How do we…
How do we keep our ISO 27001 certificate after the certification audit?
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The short answer
- Recommendation
- Book and budget the yearly surveillance audits and the recertification at once, keep the audit and review cycle running, close every finding with an effectiveness check, and tell the body about significant changes.
- Reasoning
- Surveillance audits look at the internal audit, the management review, the nonconformity log, the actions from the last audit, changes to the ISMS and a rotating part of the controls. A finding patched rather than fixed returns at the first surveillance audit. A missed surveillance audit can lead to suspension, and a recertification not completed before expiry means the certificate lapses.
- Considerations
- ISO/IEC 17021-1 and 27006-1 set the cycle and are paywalled. The timings and triggers here come from the pack and public certification body material, so confirm them with your body.
- A new service or site can be added at a surveillance audit or in a separate extension audit once it has records, and the body may charge extra days.
- A severe breach, a substantive complaint or a major restructuring can lead a body to call a short-notice special audit.
- The pack's budget figures, a third of the initial fee for surveillance and two thirds for recertification, are estimates. Use your quote.
The decision, step by step
Select any step for the reasoning behind it and where the pack covers it.
- Start
- Step
- Decision
- Outcome
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. 18 steps.
Start
We are certified and want to keep the certificate
The certificate names the scope and is usually valid for three years, provided the surveillance audits go well. The phases of the project become a yearly cycle: risk assessment, operation, internal audit and management review.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
- P08-A02 ISO 27001 Implementation Methodology & Project PlanWhat it costs
Step
Put the three-year cycle in a calendar and a budget
Mark the surveillance audits, the recertification date, the internal audits and the management reviews. The pack estimates surveillance at about a third of the initial fee each year and recertification at about two thirds every three years. Budget for them at the start, because a missed surveillance audit can lead to suspension.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanWhat it costs
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideTimelines
Step
Keep the system running between audits
Between audits the ISMS keeps running: measures, reviews, audits and records. Keep reporting the headline measures, and watch overdue gaps most closely between audits. A system that stops producing records between audits gives the auditor nothing to sample.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
- P08-A02 ISO 27001 Implementation Methodology & Project PlanMeasuring readiness
Decision
Is a surveillance audit overdue or postponed?
For schemes under the international accreditation arrangement, failure to hold a surveillance audit in time can lead to suspension, during which the certificate and marks cannot be used. If it is not resolved in the body's time, suspension can lead to withdrawal. If you are not sure of the date, answer yes and check.
- Yes, or not known: Speak to the certification body at once
- No: Is the next surveillance audit booked with the body?
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideTimelines
Step
Speak to the certification body at once
Ask the body what date it will accept and what suspension would mean for your customers. Tell the sponsor the same day, and do not use the certificate or marks if it is suspended. Then carry on with the rest of this route.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideTimelines
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
Decision
Is the next surveillance audit booked with the body?
The first falls within 12 months of the certification decision by the pack's default, set by the accreditation rules the body works under. If it is not in the body's calendar, answer no.
- Yes: Prepare for what the surveillance auditor reads
- No, or not known: Book it, with the audit days in the quote
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideTimelines
Step
Book it, with the audit days in the quote
Ask for the date, the audit days and the person who will lead it, and put it in the calendar with the internal audit and review before it.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideTimelines
- P08-A02 ISO 27001 Implementation Methodology & Project PlanWhat it costs
Step
Prepare for what the surveillance auditor reads
The auditor usually looks at the internal audit, the management review, the nonconformity log, the corrective actions from the last audit, changes to the ISMS and a rotating part of the controls. Public sources add the use of the certification marks and complaints.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
Decision
Is every finding from the last audit closed and checked?
A finding fixed only at the symptom returns at the first surveillance audit. Each needs a root cause, a correction, a corrective action and a check that it worked. If any is open without a dated plan, answer no.
- Yes: Has the scope, ownership, a site or a serious incident changed?
- No, or not known: Finish them before the audit
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideCommon mistakes
- P08-A02 ISO 27001 Implementation Methodology & Project PlanThe rules (rule IS-09)
Step
Finish them before the audit
Close each at its cause, record the check, and put any remainder on a dated plan. Bring the position to the management review.
In the pack
- P08-A08 ISMS Internal Audit Programme & ProcedureStage 7 — Nonconformity and corrective action
Decision
Has the scope, ownership, a site or a serious incident changed?
The pack says to tell the certification body about a change of scope, ownership, sites or a serious incident. It may adjust the next audit or visit sooner. Public sources add that severe breaches, serious complaints and major restructuring can lead to a short-notice audit. If you are not sure, answer yes.
- Yes, or not known: Tell the certification body, before it hears elsewhere
- No: Do you want to add a new service or site to the scope?
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
Step
Tell the certification body, before it hears elsewhere
Write to your contact with what changed, what it affects and what you are doing. Update the scope, the risk assessment and the Statement of Applicability for the change, and keep the correspondence.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
- P08-A02 ISO 27001 Implementation Methodology & Project PlanScoping decisions
Decision
Do you want to add a new service or site to the scope?
The pack's rule is to add a new service at a surveillance audit once it has records, rather than before it has run. If a part of the organisation is joining the ISMS, answer yes.
- Yes: Ask the body to assess it once it has records
- No: Have an internal audit and a management review been held this year?
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanInclude or exclude
- P08-A02 ISO 27001 Implementation Methodology & Project PlanScoping decisions
Step
Ask the body to assess it once it has records
The body reviews the updated scope, risk assessment and Statement of Applicability. It may assess the extension at a surveillance audit with added days or in a separate audit, and then issue a revised certificate.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanInclude or exclude
- P08-A02 ISO 27001 Implementation Methodology & Project PlanScoping decisions
Decision
Have an internal audit and a management review been held this year?
The pack's default is at least every 12 months, with the audit results as an input. The pack audits blocking items every year and everything else once in the cycle, and the review comes after the audit. A review held too early has to be held again. If the date has passed or the minutes show no decisions, answer no.
- Yes: Plan recertification from the start of year three
- No, or not known: Hold what is missing: the audit first, then the review
In the pack
- P08-A09 Management Review Meeting PackWhen it meets
- P08-A09 Management Review Meeting PackKeeping it a decision meeting
Step
Hold what is missing: the audit first, then the review
Hold the internal audit, then the review so its results are an input, and minute the decisions and the owners of the actions.
In the pack
- P08-A09 Management Review Meeting PackWhen it meets
- P08-A09 Management Review Meeting PackThe decisions to record
Step
Plan recertification from the start of year three
Recertification is a full audit before the certificate expires. It covers the whole ISMS and its performance over the cycle, and every clause and applicable control should have been audited internally once by then. Resolve any open major nonconformity and the body's decision before expiry.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
- P08-A08 ISMS Internal Audit Programme & ProcedureHow often
Outcome
Cycle in place: repeat it each year
Keep the calendar, the records and the log current, and review the programme after each management review. Re-rate the areas that had a finding or an incident.
In the pack
- P08-A10 Stage 1 and Stage 2 Audit Preparation GuideAfter certification
- P08-A08 ISMS Internal Audit Programme & ProcedureHow often
Practical checklist
- Book the first surveillance audit within 12 months of the certification decision, and the later ones each year.
- Keep the internal audit, management review and measures on their yearly cycle.
- Close every audit finding with a root cause, a corrective action and a check that it worked.
- Tell the body about changes of scope, ownership, sites or a serious incident.
- Add new services to the scope once they have records, through the body.
- Plan the recertification audit from the start of year three.
Evidence to have ready
- The three-year calendar of audits, reviews and internal audits.
- The nonconformity log with root causes and effectiveness checks.
- Management review minutes and measurement results for each year.
- The record of changes notified to the certification body.
Assumptions
- You are certified, or are about to be, against ISO/IEC 27001:2022 with an accredited certification body.
- The certificate runs for three years with yearly surveillance audits, as the pack and public sources describe. Your body's rules decide the detail.
- The budget fractions and review interval are the CISO Times pack's defaults and estimates.
Not covered here
- Running the internal audit when you are small. That is “How do we run an internal audit when we are small?”.
- Running a management review that decides things. That is “How do we run a management review that actually decides things?”.
- What to do about a major nonconformity. That is “If the auditor raises a major nonconformity, then what?”.
- Working out what certification costs over the cycle. That is “When will certification realistically happen, and what will it cost?”.
Related questions
- How do we run an internal audit when we are small?
- How do we run a management review that actually decides things?
- If the auditor raises a major nonconformity, then what?
- If Stage 1 has raised concerns, then how do we get ready for Stage 2?
- How do we decide what to monitor and measure in our ISMS, and who evaluates it?