ISO/IEC 27001

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Procedure Review Checklist

1. Purpose

The Procedure Review Checklist provides a structured method for reviewing documented operating procedures to determine whether they remain:

  • Accurate
  • Relevant
  • Approved
  • Current
  • Secure
  • Operationally usable
  • Consistent with organizational requirements
  • Aligned with applicable risks and controls
  • Supported by appropriate evidence

The checklist helps ensure that procedures are not simply reviewed for document formatting but are also evaluated against actual operational practices.

Core Principle

Identify → Review → Validate → Test → Update → Approve → Communicate → Evidence


2. Scope

This checklist may be used for procedures covering:

  • Information security
  • IT operations
  • Access management
  • Change management
  • Production deployment
  • Backup and recovery
  • Disaster recovery
  • Incident management
  • Vulnerability management
  • Cloud operations
  • Secure development
  • Supplier management
  • Business continuity
  • Compliance
  • Privacy
  • Security monitoring
  • Other ISMS-related operational activities

3. When to Use

Perform a procedure review:

☐ At the scheduled review date
☐ After a significant technology change
☐ After a security incident
☐ After an audit finding
☐ After a major process change
☐ After a regulatory change
☐ After a customer/contractual requirement changes
☐ After a significant organizational change
☐ When control effectiveness changes
☐ When the procedure is found to be ineffective
☐ When ownership changes
☐ When a major supplier changes
☐ When the procedure is no longer required


4. Procedure Review Information

FieldDetails
Procedure ID
Procedure Name
Process/Area
Procedure Owner
Reviewer
Review Date
Current Version
Previous Version
Scheduled Review Date
Review Type
Criticality
Status

Review Type

☐ Scheduled Review
☐ Change-Triggered Review
☐ Incident-Triggered Review
☐ Audit-Triggered Review
☐ Regulatory Review
☐ Management Review
☐ Effectiveness Review
☐ Other: __________________


5. Review Status

☐ Review Not Started
☐ In Progress
☐ Review Completed — No Changes
☐ Minor Changes Required
☐ Major Revision Required
☐ Procedure Replacement Required
☐ Procedure Retirement Required


6. Procedure Identity

Verify:

☐ Correct procedure name
☐ Unique procedure ID
☐ Correct process identified
☐ Correct owner identified
☐ Correct approver identified
☐ Version number present
☐ Effective date present
☐ Review date present
☐ Classification identified where required
☐ Current status identified


7. Purpose Review

Confirm that the purpose remains valid.

☐ Purpose still applies
☐ Business need remains
☐ Security objective remains relevant
☐ Procedure supports the intended outcome
☐ No duplicate procedure exists
☐ Purpose accurately reflects current activity

Review Result


8. Scope Review

Verify that the scope remains accurate.

☐ Systems covered are current
☐ Applications covered are current
☐ Teams covered are current
☐ Locations are current
☐ Information types are current
☐ Third-party involvement is identified
☐ Cloud services are included where applicable
☐ Production environments are included where required
☐ Scope exclusions remain valid

Scope Changes Required


9. Process Review

Compare the documented procedure with the actual operational process.

☐ Process remains unchanged
☐ Process has changed
☐ Procedure reflects current workflow
☐ Activities are performed in the documented order where required
☐ Responsibilities remain accurate
☐ Manual activities remain applicable
☐ Automated activities are documented
☐ System dependencies are current

Process Changes


10. Roles and Responsibilities

Verify:

☐ Procedure owner remains correct
☐ Operational owner remains correct
☐ Approver remains appropriate
☐ Responsibilities remain accurate
☐ Segregation of duties remains appropriate
☐ Backup personnel identified where necessary
☐ Third-party responsibilities remain accurate


11. Procedure Steps

Review every significant step.

☐ Steps remain necessary
☐ Steps are technically accurate
☐ Steps are in the correct sequence
☐ Instructions are understandable
☐ Required approvals are included
☐ Required verification steps are included
☐ Security requirements are included
☐ Evidence requirements are included
☐ Failure handling is documented
☐ Escalation requirements are documented

Step Changes Required


12. Preconditions

Confirm that prerequisites remain valid.

☐ Required access is correct
☐ Required systems are current
☐ Required tools are current
☐ Required approvals are identified
☐ Required information is identified
☐ Required personnel are identified
☐ Required dependencies are identified


13. Tools and Systems

Review all referenced tools and systems.

System/ToolCurrent?Change Required

Check:

☐ System still exists
☐ System name is correct
☐ URL/reference is current where applicable
☐ Access method is current
☐ Tool is approved
☐ Security controls remain appropriate


14. Access Requirements

Verify that access requirements remain appropriate.

☐ Access roles remain correct
☐ Least privilege considered
☐ Privileged access identified
☐ MFA requirements remain appropriate
☐ Service accounts identified
☐ Emergency access requirements remain valid
☐ Third-party access requirements remain valid


15. Security Requirements

Assess whether the procedure adequately protects information and systems.

☐ Information security requirements remain applicable
☐ Confidentiality requirements addressed
☐ Integrity requirements addressed
☐ Availability requirements addressed
☐ Authentication requirements addressed
☐ Authorization requirements addressed
☐ Logging requirements addressed
☐ Monitoring requirements addressed
☐ Encryption requirements addressed where applicable
☐ Secrets protection addressed
☐ Secure handling requirements addressed


16. Information Handling

Review information involved in the procedure.

☐ Information types remain accurate
☐ Classification remains appropriate
☐ Sensitive information identified
☐ Personal data identified where applicable
☐ Customer information identified
☐ Data transfer requirements remain appropriate
☐ Retention requirements remain appropriate
☐ Secure disposal requirements remain appropriate


17. Risk Review

Determine whether the risks associated with the procedure have changed.

Consider:

  • New threats
  • New vulnerabilities
  • New systems
  • New suppliers
  • New information
  • New access
  • Process changes
  • Incidents
  • Audit findings
  • Regulatory changes

☐ Risk unchanged
☐ Risk increased
☐ Risk decreased
☐ New risk identified
☐ Existing risk no longer applicable

Risk Changes


18. Control Review

Review controls associated with the procedure.

☐ Controls remain applicable
☐ Controls remain correctly described
☐ Control responsibilities remain accurate
☐ Control frequency remains appropriate
☐ Control evidence remains available
☐ Control implementation remains effective
☐ New controls required
☐ Existing controls no longer required


19. Statement of Applicability Consideration

Where relevant:

☐ Related Annex A control applicability reviewed
☐ Control implementation remains appropriate
☐ SoA mapping remains accurate
☐ New risk may require additional control consideration
☐ Procedure remains consistent with the SoA

The procedure review should not automatically change the Statement of Applicability. Any change should follow the organization’s risk assessment and ISMS governance process.


20. Compliance Requirements

Review whether requirements have changed.

☐ Legal requirements
☐ Regulatory requirements
☐ Contractual requirements
☐ Customer requirements
☐ Internal policy requirements
☐ Security requirements
☐ Certification requirements

New Requirements


21. Technology Change Review

Determine whether technology changes affect the procedure.

Consider:

  • Cloud architecture
  • Applications
  • Databases
  • Network
  • IAM
  • CI/CD
  • Infrastructure
  • Monitoring
  • Security tools
  • SaaS platforms

☐ No relevant technology change
☐ Technology changed
☐ Procedure requires update


22. Cloud Review

If the procedure involves cloud services:

☐ Cloud provider remains correct
☐ Cloud architecture remains accurate
☐ Accounts/subscriptions remain accurate
☐ IAM requirements remain accurate
☐ MFA requirements remain accurate
☐ Network controls remain accurate
☐ Backup arrangements remain accurate
☐ Monitoring remains accurate
☐ Recovery arrangements remain accurate


23. Third-Party Review

Where third parties are involved:

☐ Supplier remains active
☐ Supplier responsibilities remain accurate
☐ Supplier access remains appropriate
☐ Subprocessor dependency considered
☐ Contractual requirements remain current
☐ Supplier escalation details remain current
☐ Supplier security requirements remain appropriate


24. Business Continuity Review

Where the procedure supports critical operations:

☐ Business dependency remains accurate
☐ Criticality remains appropriate
☐ RTO considered
☐ RPO considered
☐ Recovery dependency remains accurate
☐ Alternate process remains available
☐ Disaster recovery dependency reviewed


25. Incident and Security Event Review

Review relevant incidents since the previous procedure review.

☐ No relevant incidents
☐ Incident occurred
☐ Procedure was followed successfully
☐ Procedure was difficult to follow
☐ Procedure was insufficient
☐ Incident identified a process gap
☐ Corrective action completed
☐ Lessons learned incorporated

Lessons Learned


26. Audit Findings Review

Review previous audit findings related to the procedure.

☐ No related findings
☐ Findings remain open
☐ Corrective actions completed
☐ Effectiveness verified
☐ Recurring finding identified
☐ Procedure update required

Findings

Finding IDIssueStatusProcedure Change Required

27. Exceptions Review

Review approved exceptions.

☐ No exceptions
☐ Active exception exists
☐ Exception remains valid
☐ Compensating controls remain effective
☐ Exception expiry reviewed
☐ Procedure should be updated to remove recurring exception


28. Evidence Review

Determine whether the procedure generates appropriate evidence.

☐ Evidence requirement documented
☐ Evidence is actually generated
☐ Evidence is complete
☐ Evidence is attributable
☐ Evidence is dated/timestamped where appropriate
☐ Evidence is protected
☐ Evidence can be retrieved
☐ Evidence retention is defined

Examples:

  • Tickets
  • Approval records
  • Logs
  • Reports
  • Screenshots
  • System records
  • Review records
  • Test results

29. Actual Compliance Review

Do not rely only on reading the procedure.

Verify whether personnel actually follow it.

☐ Sampled transactions
☐ Reviewed system records
☐ Reviewed tickets
☐ Interviewed personnel
☐ Observed process
☐ Reviewed evidence
☐ Compared procedure against actual practice

Compliance Result

☐ Compliant
☐ Partially Compliant
☐ Non-Compliant
☐ Further Testing Required


30. Procedure Effectiveness

Assess whether the procedure achieves its intended purpose.

Consider:

  • Security outcomes
  • Operational outcomes
  • Errors
  • Exceptions
  • Incidents
  • Audit findings
  • Delays
  • Rework
  • Control failures
  • User feedback

Effectiveness

☐ Effective
☐ Partially Effective
☐ Ineffective
☐ Unable to Determine

Rationale


31. Usability Review

A procedure should be practical for the people expected to use it.

☐ Instructions are clear
☐ Steps are understandable
☐ Technical terminology is appropriate
☐ Excessive documentation avoided
☐ Required information is easy to locate
☐ Emergency steps are easy to identify
☐ Screenshots/examples remain current where used
☐ Procedure can realistically be followed


32. Security of the Procedure

Review the procedure itself.

☐ Appropriate classification
☐ Access restricted where necessary
☐ Sensitive operational information protected
☐ No passwords included
☐ No API keys included
☐ No private keys included
☐ No unnecessary secrets included
☐ Restricted infrastructure information appropriately protected


33. Document Control

Verify:

☐ Version number correct
☐ Revision history maintained
☐ Owner identified
☐ Approval recorded
☐ Effective date recorded
☐ Review date recorded
☐ Current version identifiable
☐ Obsolete versions controlled


34. Related Documents

Verify references to other documents.

☐ Policies current
☐ Procedures current
☐ Forms current
☐ Registers current
☐ Templates current
☐ Standards current
☐ Work instructions current

Broken or Outdated References


35. Procedure Dependencies

Review dependencies.

☐ Upstream procedures remain valid
☐ Downstream procedures remain valid
☐ Related systems remain available
☐ Supplier dependencies remain valid
☐ Personnel dependencies understood
☐ Recovery dependencies understood


36. Change Impact Assessment

If changes are required, assess impact on:

☐ Related procedures
☐ Policies
☐ Risk assessment
☐ Statement of Applicability
☐ Controls
☐ Systems
☐ Training
☐ Suppliers
☐ Contracts
☐ Business continuity
☐ Audit evidence


37. Required Changes

Change IDChange RequiredReasonPriorityOwnerDue Date

38. Procedure Revision

Determine the required action.

☐ No change
☐ Minor revision
☐ Major revision
☐ Rewrite required
☐ Replace procedure
☐ Retire procedure

Revision Summary


39. Approval of Revised Procedure

Where changes are made:

☐ Revised version prepared
☐ Review completed
☐ Required stakeholders consulted
☐ Security impact reviewed
☐ Compliance impact reviewed
☐ Approval obtained
☐ Effective date established
☐ Previous version controlled


40. Communication

After approval:

☐ Relevant personnel notified
☐ Updated procedure published
☐ Training completed where required
☐ Acknowledgement obtained where required
☐ Obsolete version removed from normal use
☐ Related documentation updated


41. Procedure Review Findings

Finding IDAreaFindingRiskCorrective ActionOwnerDue Date

42. Corrective Action

Where weaknesses are identified:

☐ Immediate correction completed
☐ Root cause assessed
☐ Corrective action defined
☐ Owner assigned
☐ Due date assigned
☐ Remediation evidence required
☐ Effectiveness verification planned


43. Final Review Decision

☐ No Change Required

The procedure remains current and effective.

☐ Minor Update Required

Limited changes are required.

☐ Major Revision Required

Significant changes are required.

☐ Replace

A new procedure is required.

☐ Retire

The procedure is no longer required.


44. Review Summary

Key Changes Since Previous Review

Risks Identified

Findings

Corrective Actions

Overall Review Conclusion


45. Review Approval

Reviewer: ______________________________

Role: ______________________________

Date: ______________________________

Procedure Owner: ______________________________

Approval: ☐ Approved ☐ Further Action Required

Approver: ______________________________

Approval Date: ______________________________


46. Next Review

Next Scheduled Review Date: __________________

Additional Review Trigger

The procedure should also be reviewed before the scheduled date if a material change, incident, audit finding, regulatory change, or other defined trigger occurs.


47. Procedure Review Register

Maintain a central record of completed reviews.

Procedure IDProcedureReview DateReviewerResultChangesNext Review

48. Review Metrics

Possible metrics include:

MetricResult
Procedures reviewed
Procedures due
Procedures overdue
No-change reviews
Minor revisions
Major revisions
Retired procedures
Reviews with findings
Reviews with corrective actions
Recurring findings

49. AWS SaaS Startup Example

A SaaS startup performs its annual review of the Production Deployment Procedure.

During the review, the team identifies that the company has moved from manual deployments to GitHub-based CI/CD.

Review Findings

The existing procedure still states:

Production deployments are performed manually by an authorized DevOps engineer.

This no longer reflects actual operations.

Review Actions

The reviewer:

  1. Confirms the new CI/CD process.
  2. Reviews the deployment workflow.
  3. Verifies branch protection.
  4. Reviews deployment approvals.
  5. Checks CI/CD logs.
  6. Verifies production access.
  7. Reviews rollback capability.
  8. Updates the procedure.
  9. Obtains approval.
  10. Communicates the revised procedure.

Audit Trail

Scheduled Review → Compare Procedure With Actual Process → Identify Change → Assess Impact → Update Procedure → Approve → Communicate → Evidence


50. Startup-Friendly Review Model

For a small SaaS organization, every procedure does not need a lengthy review meeting.

A practical model is:

Step 1 — Document Review

Check:

  • Owner
  • Version
  • Scope
  • Steps
  • References
  • Review date

Step 2 — Change Review

Ask:

What changed since the last review?

Check:

  • Technology
  • People
  • Suppliers
  • Risks
  • Regulations
  • Incidents
  • Audit findings

Step 3 — Evidence Review

Ask:

Is this procedure actually being followed?

Review a reasonable sample of operational evidence.

Step 4 — Effectiveness

Ask:

Does the procedure achieve its intended security/operational outcome?

Step 5 — Decision

Choose:

Keep → Update → Replace → Retire

This provides meaningful review without creating unnecessary administrative overhead.


51. Common Mistakes

Avoid:

  • Reviewing only spelling and formatting.
  • Changing the review date without assessing the procedure.
  • Assuming an approved procedure is automatically effective.
  • Failing to compare the document with actual operations.
  • Ignoring technology changes.
  • Ignoring incidents and audit findings.
  • Failing to review related procedures.
  • Leaving obsolete references.
  • Allowing outdated screenshots or system instructions.
  • Keeping passwords or secrets in procedures.
  • Failing to document review evidence.
  • Updating a procedure without approval.
  • Failing to communicate significant changes.
  • Treating annual review as the only trigger for review.

52. Relationship With Other ISMS Documents

DocumentRelationship
Operating Procedure RegisterTracks procedures and review dates
Documented Operating Procedures PolicyDefines procedure governance
Operating Procedure TemplateProvides procedure structure
Risk RegisterIdentifies risks addressed by procedures
Statement of ApplicabilityProvides relevant control context
Change Management ProcedureIdentifies changes that may trigger procedure review
Incident Response ProcedureProvides incident lessons that may require updates
Compliance Monitoring ProcedureIdentifies procedure compliance issues
Internal Audit ProcedureMay identify procedure weaknesses
Corrective Action TrackerTracks remediation
Exception RegisterTracks approved deviations
Management ReviewProvides governance oversight

53. ISO/IEC 27001 Connection

Procedure reviews support the organization’s ability to maintain controlled and appropriate documented information and ensure that operational practices remain aligned with the ISMS.

The review should consider:

  • ISMS scope
  • Information-security risks
  • Risk treatment
  • Applicable controls
  • Statement of Applicability
  • Business requirements
  • Technology changes
  • Legal and regulatory requirements
  • Customer requirements
  • Contractual requirements
  • Incidents
  • Audit findings
  • Control effectiveness

The Procedure Review Checklist is not itself a universally prescribed ISO/IEC 27001 form. The organization should determine the appropriate review method, frequency, evidence, and approval process based on its risks and operational requirements.


54. Audit Evidence Checklist

An auditor should be able to verify:

☐ Procedure identified
☐ Procedure owner identified
☐ Review date defined
☐ Review actually performed
☐ Reviewer identified
☐ Current version reviewed
☐ Actual process considered
☐ Risks considered
☐ Technology changes considered
☐ Incidents considered
☐ Audit findings considered
☐ Compliance requirements considered
☐ Evidence reviewed
☐ Effectiveness considered
☐ Changes documented
☐ Approval recorded
☐ Updated version controlled
☐ Communication completed where required
☐ Next review established


55. Final Procedure Review Audit Trail

For every significant procedure, the organization should be able to demonstrate:

When was the procedure reviewed?

Who reviewed it?

Why was it reviewed?

What has changed since the previous review?

Does the procedure still reflect actual operations?

Have risks changed?

Have technology or supplier dependencies changed?

Have incidents or audit findings identified weaknesses?

Is the procedure actually being followed?

Is the procedure effective?

What changes were required?

Who approved the changes?

Were the changes communicated?

When will the procedure next be reviewed?

Final Principle

A procedure review is not simply a document-date exercise. A meaningful review confirms that the procedure still reflects the organization’s risks, technology, responsibilities, requirements, and actual operating practices—and that any necessary changes are approved, communicated, implemented, and evidenced.