How do we…
How do we decide what to log and monitor, and who reviews it, for an ISO 27001 audit?
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The short answer
- Recommendation
- List the events that matter for each in-scope system from your risks, send the logs to a store administrators cannot change, set a keep period, name who acts on alerts, and test one event from system to response. Review on a schedule and keep the records.
- Reasoning
- Auditors do not look for a tool. They ask what is logged, where, for how long, who looks at it and what happened when they did. The usual gaps are logs kept only on the system that made them, no logs from cloud services, alerts to an unread mailbox, monitoring only in office hours and logs nobody reviews. A smaller set that is tested and reviewed is easier to defend than a large one that is not.
- Considerations
- The standard's text is paywalled. The two controls are described from the pack's Library and public guides, which are secondary.
- The 12 month period is the pack's example. Your investigations, contracts, law and privacy duties set yours.
- Logs often hold personal data, so retention and access are a data protection decision as well as a security one.
- A managed detection service can run the monitoring. You still own the decision of what it watches and the review of what it reports.
The decision, step by step
Select any step for the reasoning behind it and where the pack covers it.
- Start
- Step
- Decision
- Outcome
- Loop back
Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.
Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.
Read as text
The same flow written out: each step, its reasoning and where the pack covers it. 22 steps.
Start
We must show we log and review security events
Logging records what happens so incidents can be detected, investigated and proven. Monitoring watches for unusual behaviour while it can still be stopped. The auditor asks what is logged, where, for how long and who looks at it, and the pack names logs that nobody reviews as the usual gap.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideCommonly sampled Annex A controls
Decision
Do you have a list of the systems and cloud services in scope?
Logging is decided system by system, so you need the list first. Cloud consoles and software-as-a-service tools are the ones most often missed. If you do not have the list, answer no.
- Yes: Decide the events that matter for each system, from your risks
- No, or not known: Build the asset list first, then return
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Outcome
Build the asset list first, then return
Without a list you cannot say which systems should produce logs, and the sample will find systems that do not. Build the list from the systems that already know, then come back.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Step
Decide the events that matter for each system, from your risks
Start from what would show a compromise or misuse: sign-ins and failures, administrator actions, security alerts, access to sensitive data and changes to the logging itself. Let your risk assessment set how much more. NCSC's introductory guidance starts the same way, by listing the logs that could show whether you have been compromised.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Decision
Does every system produce those logs, including cloud consoles?
Logs kept only on the system that made them, and no logs from cloud services, are the mistakes the Library names. If you have not checked a cloud console, a software-as-a-service tool or a network device, answer no.
- Yes: Send logs to a central store and keep them for a set period
- No, or not known: Turn the logging on, or record the gap and who accepts it
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Step
Turn the logging on, or record the gap and who accepts it
Turn it on where the system can do it. Where it cannot, or the cost is out of proportion, record the gap as an exception with a compensating control, approved by the person with authority to accept the risk.
In the pack
- P02-A02 Security Exception & Waiver StandardWhen an exception is needed
Step
Send logs to a central store and keep them for a set period
A central store lets you search across systems and keeps evidence if one system is lost. Point every system, including cloud services and network devices, at the same time source and record the time zone in the logs (UTC is common), so events from different systems can be put in order. The pack's privileged access standard sets a default of at least 12 months for privileged events, and the Library gives 12 months as an example. Pick a period from your own investigations, contracts and law.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
- P14-A02 Privileged Access StandardLogging and review
Decision
Can the people who administer a system alter or delete its logs?
A log the administrator can edit proves little against that administrator. The pack asks for logging to a store that administrators cannot change or delete. If you do not know the store's rights, answer yes.
- Yes, or not known: Move them to a store the administrators cannot change
- No: Do the logs contain personal data?
In the pack
- P14-A02 Privileged Access StandardLogging and review
Step
Move them to a store the administrators cannot change
Use a write-once setting, a separate account held by someone else, or a service owned outside the team. Where one person does both jobs, add a review by an independent person and record it.
In the pack
- P14-A02 Privileged Access StandardLogging and review
- P14-A07 Privileged Session Review RecordReview schedule
Decision
Do the logs contain personal data?
Logs of sign-ins, addresses and activity often identify people. Privacy law limits how long you keep them and who reads them. Decide the purpose, the retention and the access with whoever advises on data protection. If you are not sure, answer yes.
- Yes, or not known: Limit who can read them, set the purpose and shorten the period
- No: Define what should raise an alert, from your threats
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Step
Limit who can read them, set the purpose and shorten the period
Name the purpose of the logs, restrict access to those who investigate, and keep each type no longer than the purpose needs. Record the decision, as it is one an auditor and a regulator may both ask about.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Step
Define what should raise an alert, from your threats
Choose a short list that you will act on: impossible sign-ins, administrator changes, malware detections, large data movements and changes to logging. A long list that nobody can follow produces ignored alerts, which the Library names as a mistake.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Decision
Does each alert go to a named person or service who acts on it?
Alerts sent to an unread mailbox are the first mistake the Library names. The pack's generative AI standard, for one, names a person who looks at each alert within a stated time. If a mailbox rather than a person receives them, answer no.
- Yes: Do alerts reach someone outside office hours?
- No, or not known: Name the owner, the response time and the route to an incident
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
- P25-A02 Generative AI Security StandardMonitoring
Step
Name the owner, the response time and the route to an incident
Pick a person or a managed detection service, set how fast each class of alert is looked at, and say when an alert becomes an incident. Use the incident questions for that line.
In the pack
- P09-A03 Incident Response PlanDetect and report
Decision
Do alerts reach someone outside office hours?
Monitoring that works only in office hours is a mistake the Library names. Whether you need cover at night depends on how fast an attacker can do damage to your services. If you have not decided, answer no.
- Yes: Make a test event and follow it from system to alert to action
- No, or not known: Choose cover, or accept the gap in writing
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Step
Choose cover, or accept the gap in writing
Options are an on-call rota, a managed detection service or a stated acceptance that alerts wait until the morning, signed by the risk owner. Any of the three can be defended. An unrecorded gap cannot.
In the pack
- P05-A08 Risk Acceptance Form & Approval RecordHow to use this form
Step
Make a test event and follow it from system to alert to action
Do something that should be logged, such as a failed sign-in or a change to an administrator group, and trace it. Does it appear in the store, raise the alert, reach the person and get a recorded response? The Library lists a sample of log entries for a test event as evidence.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Decision
Did the test event appear, raise an alert and get a recorded response?
Follow the event the whole way: was it logged, did it reach the store, did the alert rule fire, did it reach a person, and did someone act and write it down? One break anywhere means monitoring would miss the real event. If you could not run the test, answer no.
- Yes: Does someone review logs and alerts on a schedule, with a record?
- No, or not known: Fix the gap, then repeat the test
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Step
Fix the gap, then repeat the test
Find where the chain broke: logging off, event not forwarded, no alert rule, alert to nobody, or nobody acted. Fix that, then make a new test event. Repeat until one event runs from system to recorded response.
- Then: Make a test event and follow it from system to alert to action (back to an earlier step)
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Decision
Does someone review logs and alerts on a schedule, with a record?
The auditor looks for logs that are collected but never reviewed. The privileged session review record is a model: a schedule by scope, a reviewer without rights in the area, and a follow-up for each anomaly. If the review is by habit with no record, answer no.
- Yes: Logging and monitoring decided, tested and reviewed
- No, or not known: Set a schedule, a reviewer and a record for each review
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideCommonly sampled Annex A controls
- P14-A07 Privileged Session Review RecordReview schedule
Step
Set a schedule, a reviewer and a record for each review
Weekly or monthly by risk, by someone independent of the area reviewed, with each anomaly followed up and written down. Keep the records for the whole operating period.
In the pack
- P14-A07 Privileged Session Review RecordReview schedule
- P14-A07 Privileged Session Review RecordRecords and retention
Outcome
Logging and monitoring decided, tested and reviewed
Keep the event list, the retention decision, the alert rules, the test result and the review records. Do not claim full coverage, or that you have a security operations service, unless the sample shows every in-scope system logging and every alert handled.
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
Practical checklist
- Confirm the list of in-scope systems and cloud services before choosing events.
- Decide the events to log for each system from your risks, and turn them on.
- Send logs to a central store that administrators cannot change, and set the keep period.
- Define the alerts, name who acts on them and how fast, and decide the out of hours cover.
- Trace a test event from the system through the alert to a recorded response.
- Review on a schedule by someone independent, and keep the record.
Evidence to have ready
- The logging standard or settings, showing events, store and retention.
- The store's access rights, showing administrators cannot change logs.
- The alert rules and the alert log with who acted and when.
- The test event trace and the review records.
- Clock settings on a sample of systems.
Assumptions
- You have a list of the systems and cloud services in scope, or can build one.
- You can name a person or a service who will act on alerts.
- Someone can advise on data protection where logs hold personal data.
Not covered here
- Choosing and running a security operations service or a detection platform. That is a supplier decision (“How do we decide how much assurance a supplier needs?”).
- Deciding whether an event is an incident. That is “How do we decide whether something is an incident or just an event?”.
- Controlling the person who is both the administrator and the log owner. That is “If the only IT administrator also manages the security logs, then how do we control that?”.
- What evidence is enough to reconnect a service after a compromise. That is “If a service was compromised, what evidence is enough to reconnect it?”.
Related questions
- How do we decide whether something is an incident or just an event?
- If the only IT administrator also manages the security logs, then how do we control that?
- How do we keep an asset inventory that stands up to an ISO 27001 audit?
- If a service was compromised, what evidence is enough to reconnect it?
- When does a deviation from policy need a formal exception?