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CISO Times

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The CISO Decision Brief

How do we…

How do we keep our ISO 27001 certificate after the certification audit?

6 decision pointsThe pack behind this answer: ISO 27001 Implementation & Certification Readiness

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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.
  1. 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.

  2. 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.

  3. 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

  4. 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.

  5. 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.

  6. 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.

  7. 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.

  8. 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

  9. 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.

    In the pack

  10. 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

  11. 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.

    In the pack

  12. 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

  13. 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.

  14. 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.

  15. 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.

    In the pack

  16. 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

  17. 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.

  18. 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.

Practical checklist

  1. Book the first surveillance audit within 12 months of the certification decision, and the later ones each year.
  2. Keep the internal audit, management review and measures on their yearly cycle.
  3. Close every audit finding with a root cause, a corrective action and a check that it worked.
  4. Tell the body about changes of scope, ownership, sites or a serious incident.
  5. Add new services to the scope once they have records, through the body.
  6. 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