ISO 27001 Annex A 5.35: Independent review of information security

What auditors look for

Auditors check that 5.35 is either justified as not applicable in your Statement of Applicability or implemented and working. Typical evidence includes:

• Internal audit program and reports
• External audit or assessment reports
• Management responses to findings

How to implement 5.35 in practice

1. Use reviewers independent of the area audited
2. Plan reviews across the certification cycle
3. Track findings to closure
4. Name an owner for 5.35, decide how often it runs and file evidence each time, so the control is audit-ready all year.

Recording 5.35 in the Statement of Applicability

List 5.35 with whether it applies, the reason (usually the risks it treats or a legal or contractual requirement), its implementation status and where the evidence lives. If you exclude it, explain why none of your risks or obligations require it.

Free resources

• How to prepare for a security audit
• ISO 27001 and GDPR readiness assessment
• 10 steps to implement ISO 27001
• Remote ISO 27001 consultant

More organizational controls

• 5.29 Information security during disruption
• 5.30 ICT readiness for business continuity
• 5.31 Legal, statutory, regulatory and contractual requirements
• 5.32 Intellectual property rights
• 5.33 Protection of records
• 5.34 Privacy and protection of PII
• 5.36 Compliance with policies, rules and standards for information security
• 5.37 Documented operating procedures