Independent Information Security Review Procedure

1. Purpose

The Independent Information Security Review Procedure defines how the organization performs independent reviews of its information-security arrangements, controls, processes, and practices.

The procedure is intended to provide an objective assessment of whether information-security arrangements:

Are appropriately designed
Are implemented as intended
Are operating effectively
Address identified risks
Meet applicable organizational requirements
Support contractual, legal, regulatory, and customer obligations
Provide appropriate evidence
Require corrective action or improvement

Core Principle

Plan → Define Independence → Review → Gather Evidence → Assess → Report → Remediate → Verify → Improve

2. Scope

This procedure applies to independent reviews of information-security arrangements within the organization’s ISMS scope.

Reviews may include:

Information-security governance
ISMS processes
Policies and procedures
Security controls
Access management
Cloud security
Application security
Infrastructure security
Incident management
Business continuity
Supplier security
Privacy and information protection
Vulnerability management
Secure development
Logging and monitoring
Backup and recovery
Physical security
Security awareness
Risk management
Statement of Applicability
Control effectiveness

The scope of each review shall be defined before the review begins.

3. What Is an Independent Information Security Review?

An independent information-security review is an assessment performed by a reviewer who is sufficiently independent from the activity being reviewed to provide an objective assessment.

Independence may be achieved through:

An internal reviewer outside the operational team
A security/compliance team reviewing another function
A cross-functional review
An independent consultant
An external security professional
An independent audit or assessment organization

The reviewer should not assess their own work where this would create a conflict of interest.

An independent review is not automatically an ISO certification audit or an internal audit. The organization should define the purpose, criteria, scope, and methodology of each review.

4. When to Use

An independent review may be performed:

☐ Periodically
☐ Following significant security changes
☐ Following a major incident
☐ Following significant control changes
☐ Before an external audit
☐ Before certification or surveillance activities
☐ Following a major customer security requirement
☐ Following significant organizational change
☐ Following acquisition or merger
☐ When management requests independent assurance
☐ When significant risks require additional assurance
☐ When contractual or regulatory requirements require review

The frequency should be based on risk, business requirements, changes, and applicable obligations.

5. Review Information

Field	Details
Review ID
Review Title
Review Type
Review Date
Review Period
Reviewer
Reviewer Organization
Review Sponsor
Business Owner
ISMS Scope
Review Scope
Review Criteria
Risk Level
Previous Review
Review Status

6. Review Types

Independent reviews may include:

Governance Review

Assessment of:

Policies
Roles
Responsibilities
Risk management
Management oversight
ISMS governance

Control Review

Assessment of selected security controls.

Technical Security Review

Assessment of:

Cloud configuration
IAM
Network controls
Applications
Infrastructure
Logging
Monitoring
Vulnerability management

Process Review

Assessment of operational processes such as:

Incident management
Access reviews
Supplier management
Backup
Change management

Compliance Readiness Review

Assessment against:

ISO/IEC 27001
SOC 2 requirements
Customer requirements
Contractual requirements
Applicable legal/regulatory requirements

7. Review Objectives

Before starting, document what the review is intended to determine.

Example objectives:

Determine whether access controls are operating effectively.
Determine whether supplier-security requirements are being implemented.
Determine whether security incidents are being managed according to procedure.
Determine whether cloud security controls are operating as intended.
Determine whether corrective actions from previous reviews have been completed.
Determine whether selected controls continue to address identified risks.

Review Objectives

8. Review Criteria

Define the requirements against which the review will be performed.

Possible criteria include:

Information-security policies
Internal procedures
Risk assessments
Statement of Applicability
Security standards
Contractual requirements
Customer requirements
Legal/regulatory requirements
ISO/IEC 27001 requirements
Applicable Annex A controls
Internal control requirements
Approved architecture
Security baselines

Criteria

9. Reviewer Independence Assessment

Before the review begins, confirm that the reviewer is sufficiently independent.

☐ Reviewer is not responsible for the activity being reviewed
☐ Reviewer did not design the control being assessed where independence would be compromised
☐ Reviewer does not approve their own work
☐ Conflicts of interest considered
☐ Reviewer relationship documented
☐ Independence approved where required

Independence Assessment

10. Reviewer Competence

The reviewer should have appropriate knowledge and experience for the review.

Consider:

Information security
Risk management
Audit/review methodology
Cloud security
Application security
Privacy
Relevant regulatory requirements
Relevant standards
Technical testing where applicable

Competence Evidence

☐ Relevant experience
☐ Certifications
☐ Training
☐ Technical expertise
☐ Audit/review experience
☐ Subject-matter expertise

11. Review Scope

Clearly define:

Included

Excluded

Systems

Locations

Business Processes

Information

Time Period

Scope exclusions should be documented rather than assumed.

12. Review Planning

Before the review:

☐ Scope defined
☐ Objectives defined
☐ Criteria defined
☐ Reviewer selected
☐ Independence confirmed
☐ Review schedule agreed
☐ Evidence requirements defined
☐ Relevant stakeholders identified
☐ Previous findings reviewed
☐ Risk areas identified
☐ Sampling approach defined
☐ Reporting format defined

13. Evidence Request

Evidence should be requested based on the review scope.

Examples:

Policies
Procedures
Risk assessments
Access reports
Configuration records
Security logs
Vulnerability reports
Incident records
Training records
Supplier assessments
Backup evidence
Recovery-test results
Change records
Security monitoring evidence
Screenshots
System reports
Tickets
Meeting records
Management approvals

Evidence Request Register

Evidence ID	Evidence	Owner	Requested	Received	Status

14. Evidence Handling

Review evidence shall be handled according to the organization’s information-security requirements.

☐ Evidence classified
☐ Access restricted
☐ Secure transfer method used
☐ Sensitive information protected
☐ Evidence source recorded
☐ Evidence integrity considered
☐ Retention requirement defined
☐ Disposal requirement defined

Do not unnecessarily collect:

Passwords
API keys
Private keys
Authentication secrets
Production credentials
Sensitive personal information

15. Review Methods

Depending on the review objective, methods may include:

Document Review

Review policies, procedures, records, and documented requirements.

Interview

Discuss processes and responsibilities with relevant personnel.

Observation

Observe how controls or processes operate.

Sampling

Select representative transactions, users, systems, or records.

Configuration Review

Review technical configuration against approved requirements.

Evidence Testing

Validate that claimed controls are supported by evidence.

Technical Testing

Where specifically authorized:

Vulnerability scanning
Configuration testing
Security testing
Access testing
Application testing

Technical testing must be authorized and appropriately scoped.

16. Sampling

Where full-population testing is not practical, document the sampling methodology.

Consider:

Population size
Risk
Criticality
Review objective
Previous findings
Control frequency
System importance
Recent changes
Exceptions

Sampling Record

Population	Sample Size	Selection Method	Rationale

Sampling should not be represented as complete testing of the entire population unless the entire population was actually reviewed.

17. Control Review

For each control or requirement, assess:

Requirement	Control	Evidence	Result	Finding

Possible results:

☐ Effective
☐ Partially Effective
☐ Ineffective
☐ Not Implemented
☐ Not Applicable
☐ Unable to Verify

The assessment should be supported by evidence.

18. Review Status

Use a consistent status model.

Effective

The control is appropriately designed, implemented, and supported by evidence.

Partially Effective

The control exists but has gaps or inconsistent operation.

Ineffective

The control exists but does not adequately address the intended risk.

Not Implemented

The expected control has not been implemented.

Unable to Verify

Sufficient evidence was not available to determine the control status.

19. Finding Development

A finding should clearly explain:

Requirement – What should exist?
Condition – What was observed?
Evidence – What supports the observation?
Risk – Why does it matter?
Recommendation – What should be addressed?

Finding Format

Requirement:

Condition:

Evidence:

Risk:

Recommendation:

20. Finding Classification

Findings may be classified according to the organization’s approved methodology.

Example:

Classification	Description
Critical	Significant security or compliance exposure requiring urgent action
High	Material weakness requiring timely remediation
Medium	Control weakness requiring corrective action
Low	Minor weakness or improvement opportunity
Observation	Matter noted for management awareness
Opportunity for Improvement	Improvement that may strengthen the control environment

The organization’s formal risk methodology should take precedence over these example classifications.

21. Findings Register

Finding ID	Area	Requirement	Condition	Risk	Severity	Owner	Due Date	Status

22. Management Response

Management should have an opportunity to review findings and provide a response.

Management Response

Response Type

☐ Accept
☐ Remediate
☐ Mitigate
☐ Transfer
☐ Avoid
☐ Risk Acceptance Required
☐ Further Investigation Required

23. Corrective Action

Where corrective action is required:

Action ID	Finding	Corrective Action	Owner	Target Date	Status	Evidence

Corrective actions should address the underlying issue rather than only the visible symptom.

24. Root Cause

For significant findings, determine the underlying cause.

Possible causes:

Missing policy
Inadequate procedure
Lack of ownership
Insufficient training
Technology limitation
Configuration error
Process failure
Inadequate monitoring
Incomplete implementation
Resource limitation
Supplier dependency
Change-management failure

Root Cause

25. Immediate Risk Treatment

Where a finding creates immediate risk, management may need to implement temporary treatment before permanent remediation.

Examples:

Disable unnecessary access
Apply temporary configuration restrictions
Increase monitoring
Isolate affected systems
Rotate credentials
Restrict information sharing
Apply temporary manual controls

Temporary measures should be documented and tracked until permanent remediation is completed.

26. Review Report

The review report should normally include:

Review objective
Scope
Criteria
Methodology
Reviewer independence
Review period
Evidence reviewed
Sampling methodology
Findings
Risk assessment
Management responses
Corrective actions
Overall conclusion
Limitations
Follow-up requirements

27. Review Conclusion

The reviewer should provide a conclusion based on the evidence obtained.

Conclusion

Overall Review Result

☐ Controls operating effectively
☐ Controls generally effective with improvements required
☐ Material weaknesses identified
☐ Significant remediation required
☐ Unable to conclude due to insufficient evidence

The conclusion should reflect the defined scope and evidence reviewed.

28. Management Review

Significant findings should be communicated to appropriate management.

Management review may consider:

Security risk
Business impact
Customer impact
Regulatory obligations
Remediation priorities
Resource requirements
Risk acceptance
Control improvements

Management Review Record

Date: __________________

Participants: __________________

Key Decisions: __________________

29. Follow-Up Review

Follow-up should verify whether agreed corrective actions have been implemented.

☐ Action completed
☐ Evidence reviewed
☐ Control retested
☐ Finding closed
☐ Finding remains open
☐ Residual risk reassessed

Follow-Up Result

30. Independence of Follow-Up

Where practical, follow-up should be performed by a reviewer who remains sufficiently independent.

If the original reviewer performed the follow-up, the organization should consider whether sufficient objectivity remains.

For significant findings, an independent reviewer may be used where appropriate.

31. Confidentiality

Review information may contain sensitive organizational information.

The reviewer shall:

Protect review information
Use approved storage
Restrict access
Avoid unnecessary disclosure
Follow information-classification requirements
Protect customer and personal information
Secure review reports
Dispose of information according to retention requirements

32. Security Testing During Review

If technical testing is required:

☐ Testing authorization obtained
☐ Scope documented
☐ Testing window defined
☐ Systems identified
☐ Production impact assessed
☐ Emergency contact identified
☐ Testing limitations defined
☐ Evidence captured
☐ Results protected
☐ Remediation tracked

No intrusive security testing should be performed without appropriate authorization.

33. Review of Third Parties

Independent reviews may also assess suppliers or third parties.

Consider:

Contractual requirements
Security commitments
Access
Information protection
Security assurance
Incidents
Vulnerabilities
Subprocessors
Business continuity
Data location
Corrective actions

The review should respect contractual limitations and authorized access.

34. Review of Cloud Environments

Where cloud infrastructure is within scope, consider:

☐ Cloud account structure
☐ IAM
☐ MFA
☐ Privileged access
☐ Network configuration
☐ Public exposure
☐ Encryption
☐ Logging
☐ Monitoring
☐ Security alerts
☐ Vulnerability management
☐ Backup
☐ Recovery
☐ Secrets
☐ Configuration management
☐ Infrastructure as Code
☐ Security monitoring
☐ Incident response

35. AWS SaaS Startup Example

A SaaS startup performs an annual independent information-security review covering:

AWS production environment
GitHub repositories
IAM
Employee access
Security monitoring
Backup
Incident management
Supplier security

Review Approach

Scope: Production AWS environment and supporting security processes.

Reviewer: Security professional who is not responsible for day-to-day AWS administration.

Evidence:

IAM access report
MFA configuration
CloudTrail configuration
Security monitoring
Backup configuration
Vulnerability reports
Incident records
Access review records

Example Finding

Requirement: Privileged access should be appropriately controlled.

Condition: One administrative account was found without evidence of recent access review.

Risk: Unnecessary privileged access could increase the likelihood or impact of unauthorized activity.

Action: Review the account, validate business need, remove unnecessary privileges, and establish periodic review evidence.

Audit Trail

Review Scope → Independence Confirmed → Evidence Requested → Evidence Reviewed → Controls Tested → Finding Identified → Risk Assessed → Corrective Action → Follow-Up → Finding Closed

36. Startup-Friendly Model

A startup does not necessarily need a large formal independent-review program.

A practical model can begin with:

Quarterly

Review selected high-risk controls:

IAM
MFA
Privileged access
Cloud configuration
Security monitoring
Backup

Semi-Annual

Review:

Supplier security
Incident management
Vulnerability management
Access reviews
Business continuity

Annual

Perform a broader independent review covering:

ISMS
Risk management
Security controls
Policies
Evidence
Previous findings
Customer requirements
Compliance obligations

The exact frequency should be based on risk and organizational requirements.

37. Review Frequency

Review frequency should consider:

Risk level
System criticality
Information sensitivity
Regulatory requirements
Customer requirements
Previous findings
Security incidents
Major changes
Technology changes
Supplier changes
Business growth

Review Schedule

Review Area	Frequency	Last Review	Next Review	Owner

38. Review Triggers

An additional review may be required following:

☐ Major security incident
☐ Data breach
☐ Significant vulnerability
☐ Major cloud architecture change
☐ New production environment
☐ Significant access-model change
☐ Major supplier change
☐ Acquisition or merger
☐ New regulatory requirement
☐ Major customer requirement
☐ Significant control failure
☐ Repeated audit finding
☐ Significant business change

39. Exceptions

If a review requirement cannot be completed:

☐ Reason documented
☐ Risk assessed
☐ Compensating control considered
☐ Management approval obtained
☐ Target completion date defined
☐ Exception recorded
☐ Follow-up scheduled

Exceptions should not silently remove review requirements.

40. Records and Evidence

Retain appropriate review records, including:

☐ Review plan
☐ Scope
☐ Criteria
☐ Independence assessment
☐ Reviewer competence evidence
☐ Evidence request
☐ Evidence reviewed
☐ Sampling records
☐ Test results
☐ Findings
☐ Management responses
☐ Corrective actions
☐ Review report
☐ Follow-up evidence
☐ Closure approval

Retention should follow the organization’s records-retention requirements.

41. Roles and Responsibilities

Role	Responsibility
Management	Provide oversight and decisions
Review Sponsor	Define business objective and support review
Reviewer	Plan and perform independent review
Control Owner	Provide evidence and explain control operation
Security Team	Support technical/security assessment
Risk Owner	Assess and manage identified risks
Legal/Compliance	Support applicable legal or regulatory matters
Business Owner	Assess business impact
Action Owner	Implement corrective action
ISMS Manager	Track review results and improvement

42. Common Mistakes

Avoid:

Calling a self-assessment an independent review.
Allowing someone to review their own work without considering independence.
Defining the review scope after testing begins.
Reviewing documents without checking operational evidence.
Treating screenshots alone as proof of ongoing control effectiveness.
Testing technical controls without authorization.
Reporting findings without identifying the requirement.
Reporting findings without evidence.
Ignoring business risk.
Closing findings without validating remediation.
Performing reviews only before certification audits.
Failing to track repeated findings.
Collecting unnecessary credentials or secrets as evidence.
Treating every review as requiring the same depth.

43. Relationship With Other ISMS Documents

Document	Relationship
Information Security Policy	Defines security direction
Information Security Risk Assessment	Identifies security risks
Risk Treatment Plan	Tracks risk treatment
Statement of Applicability	Records control applicability
Internal Audit Procedure	Defines formal internal audit activities
Security Control Testing Procedure	Defines control testing
Supplier Security Review	Reviews third-party controls
Cloud Security Review	Reviews cloud controls
Incident Management	Provides incident evidence
Corrective Action Tracker	Tracks remediation
Management Review	Provides management oversight
ISMS Improvement Log	Records improvement opportunities

44. ISO/IEC 27001 Connection

Independent information-security reviews can support the organization’s risk-based ISMS assurance and improvement activities.

They can provide evidence relating to:

Security governance
Risk treatment
Control effectiveness
Internal assurance
Corrective action
Continual improvement
Management oversight

However, an independent review should not automatically be represented as an ISO/IEC 27001 internal audit or certification audit unless it has been planned and performed for that purpose against the applicable audit criteria.

The organization should determine the appropriate review activities based on:

ISMS scope
Information-security risks
Control requirements
Legal/regulatory obligations
Customer requirements
Contractual commitments
Previous findings
Significant changes

45. Final Audit Trail

For every significant independent security review, the organization should be able to demonstrate:

Why was the review performed?
What was reviewed?
Who performed the review?
Was the reviewer sufficiently independent?
What criteria were used?
What evidence was reviewed?
What sampling was performed?
What controls were tested?
What findings were identified?
What risks were identified?
Who accepted or treated the risks?
What corrective actions were assigned?
Were corrective actions verified?
Who reviewed the results?
What improvements were made?

Final Principle

Define the Objective → Establish Independence → Define Scope → Gather Evidence → Test Controls → Identify Findings → Assess Risk → Correct → Verify → Improve → Preserve Evidence