10 Internal Audits
An organization may have:
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An approved ISMS.
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Security policies.
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A risk register.
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A Risk Treatment Plan.
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A Statement of Applicability.
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Annex A controls.
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Control owners.
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Security evidence.
But an important question remains:
Is the ISMS actually operating as intended?
This is where internal audit becomes essential.
An ISO/IEC 27001 internal audit provides independent and objective assurance about whether the Information Security Management System:
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Meets organizational requirements.
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Meets applicable ISO/IEC 27001 requirements.
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Has been effectively implemented.
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Is being maintained.
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Produces sufficient evidence.
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Identifies and addresses weaknesses.
The internal-audit lifecycle can be visualized as:
Audit Program ↓Audit Scope ↓Audit Criteria ↓Audit Planning ↓Evidence Collection ↓Interviews ↓Sampling ↓Control Testing ↓Findings ↓Audit Report ↓Corrective Actions ↓Retesting ↓ClosureFor GRC professionals, internal audit is especially important because it connects governance, controls, evidence, assurance, corrective action, and certification readiness.
Learning Objectives
Section titled “Learning Objectives”By the end of this lesson, you will be able to:
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Explain the purpose of an ISO/IEC 27001 internal audit.
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Understand the internal-audit requirement.
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Develop an audit program.
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Define audit scope and criteria.
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Maintain auditor objectivity and impartiality.
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Build an audit plan.
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Prepare an evidence request list.
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Conduct audit interviews.
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Select appropriate samples.
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Test control design.
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Test operating effectiveness.
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Document audit evidence.
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Identify audit findings.
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Understand nonconformities.
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Perform root-cause analysis.
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Develop corrective actions.
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Track remediation.
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Retest corrective actions.
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Prepare an internal audit report.
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Use audit results for management review.
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Support certification readiness.
1. What Is an Internal Audit?
Section titled “1. What Is an Internal Audit?”An internal audit is a structured evaluation of the ISMS.
It asks:
Are requirements defined? ↓Are processes implemented? ↓Are controls operating? ↓Is evidence available? ↓Are weaknesses identified? ↓Are weaknesses corrected?The objective is not simply to find problems.
The objective is to determine whether the ISMS is conforming and effectively implemented and maintained.
2. Internal Audit in ISO/IEC 27001
Section titled “2. Internal Audit in ISO/IEC 27001”ISO/IEC 27001 requires organizations to conduct internal audits at planned intervals.
The organization should determine whether the ISMS:
Conforms to ↓Organizational ISMS Requirements+ISO/IEC 27001 Requirements
and
Is Effectively Implemented+MaintainedThis makes internal audit part of the ISMS performance-evaluation process.
3. Internal Audit Is Not Certification Audit
Section titled “3. Internal Audit Is Not Certification Audit”These activities are different.
Internal Audit
Section titled “Internal Audit”Performed on behalf of the organization to evaluate its own ISMS.
Certification Audit
Section titled “Certification Audit”Performed by an independent certification body to determine whether the organization meets certification requirements.
A strong internal audit helps prepare the organization for external certification.
4. Internal Audit Is Not Control Operation
Section titled “4. Internal Audit Is Not Control Operation”Suppose the IAM team performs:
Quarterly Privileged Access ReviewThat is a control.
When an auditor independently examines whether those reviews occurred correctly, that is:
Control Testing / Internal AuditThese responsibilities should remain appropriately separated.
5. Why Internal Audit Matters
Section titled “5. Why Internal Audit Matters”Without internal audit, management may assume:
Policy Exists =Control WorksBut this may not be true.
Internal audit tests reality.
Example:
Policy:Access reviewed quarterly
Evidence:Q1 — CompletedQ2 — MissingQ3 — CompletedQ4 — IncompleteThe audit reveals that the process does not operate consistently.
6. Assurance
Section titled “6. Assurance”Internal audit provides assurance.
Assurance asks:
Can management reasonably rely on the ISMS and its controls?
This requires evidence rather than assumption.
7. The Audit Program
Section titled “7. The Audit Program”Organizations should establish an audit program.
The program defines:
What will be audited?
When?
How often?
By whom?
Using what criteria?It should consider the importance of relevant processes and previous audit results.
8. Risk-Based Audit Planning
Section titled “8. Risk-Based Audit Planning”Not every area necessarily requires identical attention.
Higher-risk areas may receive greater audit focus.
Example:
Privileged Access→ High Risk→ More Frequent / Deeper Testing
Low-Risk Administrative Process→ Lower Risk→ Less Intensive TestingThis supports risk-based assurance.
9. Factors Affecting Audit Priority
Section titled “9. Factors Affecting Audit Priority”Consider:
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Risk level.
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Previous findings.
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Significant changes.
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Incidents.
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New technology.
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Regulatory requirements.
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Control failures.
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Management concerns.
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Certification schedule.
These factors can influence the audit program.
10. Example Annual Audit Program
Section titled “10. Example Annual Audit Program”| Quarter | Audit Area |
|---|---|
| Q1 | ISMS Governance & Risk |
| Q2 | IAM & Access Controls |
| Q3 | Supplier & Cloud Security |
| Q4 | Incident Response & Resilience |
Another organization may conduct one comprehensive annual audit.
The model should fit organizational needs.
11. Audit Scope
Section titled “11. Audit Scope”Audit scope defines the boundaries of the audit.
Example:
Audit Scope:
Production AWS Environment
IAM Processes
Security Logging
Incident Response
Supporting PoliciesClear scope prevents ambiguity.
12. Scope Questions
Section titled “12. Scope Questions”Ask:
Which business units?
Which locations?
Which systems?
Which processes?
Which controls?
Which period?Example:
Audit Period:01 January – 30 June 202613. Audit Criteria
Section titled “13. Audit Criteria”Audit criteria define what the auditor evaluates against.
Possible criteria include:
ISO/IEC 27001 Requirements
Statement of Applicability
Internal Policies
Security Standards
Procedures
Legal Requirements
Contractual RequirementsThe auditor needs a defined benchmark.
14. Example Audit Criteria
Section titled “14. Example Audit Criteria”For access management:
ISO Requirements+Access Control Policy+IAM Standard+Joiner-Mover-Leaver Procedure+SoA ControlsThese collectively form the audit criteria.
15. Auditor Objectivity and Impartiality
Section titled “15. Auditor Objectivity and Impartiality”Internal audits should be conducted objectively and impartially.
A basic principle is:
Avoid auditing your own work where this would compromise objectivity.
Example:
IAM Administrator ↓Operates IAM Control
Should not independently conclude ↓Own control is effective16. Internal Auditor Options
Section titled “16. Internal Auditor Options”Auditors may come from:
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Internal audit.
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GRC.
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Another independent department.
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Qualified external consultants.
The important consideration is appropriate competence and objectivity.
17. Auditor Competence
Section titled “17. Auditor Competence”Auditors should understand:
ISO/IEC 27001
Audit Techniques
Risk Management
Control Testing
Evidence Evaluation
Relevant TechnologyNot every auditor needs to be a deep technical engineer, but sufficient competence is necessary.
18. Audit Planning
Section titled “18. Audit Planning”Before fieldwork begins, prepare an audit plan.
A practical plan contains:
Audit Objective
Scope
Criteria
Audit Period
Auditor
Stakeholders
Processes
Controls
Schedule
Evidence Requirements19. Audit Objective
Section titled “19. Audit Objective”Example:
Evaluate whether identity and access management controls are appropriately designed, implemented, and operating consistently with ISMS requirements.
The objective should be clear.
20. Audit Timeline
Section titled “20. Audit Timeline”Example:
Week 1Planning
Week 2Evidence Collection
Week 3Interviews & Testing
Week 4Findings Validation
Week 5Audit ReportTimelines help coordinate stakeholders.
21. Opening Meeting
Section titled “21. Opening Meeting”An internal audit commonly begins with an opening meeting.
Discuss:
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Objective.
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Scope.
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Criteria.
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Timeline.
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Evidence requests.
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Interviews.
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Communication.
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Escalation.
This establishes expectations.
22. Evidence Request List
Section titled “22. Evidence Request List”Before testing, request relevant documentation.
Example:
Information Security Policy
Risk Register
Risk Treatment Plan
Statement of Applicability
Access Review Reports
Security Training Records
Incident Records
Vendor Assessments
Vulnerability Reports
Backup Test Results23. Evidence Types
Section titled “23. Evidence Types”Audit evidence may include:
Documents
Reports
System Configurations
Tickets
Logs
Screenshots
Interview Responses
Observations
System DemonstrationsStrong conclusions usually rely on sufficient and appropriate evidence.
24. Evidence Quality
Section titled “24. Evidence Quality”Good evidence should be:
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Relevant.
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Reliable.
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Traceable.
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Appropriate to the period.
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Sufficient for the conclusion.
Example:
A screenshot from today may not prove that a quarterly control operated throughout the previous year.
25. Evidence Hierarchy
Section titled “25. Evidence Hierarchy”Evidence strength varies.
For example:
Verbal Statement ↓Procedure ↓System Report ↓System-Generated Evidence ↓Corroborated EvidenceAuditors should evaluate reliability rather than accept everything at face value.
26. Inquiry Alone Is Usually Insufficient
Section titled “26. Inquiry Alone Is Usually Insufficient”Control owner says:
“We review access every quarter.”
This is useful information.
But the auditor should request evidence.
For example:
Q1 Access Review
Q2 Access Review
Q3 Access Review
Q4 Access Review27. Audit Interviews
Section titled “27. Audit Interviews”Interviews help understand:
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Process design.
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Roles.
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Control execution.
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Exceptions.
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Evidence.
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Challenges.
Interviews should complement evidence testing.
28. Example Interview Questions
Section titled “28. Example Interview Questions”For access management:
How are users provisioned?
Who approves access?
How are privileged accounts managed?
How often is access reviewed?
What happens when someone leaves?
How are exceptions handled?29. Walkthrough
Section titled “29. Walkthrough”A walkthrough follows a process from beginning to end.
Example:
New Employee ↓Manager Request ↓Approval ↓Account Creation ↓Access Provisioning ↓EvidenceWalkthroughs help auditors understand control design.
30. Design Effectiveness
Section titled “30. Design Effectiveness”The first question is:
Is the control appropriately designed to address its intended objective or risk?
Example:
Risk:
Unauthorized privileged accessControl:
Privileged access reviewed once every five years.Even if performed perfectly, the design may be insufficient.
31. Design Test Questions
Section titled “31. Design Test Questions”Ask:
Is the control clearly defined?
Does it address the risk?
Is ownership defined?
Is frequency appropriate?
Is scope appropriate?
Is evidence produced?32. Operating Effectiveness
Section titled “32. Operating Effectiveness”Next ask:
Did the control operate as designed during the audit period?
Example:
Control:
Quarterly access reviewAudit period:
12 monthsExpected:
4 reviewsActual:
3 reviewsThis indicates an operating exception.
33. Control Population
Section titled “33. Control Population”Before sampling, identify the complete population.
Example:
Control:New user access approval
Population:850 user access requests during audit periodThe population should be complete enough to support sample selection.
34. Sampling
Section titled “34. Sampling”Auditors often cannot test every transaction.
Instead:
Population ↓Sample ↓Evidence Testing ↓ConclusionSample size depends on audit methodology and circumstances.
35. Sampling Considerations
Section titled “35. Sampling Considerations”Consider:
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Population size.
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Control frequency.
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Risk.
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Automation.
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Previous findings.
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Expected exceptions.
There is no universal sample size appropriate for every audit.
36. Sample Selection
Section titled “36. Sample Selection”Samples should avoid inappropriate bias.
Possible approaches include:
Random
Systematic
Judgmental
Risk-BasedDocument the approach.
37. Example — User Provisioning
Section titled “37. Example — User Provisioning”Population:
500 New AccountsSample:
25 AccountsFor each sample, test:
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Request.
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Approval.
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Access.
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Timing.
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Evidence.
38. Example — Quarterly Control
Section titled “38. Example — Quarterly Control”Control:
Quarterly privileged access reviewPopulation:
4 ReviewsThe auditor may test all four because the population is small.
39. Automated Controls
Section titled “39. Automated Controls”For an automated control, test:
Configuration
Logic
Access to Modify
Change Management
Exceptions
EvidenceExample:
Cloud policy automatically blocks public storage.Do not merely test one blocked event.
Verify the policy itself.
40. Manual Controls
Section titled “40. Manual Controls”For a manual control, evaluate:
Who performs it?
How often?
What information is reviewed?
How are decisions recorded?
How are exceptions remediated?Manual controls often require transaction sampling.
41. Hybrid Controls
Section titled “41. Hybrid Controls”Example:
Automated Vulnerability Scanner ↓Human Reviews Results ↓Engineering RemediatesThe auditor may need to test both automated and manual components.
42. Testing ISMS Requirements
Section titled “42. Testing ISMS Requirements”Internal audit should not focus only on Annex A.
The audit program should also cover applicable ISMS requirements.
Examples:
Scope
Leadership
Risk Assessment
Objectives
Competence
Document Control
Internal Audit
Management Review
Corrective ActionThis is critical for certification readiness.
43. Testing Risk Management
Section titled “43. Testing Risk Management”Auditor may inspect:
Risk Methodology
Risk Register
Risk Owners
Treatment Decisions
Risk Acceptance
Review RecordsQuestions include:
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Is the methodology followed?
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Are risks current?
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Are owners assigned?
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Are treatments tracked?
44. Testing the SoA
Section titled “44. Testing the SoA”Auditor may select SoA entries and verify:
Applicability ↓Implementation ↓Ownership ↓EvidenceExample:
SoA:MFA Implemented
Evidence:MFA Coverage = 82%The status may require correction.
45. Testing Policies
Section titled “45. Testing Policies”Auditor should determine:
Policy Exists?
Approved?
Current?
Communicated?
Implemented?
Followed?Having a policy document alone does not prove conformity.
46. Testing Security Awareness
Section titled “46. Testing Security Awareness”Evidence may include:
Training Content
Completion Records
New Hire Training
Phishing Exercises
ExceptionsThe auditor may compare training population against employee population.
47. Testing Supplier Security
Section titled “47. Testing Supplier Security”Sample vendor records.
Check:
Security Assessment
Risk Rating
Approval
Contract Requirements
Monitoring
Reassessment48. Testing Vulnerability Management
Section titled “48. Testing Vulnerability Management”Review:
Scanning Coverage
Severity Classification
Remediation SLA
Exceptions
Overdue Vulnerabilities
Rescan Evidence49. Testing Incident Management
Section titled “49. Testing Incident Management”Select incident samples.
Review:
Detection
Classification
Escalation
Response
Evidence
Closure
Lessons Learned50. Testing Backup Controls
Section titled “50. Testing Backup Controls”Review:
Backup Configuration
Backup Completion
Failures
Recovery Tests
Retention
EncryptionRemember:
Successful Backup≠Successful Recovery51. Testing Access Reviews
Section titled “51. Testing Access Reviews”For each sampled review:
Correct Population?
Correct Reviewer?
Completed on Time?
Access Decisions Documented?
Removals Completed?
Evidence Retained?52. Audit Working Papers
Section titled “52. Audit Working Papers”Auditors should maintain documentation supporting their work.
A working paper may contain:
Control
Audit Procedure
Population
Sample
Evidence
Exceptions
ConclusionThis creates an audit trail.
53. Example Control Testing Worksheet
Section titled “53. Example Control Testing Worksheet”| Field | Example |
|---|---|
| Control | Quarterly Access Review |
| Population | 4 |
| Sample | 4 |
| Evidence | Review Reports |
| Exceptions | Q2 Missing |
| Conclusion | Ineffective |
54. Audit Trail
Section titled “54. Audit Trail”A reviewer should be able to understand:
What Was Tested ↓How It Was Tested ↓What Evidence Was Used ↓What Was Found ↓How Conclusion Was ReachedGood documentation supports defensibility.
55. Audit Findings
Section titled “55. Audit Findings”A finding identifies a condition requiring attention.
Findings may include:
Nonconformity
Control Deficiency
Observation
Opportunity for ImprovementOrganizations may use different classifications.
56. What Is a Nonconformity?
Section titled “56. What Is a Nonconformity?”A nonconformity occurs when a requirement is not fulfilled.
Example:
Requirement:
Privileged access reviews must occur quarterly.Evidence:
No reviews performed for six months.Result:
Nonconformity57. Major vs Minor Nonconformity
Section titled “57. Major vs Minor Nonconformity”Organizations and certification bodies may distinguish between different levels of nonconformity.
A major issue generally represents a significant or systemic failure.
A minor issue generally represents a more limited lapse that does not necessarily indicate complete system breakdown.
Classification should follow the organization’s audit methodology and applicable certification practices.
58. Example Minor Issue
Section titled “58. Example Minor Issue”Requirement:Quarterly access review
Evidence:Three of four reviews completed
Issue:One review completed lateDepending on context and methodology, this could represent a limited nonconformity.
59. Example Major Issue
Section titled “59. Example Major Issue”Requirement:Information security risk assessment
Evidence:No defined methodology
No current risk register
No documented risk assessmentThis could indicate systemic failure of a core ISMS process.
60. Observation
Section titled “60. Observation”An observation may identify a weakness that does not necessarily constitute a formal nonconformity.
Example:
Vendor reassessment process exists,but reporting could be improved.61. Opportunity for Improvement
Section titled “61. Opportunity for Improvement”An OFI identifies a potential improvement.
Example:
Current:Manual evidence collection
Opportunity:Automate evidence collectionOFIs should not be used to disguise actual nonconformities.
62. Writing Strong Findings
Section titled “62. Writing Strong Findings”A good finding should explain:
Criteria
Condition
Evidence
Risk / ImpactExample:
The Access Control Standard requires quarterly privileged-access reviews. The audit found that the Q2 2026 review was not performed for 18 production applications, increasing the risk that inappropriate privileged access could remain undetected.
63. Weak Finding
Section titled “63. Weak Finding”Avoid:
IAM is bad.This provides no usable information.
64. Strong Finding Structure
Section titled “64. Strong Finding Structure”Use:
Requirement ↓Observed Condition ↓Evidence ↓ImpactThis makes remediation easier.
65. Findings Validation
Section titled “65. Findings Validation”Before issuing the final report:
Discuss Finding ↓Confirm Facts ↓Review Evidence ↓Resolve Factual Errors ↓FinalizeAuditees do not need to agree with every conclusion, but factual accuracy is important.
66. Closing Meeting
Section titled “66. Closing Meeting”The closing meeting may cover:
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Audit scope completed.
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Significant findings.
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Nonconformities.
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Positive observations.
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Next steps.
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Corrective-action expectations.
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Reporting timeline.
Avoid surprising management with major issues for the first time in the final report where practical.
67. Internal Audit Report
Section titled “67. Internal Audit Report”A practical report includes:
Executive Summary
Audit Objective
Scope
Criteria
Methodology
Overall Conclusion
Findings
Observations
Recommendations / Improvement Areas
Management Responses
Corrective Actions68. Executive Summary
Section titled “68. Executive Summary”Management usually needs:
Overall ISMS Status
Major Issues
Material Risks
Recurring Findings
Certification Concerns
Required DecisionsKeep this concise and decision oriented.
69. Audit Opinion
Section titled “69. Audit Opinion”Depending on methodology, the auditor may conclude:
Effective
Generally Effective with Improvements Required
Partially Effective
IneffectiveUse only categories defined by the organization’s audit framework.
70. Audit Findings Register
Section titled “70. Audit Findings Register”Create a centralized register.
Recommended fields:
| Field |
|---|
| Finding ID |
| Audit |
| Requirement |
| Finding |
| Severity |
| Risk |
| Owner |
| Corrective Action |
| Target Date |
| Status |
| Retest Result |
71. Corrective Action
Section titled “71. Corrective Action”A finding should lead to appropriate correction and corrective action.
The objective is not only:
Fix the Samplebut also:
Understand Why It Happened ↓Address Root Cause ↓Prevent Recurrence72. Correction vs Corrective Action
Section titled “72. Correction vs Corrective Action”Example finding:
Five terminated employees retain access.Correction
Section titled “Correction”Disable five accounts.Corrective Action
Section titled “Corrective Action”Fix HR-to-IAM offboarding workflowto prevent recurrence.Both may be necessary.
73. Root Cause Analysis
Section titled “73. Root Cause Analysis”Ask:
Why did the failure occur?
Possible causes:
Process Gap
Technology Failure
Poor Ownership
Training Gap
Resource Constraint
Manual Error
Governance Failure74. Five Whys Example
Section titled “74. Five Whys Example”Problem:
Terminated employee retained access.Why?
IAM never received termination notice.Why?
HR process relies on email.Why?
No automated integration exists.Why?
Integration was never included in IAM design.Potential root cause:
Incomplete offboarding process design.75. Corrective Action Plan
Section titled “75. Corrective Action Plan”Example:
Finding:Delayed account termination
Root Cause:Manual HR notification
Corrective Action:Integrate HRIS with identity platform
Owner:IAM Director
Target:31 January 202776. Corrective Action Ownership
Section titled “76. Corrective Action Ownership”Every corrective action should have:
Owner
Action
Target Date
StatusWithout ownership, findings frequently remain unresolved.
77. Corrective Action Tracking
Section titled “77. Corrective Action Tracking”Statuses may include:
Open
Planned
In Progress
Blocked
Ready for Retest
ClosedGRC can monitor progress.
78. Overdue Findings
Section titled “78. Overdue Findings”Example:
High Finding ↓Target Date Missed ↓Escalation ↓Risk ReviewSignificant overdue findings should not remain invisible.
79. Retesting
Section titled “79. Retesting”A finding should not necessarily be closed because the owner says:
Fixed.The auditor or appropriate assurance function should verify.
Corrective Action ↓Evidence ↓Retest ↓Effective?80. Retest Example
Section titled “80. Retest Example”Original finding:
Quarterly access reviews missing.Corrective action:
Automated review workflow implemented.Retest:
Review latest quarter
Verify complete population
Verify approvals
Verify removalsIf successful:
Finding Closed81. Failed Retest
Section titled “81. Failed Retest”If remediation does not work:
Retest Failed ↓Finding Remains Open ↓Additional Corrective ActionDo not close findings simply to improve metrics.
82. Recurring Findings
Section titled “82. Recurring Findings”Repeated findings may indicate:
Weak Root Cause Analysis
Poor Governance
Insufficient Ownership
Ineffective Corrective ActionRecurring issues deserve management attention.
83. Audit Metrics
Section titled “83. Audit Metrics”Useful metrics include:
Audits Completed
Open Findings
High-Risk Findings
Overdue Findings
Average Closure Time
Repeat Findings
Retest Failure RateMetrics should support decisions.
84. Example KRI
Section titled “84. Example KRI”KRI:Number of overdue High-risk audit findings
Tolerance:0This can support management escalation.
85. Audit and Management Review
Section titled “85. Audit and Management Review”Internal audit results should feed management review.
Management may need visibility into:
Audit Results
Major Nonconformities
Control Failures
Corrective Action Status
Recurring Issues
Certification ReadinessThis supports leadership oversight.
86. Internal Audit and Certification
Section titled “86. Internal Audit and Certification”Before certification, internal audit should provide confidence that:
ISMS Requirements ↓Implemented
Controls ↓Operating
Evidence ↓Available
Findings ↓ManagedInternal audit is not merely a paperwork requirement before certification.
87. Certification Readiness Review
Section titled “87. Certification Readiness Review”Before external audit, verify:
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ISMS scope current.
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Policies approved.
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Risk assessment current.
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RTP current.
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SoA current.
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Internal audit completed.
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Management review completed.
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Findings managed.
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Evidence available.
These provide a strong certification foundation.
88. Common Internal Audit Mistakes
Section titled “88. Common Internal Audit Mistakes”Mistake 1 — Auditing Only Annex A
Section titled “Mistake 1 — Auditing Only Annex A”The ISMS clauses also need coverage.
Mistake 2 — Auditor Tests Own Work
Section titled “Mistake 2 — Auditor Tests Own Work”Objectivity may be compromised.
Mistake 3 — Checklist-Only Audit
Section titled “Mistake 3 — Checklist-Only Audit”Policy exists?Yes.No effectiveness testing occurs.
Mistake 4 — Inquiry Without Evidence
Section titled “Mistake 4 — Inquiry Without Evidence”Management statements are accepted without validation.
Mistake 5 — Poor Sampling
Section titled “Mistake 5 — Poor Sampling”Samples do not support the audit conclusion.
Mistake 6 — No Population Validation
Section titled “Mistake 6 — No Population Validation”The auditor tests a sample from an incomplete population.
Mistake 7 — Vague Findings
Section titled “Mistake 7 — Vague Findings”Stakeholders cannot understand what failed.
Mistake 8 — Fixing Symptoms Only
Section titled “Mistake 8 — Fixing Symptoms Only”Root cause remains.
Mistake 9 — Findings Closed Without Retesting
Section titled “Mistake 9 — Findings Closed Without Retesting”Remediation effectiveness is unknown.
Mistake 10 — Audit Performed Only Before Certification
Section titled “Mistake 10 — Audit Performed Only Before Certification”Internal audit should support ongoing improvement.
89. Weak Audit Approach
Section titled “89. Weak Audit Approach”Ask:Do you have an access policy?
Answer:Yes.
Result:Pass.This provides little assurance.
90. Strong Audit Approach
Section titled “90. Strong Audit Approach”Review Policy ↓Review Control Design ↓Identify Population ↓Select Samples ↓Inspect Evidence ↓Interview Owner ↓Test Exceptions ↓Conclude EffectivenessThis provides meaningful assurance.
91. Practical Activity — Build Internal Audit Plan
Section titled “91. Practical Activity — Build Internal Audit Plan”Create:
01 ISO Internal Audit PlanInclude:
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Audit objective.
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Scope.
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Criteria.
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Audit period.
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Auditor.
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Processes.
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Controls.
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Stakeholders.
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Schedule.
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Deliverables.
92. Practical Activity — Build Audit Checklist
Section titled “92. Practical Activity — Build Audit Checklist”Create:
02 ISO Internal Audit ChecklistRecommended fields:
| Field |
|---|
| Requirement |
| Audit Question |
| Evidence Expected |
| Evidence Reviewed |
| Result |
| Notes |
Include both ISMS requirements and relevant Annex A controls.
93. Practical Activity — Evidence Request List
Section titled “93. Practical Activity — Evidence Request List”Create:
03 Audit Evidence Request ListUse:
| Request | Owner | Due Date | Status |
|---|
Include:
Policies
Risk Register
RTP
SoA
Control Evidence
Audit Logs
Training Records
Vendor Records
Incident Records94. Practical Activity — Control Testing Worksheet
Section titled “94. Practical Activity — Control Testing Worksheet”Create:
04 Control Testing WorksheetFields:
Control ID
Control Objective
Control Owner
Frequency
Population
Sample
Test Procedure
Evidence
Exceptions
Design Conclusion
Operating Conclusion95. Practical Activity — Audit Findings Register
Section titled “95. Practical Activity — Audit Findings Register”Create:
05 Audit Findings RegisterUse:
| Finding | Requirement | Severity | Owner | Target | Status |
|---|
Add:
Root Cause
Corrective Action
Retest Result96. Practical Activity — Corrective Action Tracker
Section titled “96. Practical Activity — Corrective Action Tracker”Create:
06 Corrective Action TrackerRecommended fields:
Finding ID
Root Cause
Corrective Action
Owner
Target Date
Evidence
Retest Date
Retest Result
Closure Date97. Practical Activity — Perform a Mock Audit
Section titled “97. Practical Activity — Perform a Mock Audit”Select five controls:
Access Review
MFA
Security Awareness
Vendor Assessment
Backup RecoveryFor each control:
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Define audit criteria.
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Identify population.
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Select sample.
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Request evidence.
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Perform testing.
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Document exceptions.
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Determine effectiveness.
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Write findings where necessary.
This simulates real GRC audit work.
98. Internal Audit Checklist
Section titled “98. Internal Audit Checklist”Before completing an internal audit:
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Audit program established.
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Scope defined.
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Criteria defined.
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Auditor competence considered.
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Objectivity and impartiality considered.
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Audit plan approved.
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Evidence requested.
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Interviews completed.
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Walkthroughs completed.
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Populations identified.
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Samples selected.
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ISMS requirements tested.
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Applicable controls tested.
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Evidence documented.
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Findings validated.
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Audit report issued.
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Corrective actions assigned.
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Target dates established.
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Findings tracked.
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Retesting performed.
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Audit records retained.
99. GRC Analyst Responsibilities
Section titled “99. GRC Analyst Responsibilities”A GRC professional may:
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Coordinate the audit program.
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Define audit scope.
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Prepare audit plans.
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Build evidence requests.
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Coordinate stakeholders.
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Conduct control walkthroughs.
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Perform or support control testing.
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Maintain working papers.
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Document findings.
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Facilitate root-cause analysis.
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Track corrective actions.
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Escalate overdue findings.
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Coordinate retesting.
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Maintain the findings register.
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Prepare audit reporting.
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Support certification readiness.
Depending on the organization, GRC may perform audits or support an independent internal-audit function.
100. Internal Audit Governance Model
Section titled “100. Internal Audit Governance Model”A practical model may look like:
Management ↓Approves Audit Program
Internal Audit / Independent Assurance ↓Performs Audit
GRC ↓Coordinates ISMS Evidence
Control Owners ↓Provide Evidence
Risk Owners ↓Address Risk
Management ↓Reviews ResultsResponsibilities should preserve appropriate objectivity.
101. Internal Audit Lifecycle
Section titled “101. Internal Audit Lifecycle”Annual Audit Program ↓Audit Planning ↓Scope & Criteria ↓Evidence Request ↓Interviews ↓Walkthroughs ↓Sampling ↓Testing ↓Findings ↓Audit Report ↓Root Cause ↓Corrective Action ↓Retesting ↓Closure ↓Management Review ↓Continuous Improvement102. Internal Audit Maturity
Section titled “102. Internal Audit Maturity”Level 1 — Checklist
Section titled “Level 1 — Checklist”Documents checkedLittle testingLevel 2 — Evidence Based
Section titled “Level 2 — Evidence Based”EvidenceSamplingFindingsLevel 3 — Risk Based
Section titled “Level 3 — Risk Based”Risk PrioritizationControl TestingRoot CauseLevel 4 — Integrated Assurance
Section titled “Level 4 — Integrated Assurance”RiskControlsAuditComplianceFindingsLevel 5 — Continuous Assurance
Section titled “Level 5 — Continuous Assurance”Automated Evidence
Continuous Control Monitoring
Risk-Based Testing
Real-Time Exceptions103. Internal Audit Mindset
Section titled “103. Internal Audit Mindset”When auditing any ISMS process or control, ask:
What is the requirement?
What should happen?
Who is responsible?
What actually happened?
What evidence proves it?
Was the complete population considered?
Was the control properly designed?
Did it operate consistently?
Were exceptions identified?
What risk results from the exception?
Why did the failure happen?
Has the root cause been corrected?
Can remediation be independently verified?These questions transform internal audit from a checklist exercise into meaningful assurance.
Key Takeaways
Section titled “Key Takeaways”-
ISO/IEC 27001 requires internal audits at planned intervals.
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Internal audit evaluates both conformity and effective implementation and maintenance of the ISMS.
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Internal audit should cover ISMS requirements as well as applicable controls.
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Audit programs should consider process importance and previous audit results.
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Audit scope and criteria should be clearly defined.
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Auditors should maintain appropriate objectivity and impartiality.
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Inquiry alone generally provides insufficient assurance.
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Evidence should be relevant, reliable, sufficient, and appropriate.
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Control design and operating effectiveness should be evaluated separately.
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Sampling should be based on a defined population and appropriate methodology.
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Findings should clearly connect criteria, condition, evidence, and impact.
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Nonconformities require appropriate correction and corrective action.
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Root-cause analysis helps prevent recurrence.
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Corrective actions should have owners and target dates.
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Findings should be independently retested before closure where appropriate.
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Internal-audit results are an important input into management review and certification readiness.
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GRC plays a major role in coordinating audit evidence, findings, remediation, and assurance activities.
Knowledge Check
Section titled “Knowledge Check”Before continuing, make sure you can answer:
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What is the purpose of an ISO/IEC 27001 internal audit?
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What should the internal audit determine?
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What is an audit program?
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What is audit scope?
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What are audit criteria?
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Why is auditor objectivity important?
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What is an audit walkthrough?
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What is design effectiveness?
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What is operating effectiveness?
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What is a control population?
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Why is sampling used?
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Why should the auditor validate the population?
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What makes good audit evidence?
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Why is inquiry alone usually insufficient?
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What is a nonconformity?
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What is the difference between correction and corrective action?
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Why is root-cause analysis important?
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Why should corrective actions be retested?
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How do internal-audit results support management review?
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How does internal audit support certification readiness?
What’s Next?
Section titled “What’s Next?”➡️ Next: 10 — Certification Process
In the next lesson, you will move from independent ISMS assurance into leadership oversight and continual improvement.
You will learn how management reviews information such as:
Internal Audit Results ↓Risk & Treatment Status ↓Security Objectives ↓Control Performance ↓Incidents & Nonconformities ↓Stakeholder Changes ↓Improvement Opportunities ↓Management Decisions ↓Actions & OwnershipYou will also build practical artifacts including a Management Review Agenda, Management Review Pack, ISMS KPI/KRI Dashboard, Management Decision Log, Improvement Register, and Management Review Minutes Template.
This completes the core operational cycle of the ISO/IEC 27001 ISMS and prepares you for the module’s practical labs and runbooks.