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Control 5.35 Explained: Conducting Independent Information Security Reviews

Information security is a fundamental component of an organisation’s data management policies.

It is essential that businesses ensure their data is secure, as this is a key factor in avoiding unpleasant consequences. Making sure information is safe and secure will help prevent potential issues.

It is imperative to avoid any sense of complacency, and so regular independent reviews must be conducted to assess the organisation’s management of the people, processes, and technologies involved in maintaining a successful information security operation.

Purpose of ISO 27001:2022 Annex A 5.35

Organisations should conduct independent reviews at planned intervals and whenever major operational changes occur, in order to guarantee that their information security management policies remain intact, as per ISO 27001:2022 Annex A Control 5.35 to ensure that:

  • They possess the ability to meet the adequate requirements.
  • They strive to attain the right objectives.
  • Their performance is effective; they function as designed.



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Ownership of Annex A 5.35

ISO 27001:2022 Annex A Control 5.35 focuses primarily on operational affairs, so ownership should be held by the Chief Operating Officer (COO) or Chief Information Security Officer (CISO) if one is present.

General Guidance on ISO 27001:2022 Annex A 5.35

The goal of management is to devise and execute procedures which allow for separate reviews of their info security practices.

Reviews should focus on identifying areas for improvement in an organisation’s approach to information security, including:

An individual from outside the organisation with no personal stake in the matter should conduct a review. This could be someone from within the organisation or an independent third party, such as:

  • Internal auditors are responsible for assessing the effectiveness of a company’s internal control systems and procedures.
  • Independent departmental managers.
  • Third-party organisations may be engaged to provide services.

Whoever conducts the review should possess the necessary operational skills to make a valid judgement on their findings. In the case of internal staff, their job role should not restrict them from delivering a justifiable and valid assessment.

The review’s findings should be meticulously logged, retained, and reported to the Managers who requested it, and in some cases to C-level personnel or ownership.

Reviewers should assess whether information security practices are compliant with the organisation’s established objectives and requirements, which are detailed in the information security policy and any topic-specific policies.

Periodic reviews may be supplemented with ad-hoc ones. Five grounds for such reviews can be identified:

  1. Any amendments to laws, guidelines or regulations that affect the organisation’s information security operations must be observed.
  2. Significant events that have an effect on information security, such as data loss and intrusion, arise.
  3. A new venture is established or major transformations are made to the existing business.
  4. The company takes on a new product or service that has information security implications or alters an existing product or service.
  5. Significant alterations are executed in the organisation’s bank of information security controls, regulations and processes.

Supplementary Guidance on Annex A 5.35

ISO/IEC 27007 and ISO/IEC TS 27008 provide further advice on carrying out independent reviews.




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Changes and Differences from ISO 27001:2013

ISO 27001:2022 Annex A 5.35 replaces ISO 27001:2013 Annex A 18.1.2 (Independent Review of Information Security).

ISO 27001:2022 Annex A 5.35 offers the same general instructions as ISO 27001:2013 Annex A 18.1.2, but goes beyond that to provide specific examples of when an organisation should do ad-hoc assessments in addition to its regular reviews.

Table of All ISO 27001:2022 Annex A Controls

In the table below you’ll find more information on each individual ISO 27001:2022 Annex A Control.

ISO 27001:2022 Organisational Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Organisational Controls Annex A 5.1 Annex A 5.1.1
Annex A 5.1.2
Policies for Information Security
Organisational Controls Annex A 5.2 Annex A 6.1.1 Information Security Roles and Responsibilities
Organisational Controls Annex A 5.3 Annex A 6.1.2 Segregation of Duties
Organisational Controls Annex A 5.4 Annex A 7.2.1 Management Responsibilities
Organisational Controls Annex A 5.5 Annex A 6.1.3 Contact With Authorities
Organisational Controls Annex A 5.6 Annex A 6.1.4 Contact With Special Interest Groups
Organisational Controls Annex A 5.7 NEW Threat Intelligence
Organisational Controls Annex A 5.8 Annex A 6.1.5
Annex A 14.1.1
Information Security in Project Management
Organisational Controls Annex A 5.9 Annex A 8.1.1
Annex A 8.1.2
Inventory of Information and Other Associated Assets
Organisational Controls Annex A 5.10 Annex A 8.1.3
Annex A 8.2.3
Acceptable Use of Information and Other Associated Assets
Organisational Controls Annex A 5.11 Annex A 8.1.4 Return of Assets
Organisational Controls Annex A 5.12 Annex A 8.2.1 Classification of Information
Organisational Controls Annex A 5.13 Annex A 8.2.2 Labelling of Information
Organisational Controls Annex A 5.14 Annex A 13.2.1
Annex A 13.2.2
Annex A 13.2.3
Information Transfer
Organisational Controls Annex A 5.15 Annex A 9.1.1
Annex A 9.1.2
Access Control
Organisational Controls Annex A 5.16 Annex A 9.2.1 Identity Management
Organisational Controls Annex A 5.17 Annex A 9.2.4
Annex A 9.3.1
Annex A 9.4.3
Authentication Information
Organisational Controls Annex A 5.18 Annex A 9.2.2
Annex A 9.2.5
Annex A 9.2.6
Access Rights
Organisational Controls Annex A 5.19 Annex A 15.1.1 Information Security in Supplier Relationships
Organisational Controls Annex A 5.20 Annex A 15.1.2 Addressing Information Security Within Supplier Agreements
Organisational Controls Annex A 5.21 Annex A 15.1.3 Managing Information Security in the ICT Supply Chain
Organisational Controls Annex A 5.22 Annex A 15.2.1
Annex A 15.2.2
Monitoring, Review and Change Management of Supplier Services
Organisational Controls Annex A 5.23 NEW Information Security for Use of Cloud Services
Organisational Controls Annex A 5.24 Annex A 16.1.1 Information Security Incident Management Planning and Preparation
Organisational Controls Annex A 5.25 Annex A 16.1.4 Assessment and Decision on Information Security Events
Organisational Controls Annex A 5.26 Annex A 16.1.5 Response to Information Security Incidents
Organisational Controls Annex A 5.27 Annex A 16.1.6 Learning From Information Security Incidents
Organisational Controls Annex A 5.28 Annex A 16.1.7 Collection of Evidence
Organisational Controls Annex A 5.29 Annex A 17.1.1
Annex A 17.1.2
Annex A 17.1.3
Information Security During Disruption
Organisational Controls Annex A 5.30 NEW ICT Readiness for Business Continuity
Organisational Controls Annex A 5.31 Annex A 18.1.1
Annex A 18.1.5
Legal, Statutory, Regulatory and Contractual Requirements
Organisational Controls Annex A 5.32 Annex A 18.1.2 Intellectual Property Rights
Organisational Controls Annex A 5.33 Annex A 18.1.3 Protection of Records
Organisational Controls Annex A 5.34 Annex A 18.1.4 Privacy and Protection of PII
Organisational Controls Annex A 5.35 Annex A 18.2.1 Independent Review of Information Security
Organisational Controls Annex A 5.36 Annex A 18.2.2
Annex A 18.2.3
Compliance With Policies, Rules and Standards for Information Security
Organisational Controls Annex A 5.37 Annex A 12.1.1 Documented Operating Procedures
ISO 27001:2022 People Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
People Controls Annex A 6.1 Annex A 7.1.1 Screening
People Controls Annex A 6.2 Annex A 7.1.2 Terms and Conditions of Employment
People Controls Annex A 6.3 Annex A 7.2.2 Information Security Awareness, Education and Training
People Controls Annex A 6.4 Annex A 7.2.3 Disciplinary Process
People Controls Annex A 6.5 Annex A 7.3.1 Responsibilities After Termination or Change of Employment
People Controls Annex A 6.6 Annex A 13.2.4 Confidentiality or Non-Disclosure Agreements
People Controls Annex A 6.7 Annex A 6.2.2 Remote Working
People Controls Annex A 6.8 Annex A 16.1.2
Annex A 16.1.3
Information Security Event Reporting
ISO 27001:2022 Physical Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Physical Controls Annex A 7.1 Annex A 11.1.1 Physical Security Perimeters
Physical Controls Annex A 7.2 Annex A 11.1.2
Annex A 11.1.6
Physical Entry
Physical Controls Annex A 7.3 Annex A 11.1.3 Securing Offices, Rooms and Facilities
Physical Controls Annex A 7.4 NEW Physical Security Monitoring
Physical Controls Annex A 7.5 Annex A 11.1.4 Protecting Against Physical and Environmental Threats
Physical Controls Annex A 7.6 Annex A 11.1.5 Working In Secure Areas
Physical Controls Annex A 7.7 Annex A 11.2.9 Clear Desk and Clear Screen
Physical Controls Annex A 7.8 Annex A 11.2.1 Equipment Siting and Protection
Physical Controls Annex A 7.9 Annex A 11.2.6 Security of Assets Off-Premises
Physical Controls Annex A 7.10 Annex A 8.3.1
Annex A 8.3.2
Annex A 8.3.3
Annex A 11.2.5
Storage Media
Physical Controls Annex A 7.11 Annex A 11.2.2 Supporting Utilities
Physical Controls Annex A 7.12 Annex A 11.2.3 Cabling Security
Physical Controls Annex A 7.13 Annex A 11.2.4 Equipment Maintenance
Physical Controls Annex A 7.14 Annex A 11.2.7 Secure Disposal or Re-Use of Equipment
ISO 27001:2022 Technological Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Technological Controls Annex A 8.1 Annex A 6.2.1
Annex A 11.2.8
User Endpoint Devices
Technological Controls Annex A 8.2 Annex A 9.2.3 Privileged Access Rights
Technological Controls Annex A 8.3 Annex A 9.4.1 Information Access Restriction
Technological Controls Annex A 8.4 Annex A 9.4.5 Access to Source Code
Technological Controls Annex A 8.5 Annex A 9.4.2 Secure Authentication
Technological Controls Annex A 8.6 Annex A 12.1.3 Capacity Management
Technological Controls Annex A 8.7 Annex A 12.2.1 Protection Against Malware
Technological Controls Annex A 8.8 Annex A 12.6.1
Annex A 18.2.3
Management of Technical Vulnerabilities
Technological Controls Annex A 8.9 NEW Configuration Management
Technological Controls Annex A 8.10 NEW Information Deletion
Technological Controls Annex A 8.11 NEW Data Masking
Technological Controls Annex A 8.12 NEW Data Leakage Prevention
Technological Controls Annex A 8.13 Annex A 12.3.1 Information Backup
Technological Controls Annex A 8.14 Annex A 17.2.1 Redundancy of Information Processing Facilities
Technological Controls Annex A 8.15 Annex A 12.4.1
Annex A 12.4.2
Annex A 12.4.3
Logging
Technological Controls Annex A 8.16 NEW Monitoring Activities
Technological Controls Annex A 8.17 Annex A 12.4.4 Clock Synchronization
Technological Controls Annex A 8.18 Annex A 9.4.4 Use of Privileged Utility ProgramsAccess Rights
Technological Controls Annex A 8.19 Annex A 12.5.1
Annex A 12.6.2
Installation of Software on Operational Systems
Technological Controls Annex A 8.20 Annex A 13.1.1 Networks Security
Technological Controls Annex A 8.21 Annex A 13.1.2 Security of Network Services
Technological Controls Annex A 8.22 Annex A 13.1.3 Segregation of Networks
Technological Controls Annex A 8.23 NEW Web filtering
Technological Controls Annex A 8.24 Annex A 10.1.1
Annex A 10.1.2
Use of Cryptography
Technological Controls Annex A 8.25 Annex A 14.2.1 Secure Development Life Cycle
Technological Controls Annex A 8.26 Annex A 14.1.2
Annex A 14.1.3
Application Security Requirements
Technological Controls Annex A 8.27 Annex A 14.2.5 Secure System Architecture and Engineering PrinciplesLearning From Information Security Incidents
Technological Controls Annex A 8.28 NEW Secure Coding
Technological Controls Annex A 8.29 Annex A 14.2.8
Annex A 14.2.9
Security Testing in Development and Acceptance
Technological Controls Annex A 8.30 Annex A 14.2.7 Outsourced Development
Technological Controls Annex A 8.31 Annex A 12.1.4
Annex A 14.2.6
Separation of Development, Test and Production Environments
Technological Controls Annex A 8.32 Annex A 12.1.2
Annex A 14.2.2
Annex A 14.2.3
Annex A 14.2.4
Change Management
Technological Controls Annex A 8.33 Annex A 14.3.1 Test Information
Technological Controls Annex A 8.34 Annex A 12.7.1 Protection of Information Systems During Audit Testing




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ISO 27001:2022 Annex A Controls

Organisational Controls