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CISO Times

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The CISO Decision Brief

When do we…

When are we ready for the Stage 1 audit?

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

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The short answer

Recommendation
Confirm Stage 1 only when every required document exists, is approved and is under control, the scope and Statement of Applicability are defensible, a full internal audit and a management review are complete, and every blocking item is at least In place. If any condition fails, move Stage 1.
Reasoning
Stage 1 reads the scope, reviews the required documents (IS-04), checks that the Statement of Applicability follows from the risk assessment (IS-03), and confirms the internal audit and management review have happened (IS-06). It is the cheapest place to find a problem, but only if the basics are there: a Stage 1 that finds missing documents costs a second Stage 1. Stage 1 is also only worth holding if Stage 2 can follow, so the earliest Stage 2 estimate is checked against the booked date before you go.
Considerations
  • The go conditions, the 3-month operating period and the 2 to 4 weeks for sending documents are the pack's defaults. Your certification body may ask for more.
  • Readiness is self-assessed and owners tend to score their own controls high. Take the lower score when in doubt, and have a second person check the blocking items.
  • If the Stage 2 estimate falls after the booked date, tell the executive sponsor that month and choose between adding resource, narrowing the scope and moving the date. A scope cut only to leave out what is not ready fails the scope tests.

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. 11 steps.
  1. Start

    Stage 1 is booked, or about to be

    Stage 1 is the certification body's review of your documentation and of whether you are ready for Stage 2. It reads the scope, checks the required documents, checks that the Statement of Applicability follows from the risk assessment, and confirms that an internal audit and a management review have taken place. It is the cheapest place to find a problem, but only if the basics are already there.

    In the pack

  2. Step

    Reassess readiness against the checklist this month

    Score every clause requirement and applicable Annex A control from 0 (Not started) to 3 (Operating). When in doubt, take the lower score: it describes what an auditor could see today, not what is planned. Have a second person check the scores of the blocking items, because owners tend to score their own controls high.

  3. Decision

    Does every required document exist, approved and under control?

    Every document and record the standard requires must exist, be approved and be kept under document control. The scope, the policy, the risk assessment and treatment processes, the Statement of Applicability, the treatment plan and the objectives are the ones the certification body usually asks for first. A document with no approval, owner or review date is a common Stage 1 challenge. If you are not sure, answer no.

    In the pack

  4. Decision

    Are the scope and the Statement of Applicability defensible?

    The scope must be approved by top management and name its interfaces and every exclusion with a reason. The Statement of Applicability must trace every inclusion and exclusion to the risk assessment. Both are on the list of what the certification body tends to challenge at Stage 1: a scope it cannot map to real services, and a Statement of Applicability not traced to the risk assessment.

    In the pack

  5. Decision

    Are a full internal audit and a management review complete?

    The internal audit must cover the whole ISMS, and nobody may audit their own work. The management review must come after the audit, because the audit results are one of its inputs, and its minutes must show decisions. An audit run by the person who runs the ISMS, or a review held before the audit, will be challenged.

    In the pack

  6. Decision

    Is every blocking item at least In place?

    Blocking items are the requirements without which Stage 2 cannot pass: the scope, the policy, risk assessment, risk treatment, objectives, the internal audit programme, management review results, and nonconformity and corrective action. For Stage 1 each must be at least In place: documented and working, even with few records yet. If a score is not known, answer no.

  7. Decision

    Does the earliest Stage 2 estimate fall by the booked date?

    Stage 1 is only worth holding if Stage 2 can follow. Work out the earliest Stage 2 date as the latest of three: when the last gap is In place, when the last blocking item has had the operating period of records (the pack's default is 3 months), and when the internal audit and management review are done. Compare it with the booked Stage 2 date.

  8. Step

    Send the documents the certification body asked for

    Many certification bodies ask for the documents some weeks before Stage 1; the pack's typical figure is 2 to 4 weeks. Expect also an organisation chart for the scope, the list of legal, regulatory and contractual requirements, the asset inventory, the supplier list and the headline measures so far. Confirm the Stage 1 plan with the body.

    In the pack

  9. Outcome

    Go: confirm Stage 1 at the management review

    Record the go decision in the management review minutes, with the checks it rests on. Treat anything Stage 1 raises as a nonconformity in waiting: give each area of concern an owner and a date, and close it before Stage 2.

  10. Outcome

    No-go: close the gap, then move Stage 1

    Move Stage 1 rather than go in with gaps. A Stage 1 that finds missing documents costs a second Stage 1. Put each failed condition in your gap tracker with an owner and a date, and agree new dates with the certification body early, because auditors are booked weeks or months ahead.

    In the pack

  11. Outcome

    Tell the sponsor now: add resource, narrow scope or move dates

    If the estimate falls after the booked Stage 2 date, tell the executive sponsor the same month and decide between adding resource, narrowing the scope and moving the date. Do not wait for Stage 1 to decide for you. Narrowing the scope after Stage 1 is expensive, so if the scope is to change, change it before Stage 1, and only so far as it still passes every scope test.

Practical checklist

  1. Reassess readiness this month, scoring every requirement and applicable control from 0 to 3.
  2. Check every required document exists, is approved and is under document control.
  3. Check the scope is approved and names interfaces and exclusions, and the Statement of Applicability traces to the risk assessment.
  4. Check a full internal audit by independent auditors and a management review after it are complete.
  5. Check every blocking item is at least In place.
  6. Work out the earliest Stage 2 date and compare it with the booked date.
  7. Send the documents the certification body asked for, and confirm the Stage 1 plan.
  8. Record the go or no-go decision in the management review minutes.

Evidence to have ready

  • The approved, controlled required documents: scope, policy, risk processes, Statement of Applicability, treatment plan and objectives.
  • The internal audit programme and reports, with auditor independence statements.
  • The management review minutes recording the go decision and the checks it rests on.
  • This month's readiness assessment, with the blocking items and the earliest Stage 2 estimate.
  • Also expected: an organisation chart for the scope, the requirements list, the asset inventory, the supplier list and headline measures.

Assumptions

  • You have booked, or are about to book, Stage 1 with an accredited certification body.
  • You score readiness on a 0 to 3 scale: Not started, Planned, In place, Operating. The go conditions are the defaults in the CISO Times ISO 27001 pack. Your certification body may ask for more.

Not covered here