews

Independent reviews are about gaining insights and improving your organization’s overall security posture. Think of them as your organization’s health check, a moment to pause, reflect, and refine your approach. Let’s break down the key objectives of independent reviews under ISO 27001 Control 5.35.


2.1 Ensuring Suitability

Every organization has unique goals, whether it’s protecting customer data, securing intellectual property, or complying with regulatory requirements. But is your information security framework truly aligned with these objectives?

An independent review asks the tough questions:

  • Do your policies and processes reflect your business priorities? For example, if you prioritize customer privacy, is your data encryption strategy up to par?
  • Are your goals realistic and achievable with your current resources? Often, organizations set lofty ambitions without the necessary tools or personnel to back them up.

The review’s purpose here is to ensure that your approach to information security isn’t just a theoretical exercise but a specific, practical strategy designed to meet your organizations specific needs.


2.2 Assessing Adequacy

Even the most well-designed security frameworks can fall short if they don’t adequately address the risks your organization faces. Risks evolve—new technologies, changing regulations, and emerging threats all demand a constant reevaluation of your defenses.

Independent reviews dig deep to answer questions like:

  • Are your controls addressing the risks identified in your risk assessment?
  • Are any key risks being overlooked or underestimated?

This is where a tool like an ISO 27001 Internal Audit Template becomes invaluable. It helps ensure your review covers every corner of your information security landscape, from data handling procedures to access controls.


2.3 Evaluating Effectiveness

Suitability and adequacy are only part of the equation. The ultimate test is whether your controls are working as intended. Are they actively mitigating threats, or are there gaps that attackers could exploit?

Key areas of focus during the review include:

  • Incident History: Have past security incidents been effectively managed and prevented from recurring?
  • Compliance Metrics: Are you meeting internal and external benchmarks for security performance?
  • Control Performance: Are technologies like firewalls, monitoring systems, and encryption tools delivering as expected?

3. Scope of Independent Reviews

Independent reviews under ISO 27001 Control 5.35 are comprehensive by design, delving into every facet of your organization’s information security framework. To truly benefit from these reviews, you need to clearly define their scope. By focusing on People, Processes, and Technologies.


3.1 People: The Human Element

Information security starts with people. Your policies and technologies are only as strong as the individuals who implement and follow them. An independent review evaluates:

  1. Roles and Responsibilities

    • Are key roles, like the CISO or data protection officer, clearly defined?
    • Do employees understand their responsibilities for safeguarding information?
  2. Competence and Training

    • Have team members received adequate training in information security practices?
    • Are training programs tailored to address specific risks and roles?
  3. Behavioral Patterns

    • Is there a culture of security awareness across all levels of the organization?
    • Are incidents of non-compliance addressed effectively?

      Tip: Use training metrics and feedback loops to measure the effectiveness of your security education programs.


3.2 Processes: The Backbone of Security

Processes are the glue that holds your ISMS together. During an independent review, the focus is on ensuring your processes are not only documented but also practical and efficient.

  1. Policies and Procedures

    • Are your policies aligned with your organization’s risk assessment and objectives?
    • Are topic-specific policies (like access control or incident response) up-to-date and accessible?
  2. Workflows and Compliance

    • Are workflows efficient and free from unnecessary bottlenecks?
    • Do they comply with ISO 27001 requirements, relevant regulations, and internal standards?
  3. Incident Management

    • Are there well-defined steps for identifying, reporting, and resolving security incidents?
    • How effectively are lessons learned from incidents integrated into your processes?

3.3 Technologies: Securing the Digital Infrastructure

While people and processes are crucial, technology remains the frontline of your security defense. An independent review should assess:

  1. Hardware and Software

    • Is your hardware properly configured and protected against physical and digital threats?
    • Are software systems patched and updated regularly?

  2. Network Infrastructure

    • Are firewalls, intrusion detection systems, and encryption protocols performing as intended?
    • Is network segmentation used to limit potential damage from breaches?

  3. Integration with Processes

    • Are technologies seamlessly integrated into your workflows?
    • Do they support and enforce policies, like access control or data classification?


    Tip:
    Focus on scalability and adaptability when assessing your technologies. Can your systems handle future growth and evolving threats?


3.4 Bringing the Scope Together

Independent reviews must look at the interplay between people, processes, and technologies. A strong ISMS isn’t built in silos—these three pillars work together to create a cohesive defense.

Next up: Planning and Initiating Reviews—because a well-scoped review is only as good as the plan that brings it to life!

4. Planning and Initiating Reviews

A well-executed independent review doesn’t just happen—it requires thoughtful planning and precise execution. ISO 27001 Control 5.35 emphasizes the importance of both regular and situational reviews to keep your organization’s information security in check.


4.1 Establishing Review Schedules

Consistency is key to maintaining a resilient information security framework. Regularly scheduled reviews ensure your defenses remain relevant and effective over time. But how often should these reviews take place?

  1. Frequency Considerations

    • Annual Reviews: A common baseline for most organizations, providing a holistic overview of your security posture.
    • Quarterly or Biannual Reviews: For high-risk environments or organizations undergoing rapid change, more frequent reviews might be necessary.
  2. Aligning with Other Activities

    • Schedule reviews to complement other audits, such as internal audits or certification assessments, to maximize efficiency.
    • Consider aligning them with fiscal years, major project deadlines, or regulatory reporting periods.
  3. Document the Schedule
    Create a formal review plan that includes dates, responsible parties, and the scope for each review. This ensures accountability and reduces the likelihood of overlooked assessments.


4.2 Identifying Triggers for Additional Reviews

While regular reviews are essential, sometimes the unexpected demands immediate action. Situational reviews provide the flexibility to respond to changes or events that could impact your security framework.

  1. Changes in Laws and Regulations

    • Regulatory updates, such as new data privacy laws or cybersecurity requirements, often necessitate a review.
    • Example: The introduction of GDPR prompted many organizations to reassess their information security policies.
  2. Occurrence of Significant Security Incidents

    • A major breach, phishing attack, or ransomware incident is a wake-up call for an immediate review.
    • Focus: Investigate what went wrong, assess current controls, and implement corrective actions to prevent recurrence.
  3. Introduction of New Business Ventures or Services

    • Expanding into new markets, launching a product, or adopting cloud-based services introduces fresh risks.
    • Example: Moving sensitive operations to a cloud platform might require a review of access controls and encryption policies.
  4. Major Modifications to Existing Information Security Controls

    • Upgrades or changes to technology, processes, or team structures can create vulnerabilities if not properly managed.
    • Example: Replacing an outdated firewall or implementing a new identity management system should trigger a targeted review.


    Checklist Tip
    : Use an ISO 27001 internal audit checklist to ensure your review covers areas such as compatibility, potential gaps, and alignment with organizational goals.


4.3 Steps to Initiate a Review

  1. Define Objectives and Scope

    • Start by revisiting the goals: suitability, adequacy, and effectiveness. Clearly outline what the review will assess.
  2. Select Competent Reviewers

    • Whether internal (e.g., an audit team) or external (e.g., third-party consultants), ensure reviewers have the expertise and independence required for unbiased evaluations.
  3. Communicate the Plan

    • Notify stakeholders about the review’s purpose, scope, and timeline. Transparent communication reduces resistance and fosters collaboration.
  4. Gather Preliminary Data

    • Collect relevant documents, logs, and previous review reports to give reviewers a head start.

4.4 Planning in Action: A Case Study

Imagine your organization just launched a new service that collects sensitive customer data. A situational review triggered by this launch might focus on:

  • Evaluating the data handling process for compliance with privacy laws.
  • Assessing encryption methods used to protect sensitive information.
  • Ensuring employees involved in the service have received appropriate training.

5. Selection of Reviewers

The credibility and effectiveness of an independent review hinge on the individuals conducting it. Selecting the right reviewers ensures an unbiased, thorough, and actionable assessment.


5.1 Criteria for Independence

Independence is non-negotiable when it comes to an effective review. Reviewers must approach the assessment without bias or conflicts of interest to provide an honest evaluation.

  1. No Vested Interest

    • Reviewers should not be involved in the day-to-day operations of the area under review.
    • Example: A department manager reviewing another department’s processes ensures impartiality.
  2. Neutral Reporting Line

    • Reviewers should not report directly to the team or individuals being assessed. This avoids any undue influence on their findings.
  3. External vs. Internal Reviewers

    • While internal teams can bring valuable insights, external reviewers often provide a fresh perspective and are free from internal politics.


    Tip
    : If using internal resources, ensure they are rotated regularly to maintain independence over time.


5.2 Required Competencies

An independent review is only as good as the expertise behind it. Reviewers need a combination of technical knowledge, analytical skills, and familiarity with ISO 27001.

  1. Technical Knowledge

    • Proficiency in information security principles, technologies, and threat landscapes.
    • Example: Understanding encryption protocols, intrusion detection systems, and risk management frameworks.
  2. Familiarity with ISO 27001

    • Reviewers must have a solid understanding of ISO 27001 requirements and how they apply to your organization.
  3. Analytical Skills

    • Ability to assess complex systems, identify weaknesses, and propose practical improvements.
  4. Communication Skills

    • Reviewers should be able to clearly document their findings and present them to stakeholders in an understandable and actionable format.

5.3 Potential Reviewers

Now that you know what to look for, where do you find these qualified and independent individuals? Here are three reliable options:

  1. Internal Audit Teams

    • Pros: Familiar with the organization’s operations and culture. Cost-effective option for routine reviews.
    • Cons: May lack independence if they work closely with the assessed areas.
  2. Independent Departmental Managers

    • Pros: Offer an internal perspective while maintaining some independence.
    • Cons: Their focus may be narrower compared to dedicated audit professionals.
  3. External Organizations Specializing in Information Security Reviews

    • Pros: Provide deep expertise, an outsider’s perspective, and the highest level of independence.
    • Cons: Can be expensive, especially for smaller organizations.

    When to Choose External Reviewers:

    • For initial reviews when establishing an ISMS.
    • For high-stakes situations, such as preparing for certification audits.
    • When internal resources lack the required expertise.

6. Conducting the Review

Now that you’ve planned your review and selected the right team, it’s time to execute. Conducting an independent review requires a systematic approach to uncover valuable insights.

6.1 Methodologies

The success of a review lies in its approach. Different methodologies can be applied based on the scope, objectives, and specific risks being evaluated. Here are three proven techniques to guide your process:

  1. Interviews

    • Purpose: To gather qualitative insights from key stakeholders, such as IT staff, management, and end-users.
    • What to Ask:
      • Are current policies and procedures understood and followed?
      • Have there been any recent challenges or incidents that exposed vulnerabilities?
        Tip: Prepare a structured questionnaire, but leave room for open-ended discussions to uncover issues that might not be on your radar.
  2. Document Analysis

    • Purpose: To review the documentation supporting your information security management system (ISMS).
    • What to Analyze:
      • Information security policies, procedures, and training records.
      • Incident reports and risk assessments.
      • Audit logs and compliance reports.

  3. System Testing

    • Purpose: To evaluate the technical controls protecting your organization’s assets.
    • What to Test:
      • Vulnerability scans and penetration tests.
      • Configuration settings for firewalls, IDS/IPS, and endpoint protection.
      • Access control mechanisms and user privilege levels.

        Tip: Combine manual testing with automated tools for maximum coverage.

6.2 Assessment Areas

An independent review is about understanding how well your ISMS is functioning and identifying opportunities for growth. Focus on these key areas:

  1. Compliance with Information Security Policies

    • Objective: Ensure that organizational policies are being followed consistently.
    • How to Assess:
      • Compare operational practices with documented policies.
      • Identify deviations and understand their root causes.
    • Example: If employees bypass multi-factor authentication, is it due to lack of training or technical difficulties?
  2. Effectiveness of Implemented Controls

    • Objective: Verify that controls are mitigating risks as intended.
    • How to Assess:
      • Review incident reports to evaluate how controls performed during past events.
      • Simulate potential attack scenarios to test control effectiveness.
    • Example: Test whether a recently deployed firewall correctly blocks unauthorized access attempts.
  3. Opportunities for Improvement

    • Objective: Identify gaps and propose enhancements to strengthen your ISMS.
    • How to Assess:
      • Look for recurring issues in incident records.
      • Evaluate whether existing controls are scalable and adaptable to future needs.
    • Example: If phishing emails remain a consistent threat, consider additional user training or advanced email filtering tools.

6.3 Practical Tips for Conducting the Review

  1. Maintain Transparency

    • Communicate the review process clearly to all stakeholders. This reduces resistance and fosters collaboration.
  2. Stay Objective

    • Avoid jumping to conclusions. Let the data and findings guide your assessment.
  3. Document Everything

    • Keep detailed records of your observations, evidence, and analysis. This not only supports your conclusions but also provides a valuable resource for future reviews.
  4. Prioritize Issues

    • Not all findings are created equal. Focus on addressing critical vulnerabilities first, then work on secondary improvements.

6.4 The Review in Action

Imagine your organization recently implemented a new access control policy. During the review:

  • Interviews: IT staff reveal that the policy’s enforcement mechanism sometimes locks out legitimate users.
  • Document Analysis: Logs show that privileged access approvals are delayed, impacting productivity.
  • System Testing: Testing reveals a misconfigured setting in the access control software.

The result? Actionable insights to fine-tune the policy, update configurations, and retrain staff.

7. Reporting Findings

The culmination of an independent review lies in its findings. These findings should capture what’s working and what isn’t and also provide actionable recommendations to guide improvement. Reporting is the bridge between insights and action, and getting it right is crucial.

7.1 Documentation: Recording Observations, Conclusions, and Recommendations

Clear and comprehensive documentation is the foundation of a successful review report. 

  1. What to Document

    • Observations: Key issues, discrepancies, and areas of non-compliance identified during the review.
    • Conclusions: Summarize whether the reviewed processes, controls, and systems meet their objectives (suitability, adequacy, and effectiveness).
    • Recommendations: Actionable steps to address gaps, mitigate risks, and optimize controls.
  2. Structuring the Report

    • Executive Summary: A high-level overview of the review’s purpose, scope, and key findings.
    • Detailed Findings: Organized by category (e.g., people, processes, technologies).
    • Action Plan: Prioritized list of recommendations with timelines and responsible parties.

7.2 Communication: Presenting Findings

The best report is one that inspires action. To achieve this, findings must be communicated effectively to the right audience.

  1. Tailor Your Presentation

    • Initiating Management: Focus on detailed operational insights relevant to their department or team.
    • Top Management: Provide a high-level summary emphasizing strategic implications and compliance.
  2. Use Visuals

    • Include charts, graphs, and heatmaps to make complex data more digestible.
    • Example: A bar graph showing the frequency of incidents related to specific controls can highlight areas needing immediate attention.
  3. Host Review Meetings

    • Schedule a formal meeting to discuss the findings. Encourage feedback and address concerns to ensure alignment on the next steps.

      Tip: Frame recommendations as opportunities for improvement rather than criticisms. This creates a collaborative mindset.

7.3 Record Maintenance: Storing and Accessing Reports

Review reports are not just historical records; they are valuable tools for future assessments and audits. Proper record maintenance ensures they remain useful.

  1. Storage Best Practices

    • Use a secure digital repository for storing reports. Ensure access is limited to authorized personnel.
    • Maintain backups to prevent data loss.
  2. Retention Period

    • Retain reports for at least the duration of your ISO 27001 certification cycle (typically three years). Longer retention may be necessary for regulatory or contractual reasons.
  3. Accessibility

    • Ensure reports are easy to retrieve for follow-up reviews, audits, or external inspections.

      Tip: Keep a log of all reviews conducted, including their scope and results, to identify trends over time.

7.4 The Impact of Effective Reporting

Let’s say your review identified gaps in employee adherence to the company’s data classification policy. A well-documented report might include:

  • Observation: Employees aren’t consistently labeling emails with the correct data classification.
  • Conclusion: Training gaps and a lack of automated labeling tools are causing the issue.
  • Recommendation: Implement additional training and deploy an email plugin to enforce labeling automatically.

When presented to top management with visuals showing the frequency of misclassified emails, the recommendation gains urgency and is likely to be approved for immediate action.

8. Addressing Identified Issues

A thorough independent review is only valuable if the findings lead to meaningful action. Addressing identified issues is the phase where insights transform into improvements. This involves initiating corrective actions and ensuring their implementation is effective through continuous monitoring and follow-up.


8.1 Initiating Corrective Actions

Corrective actions are the immediate steps taken to address gaps, vulnerabilities, or inadequacies highlighted in the review. Without these, the review’s efforts lose their impact.

  1. Prioritizing Issues

    • Use a risk-based approach to rank findings. Focus on high-risk vulnerabilities and areas with significant business impact first.
    • Example: A misconfigured firewall rule that allows unauthorized access would demand urgent attention, while outdated training materials might be a lower priority.
  2. Developing an Action Plan

    • Define Actions: Clearly outline what needs to be fixed and how.
    • Assign Responsibilities: Allocate tasks to specific individuals or teams, ensuring accountability.
    • Set Deadlines: Include realistic timelines for completion to maintain momentum.
  3. Engaging Stakeholders

    • Communicate the plan to all involved parties, from IT staff implementing technical fixes to management overseeing strategic changes.
    • Example: If new training programs are required, HR and security teams must collaborate to design and deploy them effectively.
  4. Resource Allocation

    • Ensure that adequate resources—both human and technological—are available to execute the corrective actions.

8.2 Monitoring and Follow-Up

The work doesn’t end once corrective actions are initiated. Ongoing monitoring and follow-up to ensure these measures are both implemented and effective.

  1. Tracking Progress

    • Use project management tools or spreadsheets to track each corrective action, noting its status (e.g., pending, in progress, completed).
    • Include milestones to measure incremental progress, especially for complex issues.
  2. Verification

    • Conduct tests or reviews to confirm that actions have resolved the identified issues.
    • Example: If the review found weaknesses in access control, verify that new access rules are functioning as intended and no unauthorized access occurs.
  3. Measuring Effectiveness

    • Evaluate whether the corrective measures have reduced risks to an acceptable level.
    • Example: After deploying advanced phishing filters, track phishing incidents to see if they decrease.
  4. Continuous Feedback Loop

    • Incorporate lessons learned from the corrective actions into future reviews and updates to policies, processes, and technologies.
    • Example: A discovered training gap could lead to a new annual refresher course on key security practices.
  5. Reporting Progress to Management

    • Provide regular updates on the status of corrective actions to the management team. Use clear metrics to demonstrate progress and effectiveness.

8.3 Practical Example: Addressing a Major Finding

Finding: The review identified outdated antivirus software across multiple endpoints, leaving the network vulnerable to malware.
Corrective Action Plan:

  • Update all endpoints with the latest antivirus software version.
  • Train employees on recognizing malware warning signs.
  • Implement automated updates to ensure antivirus software stays current.

Monitoring:

  • IT tracks software updates, ensuring all systems are compliant within two weeks.
  • Follow-up testing confirms that the antivirus is functioning properly and logging threats accurately.

Outcome: The organization reduces its malware risk and gains better visibility into endpoint protection.

9. Integration with Other Standards

The effectiveness of ISO 27001 Control 5.35 is amplified when integrated with complementary standards. Two key players in the realm of information security reviews are ISO/IEC 27007 and ISO/IEC TS 27008. These standards provide deeper insights and frameworks for managing audits and evaluating controls, making them invaluable companions to Control 5.35.


9.1 ISO/IEC 27007: Guidance on Managing Information Security Audits

ISO/IEC 27007 focuses on the how of conducting information security audits. While Control 5.35 emphasizes the need for independent reviews, ISO/IEC 27007 offers a structured methodology for executing them effectively.

  1. Key Features of ISO/IEC 27007

    • Audit Planning: Guidance on defining the scope, objectives, and criteria for audits.
    • Auditor Competence: Emphasizes the importance of selecting auditors with relevant knowledge and skills.
    • Audit Execution: Step-by-step guidance on conducting audits, from gathering evidence to analyzing findings.
    • Reporting and Follow-Up: Detailed instructions on preparing audit reports and tracking corrective actions.

  2. How It Complements Control 5.35

    • Provides a more granular approach to planning and executing reviews.
    • Offers best practices for ensuring consistency and reliability in the review process.
    • Enhances the quality of reporting by introducing standardized formats and procedures.

  3. Practical Tip

    • Use ISO/IEC 27007’s guidance to refine your independent review process. For example, align your review methodology with its audit lifecycle stages—planning, execution, and follow-up.

9.2 ISO/IEC TS 27008: Guidelines for Auditors on Information Security Controls

ISO/IEC TS 27008 dives into the specifics of assessing information security controls. While Control 5.35 requires evaluating the suitability, adequacy, and effectiveness of controls, this standard provides auditors with the tools to do so with precision.

  1. Key Features of ISO/IEC TS 27008

    • Control Selection: Helps auditors focus on the most relevant controls based on organizational context.
    • Assessment Techniques: Outlines methods for testing and evaluating control performance.
    • Risk-Based Approach: Encourages prioritizing controls that address the highest risks.
  2. How It Complements Control 5.35

    • Provides deeper insights into evaluating technical controls, such as encryption protocols or firewalls.
    • Enhances the objectivity of reviews by offering standardized assessment criteria.
    • Bridges the gap between high-level review goals and detailed control assessments.
  3. Practical Tip

    • When assessing the effectiveness of implemented controls during your independent review, use ISO/IEC TS 27008 as a reference to ensure thorough and consistent evaluations.

9.3 Why Integration Matters

Integrating Control 5.35 with ISO/IEC 27007 and ISO/IEC TS 27008 ensures a more comprehensive and reliable approach to independent reviews. Here’s how they work together:

Control/StandardFocus AreaKey Benefit
ISO 27001 Control 5.35High-level framework for independent reviews.Ensures regular, independent evaluations.
ISO/IEC 27007Audit process and methodology.Provides structure and consistency to reviews.
ISO/IEC TS 27008Detailed assessment of security controls.Enhances control evaluation with in-depth tools.

9.4 Maximizing the Value of Integration

  1. Training for Reviewers

    • Ensure that internal or external reviewers are familiar with these standards to maximize the value of their guidance.
  2. Unified Reporting

    • Use the templates and reporting formats suggested in ISO/IEC 27007 and TS 27008 to standardize documentation across reviews.
  3. Continuous Improvement

    • Regularly update your review process by incorporating new insights and best practices from these standards.

10. Conclusion

Independent reviews are a compliance requirement and are the backbone of a resilient and effective ISMS. Regularly evaluating your approach, addressing gaps, and striving for improvement, your organization can stay ahead of new threats and maintain trust with stakeholders. Let’s wrap up by focusing on two critical aspects: continuous improvement and organizational commitment.


10.1 Continuous Improvement

Security threats are constantly improving, and so should your defenses. Independent reviews are a powerful tool for driving continuous improvement within your ISMS.

  1. Learning from Findings

    • Each review provides insights into what’s working and what isn’t. Use these findings as a roadmap for targeted enhancements.
    • Example: If access control issues are a recurring theme, focus on implementing stronger authentication methods or refining role-based access permissions.
  2. Adapting to Change

    • Significant organizational changes—like adopting new technologies, entering new markets, or responding to regulatory updates—require a proactive approach.
    • Independent reviews help ensure your ISMS evolves alongside your business needs.
  3. Benchmarking Progress

    • Track your improvements over time by comparing review results. This helps identify trends, measure the impact of corrective actions, and highlight areas that still need attention.
  4. Building a Culture of Security

    • When reviews are seen as opportunities for growth rather than mere audits, they contribute to a culture that values and prioritizes security.


    Tip
    : Incorporate findings from your ISO 27001 Internal Audit Template into strategic planning sessions to align security improvements with organizational goals.


10.2 Organizational Commitment

For independent reviews to succeed, they need more than just policies—they require unwavering support from the top.

  1. Management Buy-In

    • Senior leaders must champion the importance of independent reviews, setting the tone for accountability and transparency.
    • How to Get Buy-In: Highlight the tangible benefits of reviews, such as reduced risk exposure, improved compliance, and enhanced customer trust.
  2. Resource Allocation

    • Reviews demand time, expertise, and sometimes external resources. Organizations must allocate sufficient budgets and personnel to uphold the integrity of the process.
    • Example: Investing in qualified external auditors or advanced tools for system testing can yield long-term benefits by identifying critical vulnerabilities.
  3. Setting the Standard

    • When management actively supports and participates in the review process, it sends a clear message: security is not optional—it’s essential.
  4. Regular Review Cycles

    • Commit to a schedule of periodic and situational reviews, and ensure follow-through on corrective actions.

10.3 Final Thoughts

ISO 27001 Control 5.35 is about compliance and creating a mindset of vigilance and adaptability. By committing to regular, independent reviews and integrating their findings into your broader strategy, you’re managing and mastering information security.