ISO 27002:2022, Control 5.35 – Independent Review of Information Security

Ownership of Control 5.35

Control 5.35 deals primarily with operational matters. As such, ownership should reside with the COO, or CISO (if present).

General Guidance on Control 5.35

The overarching aim is for management to create and implement processes that cater for independent reviews of their information security practices.

Reviews should focus on any changes that are required to improve an organisation’s approach to information security, including:

1. The information security policy.
2. Topic-specific policies.
3. Related controls.

Any review should be conducted by a person inside or outside the organisation that doesn’t have a vested interest in what they are investigating, such as:

1. Internal auditors.
2. Independent departmental managers.
3. Third-party organisations.

Whoever conducts the review should have the relevant operational competence to make a sound judgement on their findings, and (in the case of internal staff) their job role should not inhibit them from making a valid and legitimate assessment.

The results of the review should be thoroughly recorded, stored and reported to the Manager (or groups of Managers) who requested it, and in certain cases to C-suite level or ownership.

Reviewers should seek to establish whether or not information security practices are compliant with the organisation’s “documented objectives and requirements” stated within the information security policy, or any topic-specific policies.

Alongside periodic reviews, it may be necessary to initiate ad-hoc reviews. These reviews can be justified across 5 key areas:

1. Any laws, guidelines or regulations are amended which affect the organisation’s information security operation.
2. Major incidents occur that have an impact on information security (data loss, intrusion etc).
3. A new business is created, or major changes are enacted to the current business.
4. The organisation adopts a new product or service that has information security implications, or makes underlying changes to a current product or service.
5. Major changes are made to the organisation’s bank of information security controls, policies and procedures.

Supplementary Guidance

ISO/IEC 27007 and ISO/IEC TS 27008 contain further guidance on the practice of independent reviews.

Changes and Differences from ISO 27002:2013

27002:2022-5.35 replaces 27002:2013-18.1.2 (Independent review of information security).

27002:2022-5.35 contains the same general guidance as 27002:2013-18.1.2, but goes a step further in stipulating specific examples of when an organisation should carry out ad-hoc reviews, alongside its periodic reviews.

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