Independent Security Review Checklist Template (ISO/IEC 27001 A.5.35, A.5.36)
Review programme and triggers, reviewer independence, ISMS approach checklist, manager and technical compliance checklists, ratings, reporting, size tiers
Cómo usar: Use it to plan and record the independent review of the ISMS approach (A.5.35) and the manager and technical compliance reviews (A.5.36). Fill the review programme and the reviewer independence table first. The main pitfall is presenting the internal audit report or a single scan as these reviews without showing scope, independence and follow-up.
Vista previa
Independent Security Review and Compliance Review Checklist: [Organization name]
Planning form, checklist and report format for two related controls of ISO/IEC 27001:2022 + Amd 1:2024 Annex A: A.5.35 (independent review of security: an objective look at the whole ISMS approach, planned and also triggered by major change) and A.5.36 (compliance with security policies and standards: managers and technical checks confirm that the rules are followed). Read the official control text for the exact requirements. It explains how both differ from the internal audit required by clause 9.2 and from management review in clause 9.3. Replace every
[bracketed]value and every row marked Example.
Document control
| Field | Value |
|---|---|
| Document ID | [DOC-ISMS-048] |
| Version | [1.0] |
| Status | [Draft / In review / Approved / Superseded] |
| Owner | [@isms-manager] |
| Approvers/reviewers | [@ciso], [@ceo or audit committee chair] |
| Last updated | YYYY-MM-DD |
| Classification | [Confidential] |
| Standard and edition | ISO/IEC 27001:2022 + Amd 1:2024 (A.5.35, A.5.36, cl. 9.2, cl. 9.3); ISO/IEC 27002:2022; ISO 19011:2026 for review practice |
| Next scheduled review | YYYY-MM-DD |
| Review cycle covered | [YYYY-MM-DD to YYYY-MM-DD] |
| ISMS scope reference | [DOC-ISMS-002] |
| Internal audit programme reference | [DOC-ISMS-082] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| ISMS manager | [@isms-manager] | [Prepared] | YYYY-MM-DD |
| CISO | [@ciso] | [Reviewed] | YYYY-MM-DD |
| Top management or audit committee | [@ceo] | [Approved programme and reviewer appointment] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change |
|---|---|---|---|
| 1.0 (Example) | YYYY-MM-DD | [@isms-manager] | Programme for the first certification cycle |
| 1.1 (Example) | YYYY-MM-DD | [@isms-manager] | Extra independent review added after the merger of the support function (significant change) |
Contents
- Purpose and scope
- Independent review, compliance review and internal audit compared
- Review programme and triggers
- Reviewer independence and competence
- Checklist A: independent review of the ISMS approach (A.5.35)
- Checklist B: management compliance reviews (A.5.36)
- Checklist C: technical compliance reviews (A.5.36)
- Ratings and findings
- Reporting and follow-up
- Size tiers
- Records and evidence
- References
1. Purpose and scope
This document records how [Organization name] obtains an objective view of whether the way it runs information security still fits its risks, has enough people and money behind it, and actually works in practice. It has three parts that answer different questions:
- Independent review (A.5.35): is our overall approach to information security (policies, organization, processes, resources, controls) right for our risks and objectives, and is it implemented as designed? Done by people independent of the area reviewed.
- Management compliance review (A.5.36): in each area, do people and processes stick to the security documents written for them, from the top-level policy down to local rules? Done by the managers who own the area, or someone they appoint.
- Technical compliance review (A.5.36): do systems actually match the required configurations and rules? Done with tools and by technical reviewers, without disturbing operations.
Scope of this cycle: [ISMS scope as in DOC-ISMS-002, with any areas added because of significant change].
2. Independent review, compliance review and internal audit compared
| Aspect | Internal audit (cl. 9.2) | Independent review (A.5.35) | Compliance review (A.5.36) | Management review (cl. 9.3) |
|---|---|---|---|---|
| Question | Do our processes match what we wrote down and what the standard asks for, and do they work day to day? | Is our way of running security the right one for our risks, and does reality match the design? | Do people and systems in each area follow the rules that apply to them? | Does the ISMS still serve the business, and what must change? |
| Who | Auditors who are objective and impartial | Reviewers independent of the area, internal or external | Area managers, system owners, technical reviewers | Top management |
| Basis | Audit criteria, sampling, audit programme | Review terms of reference, often wider than conformity | Policy set, standards, baselines | Inputs listed in 9.3.2 |
| Frequency | Planned intervals per audit programme | Planned intervals and on significant change | Regularly, per area and per system | Planned intervals |
| Output | Audit findings and nonconformities | Conclusions and recommendations on the approach | Compliance status, deviations, corrective actions | Decisions and actions |
| Records | Audit programme and results (required documented information) | Review report | Review checklists, scan reports | Management review results (required documented information) |
Decision for this organization: [Example: the annual internal audit covers conformity; a separate external independent review every second year covers the approach as a whole; in the other year the internal audit terms of reference include section 5 of this checklist and the report says so.]
3. Review programme and triggers
3.1 Programme
| Review ID | Type | Scope | Reviewer | Planned | Done | Report |
|---|---|---|---|---|---|---|
| ISR-2027-01 (Example) | Independent review (A.5.35) | Whole ISMS approach | External reviewer, engaged by the CEO | 2027-03 | YYYY-MM-DD | ISR-2027-01-R |
| CMR-2027-Q1-ENG (Example) | Management compliance review | Engineering: access, change, secure development | Head of Engineering | 2027-02 | YYYY-MM-DD | Checklist B |
| CMR-2027-Q1-PEO (Example) | Management compliance review | People: screening, onboarding, offboarding, training | Head of People | 2027-02 | YYYY-MM-DD | Checklist B |
| TCR-2027-M01 (Example) | Technical compliance review | Cloud configuration against baseline | Platform lead | Monthly | YYYY-MM-DD | Posture report |
| TCR-2027-Q1-ACC (Example) | Technical compliance review | User and privileged access | Service owners | Quarterly | YYYY-MM-DD | Access review record |
| [ID] | [type] | [scope] | [reviewer] | [YYYY-MM] | YYYY-MM-DD | [ref] |
3.2 Triggers for an extra independent review
Run an independent review outside the plan when any of these occurs:
- a merger, acquisition, divestment or new legal entity in scope;
- a major outsourcing or insourcing decision, or a change of primary cloud provider;
- a major incident, or a pattern of incidents with a shared cause;
- a significant change of risk appetite, business model or regulation (for example becoming subject to NIS2 or DORA);
- replacement of the CISO or ISMS manager, or a major reorganization of security roles;
- a certification body finding that questions the ISMS approach.
The ISMS manager records each trigger, the decision to review or not, and who approved the decision.
4. Reviewer independence and competence
4.1 Independence criteria
| Criterion | Reviewer 1 | Reviewer 2 |
|---|---|---|
| Not responsible for designing or operating the area reviewed | [Yes / No] | [Yes / No] |
| Does not report to the owner of the area reviewed | [Yes / No] | [Yes / No] |
| No involvement in the area in the last [12] months | [Yes / No] | [Yes / No] |
| No financial or personal interest in the result | [Yes / No] | [Yes / No] |
| Has direct access to top management for the report | [Yes / No] | [Yes / No] |
| Declaration of conflicts signed (section 4.3) | [Yes / No] | [Yes / No] |
Any "No" needs a written mitigation (for example a second reviewer, a reduced scope or a different reporting line) approved by top management.
4.2 Competence
| Competence area | Evidence | Reviewer 1 | Reviewer 2 |
|---|---|---|---|
| Information security management and ISO/IEC 27001 | Training record, prior reviews or audits | [evidence] | [evidence] |
| Review and audit method (for example ISO 19011:2026 principles) | Training record | [evidence] | [evidence] |
| Knowledge of the business and its sector | Briefing, prior experience | [evidence] | [evidence] |
| Technical depth for the scope (cloud, OT, development) | Certification or experience | [evidence] | [evidence] |
Record competence in the competence and training matrix (DOC-ISMS-026).
4.3 Declaration of independence
Each reviewer signs this declaration before fieldwork starts. Keep the signed copy with the review file.
I, [name], appointed as reviewer for [review ID], confirm that:
- I have not designed, operated or managed the activities in scope in the
last [12] months;
- I do not report to the owner of the activities in scope;
- I have no financial or personal interest in the outcome;
- I will report to [top management role] without prior approval of the
content by the owners of the areas reviewed.
Conflicts declared: [none / description and mitigation]
Signed: [name] Date: YYYY-MM-DD
5. Checklist A: independent review of the ISMS approach (A.5.35)
| ID | Review question | Evidence to examine | Rating | Notes |
|---|---|---|---|---|
| IR-01 | Is the ISMS scope still right for the business, including new services, sites, legal entities and cloud services? | Scope (DOC-ISMS-002), context (DOC-ISMS-003), product list | [rating] | [notes] |
| IR-02 | Are internal and external issues, including climate change where relevant (cl. 4.1, Amd 1:2024), reviewed and reflected in the risk assessment? | Context document, risk register | [rating] | [notes] |
| IR-03 | Do interested party requirements reach the legal register, contracts and controls? | Legal register (DOC-ISMS-014), sample of contracts | [rating] | [notes] |
| IR-04 | Is top management visibly leading, setting direction and resourcing the ISMS? | Policy approval, steering minutes (DOC-ISMS-007), budget (DOC-ISMS-031) | [rating] | [notes] |
| IR-05 | Are roles, responsibilities and authorities clear and staffed, with deputies? | RACI (DOC-ISMS-006), organization chart | [rating] | [notes] |
| IR-06 | Is the risk method producing consistent, comparable results that drive decisions? | Methodology (DOC-ISMS-010), last assessment report (DOC-ISMS-017) | [rating] | [notes] |
| IR-07 | Do the controls selected in the SoA match the risks, and are exclusions defensible? | SoA (DOC-ISMS-011), risk treatment plan (DOC-ISMS-013) | [rating] | [notes] |
| IR-08 | Are objectives measurable, monitored and reported? | Objectives register (DOC-ISMS-024), performance report (DOC-ISMS-081) | [rating] | [notes] |
| IR-09 | Is the policy set complete, current, communicated and understood by staff? | Policy index (DOC-ISMS-005), interviews with 5 staff | [rating] | [notes] |
| IR-10 | Are suppliers, including cloud providers, managed in proportion to risk? | Supplier register (DOC-ISMS-066), assessments | [rating] | [notes] |
| IR-11 | Can the organization detect, respond to and recover from incidents and disruptions, as shown by exercises and real events? | Incident register (DOC-ISMS-021), ICT readiness tests (DOC-ISMS-047) | [rating] | [notes] |
| IR-12 | Do internal audit, management review and corrective action close the loop? | Audit programme (DOC-ISMS-082), review minutes (DOC-ISMS-085), CAPA records | [rating] | [notes] |
| IR-13 | Are resources (people, budget, tools, skills) sufficient for the plans? | Budget plan, training matrix (DOC-ISMS-026) | [rating] | [notes] |
| IR-14 | Has the ISMS adapted to significant changes since the last review (cl. 6.3)? | Change plan (DOC-ISMS-025) | [rating] | [notes] |
| IR-15 | Are previous independent review recommendations implemented or consciously rejected? | Last review report, action list | [rating] | [notes] |
6. Checklist B: management compliance reviews (A.5.36)
Area: [area] Manager: [@manager] Period: [YYYY-MM-DD to YYYY-MM-DD]
| ID | Requirement source | Check | Sample | Result | Cause if not compliant | Action |
|---|---|---|---|---|---|---|
| CR-01 | Acceptable use policy (DOC-ISMS-040) | Staff in the area acknowledged the current version | All staff in the area | [Compliant / Partly / Not compliant] | [cause] | [action] |
| CR-02 | Access control policy (DOC-ISMS-041) | Joiner, mover and leaver changes match approved requests | [10] changes | [result] | [cause] | [action] |
| CR-03 | Information labelling and handling (DOC-ISMS-042) | Documents shared externally carry the right label | [10] documents | [result] | [cause] | [action] |
| CR-04 | Clear desk and clear screen (DOC-ISMS-056) | Walk-through of the area outside working hours | Whole area | [result] | [cause] | [action] |
| CR-05 | Security awareness programme | Training completed within the required period | All staff | [result] | [cause] | [action] |
| CR-06 | Security operating procedures (DOC-ISMS-049) | Procedures in use are the approved version and are followed | [3] procedures | [result] | [cause] | [action] |
| CR-07 | Supplier rules (DOC-ISMS-066) | New suppliers in the area were assessed before use | All new suppliers | [result] | [cause] | [action] |
| CR-08 | Remote working policy (DOC-ISMS-054) | Remote staff use managed devices and approved networks | [10] staff | [result] | [cause] | [action] |
| CR-09 | Exceptions (DOC-ISMS-122) | Every deviation has a current, approved exception | All open exceptions | [result] | [cause] | [action] |
| CR-10 | Area-specific rule: [rule] | [check] | [sample] | [result] | [cause] | [action] |
Worked example (Example), Engineering area at Quillmere Analytics Ltd: CR-02 sampled 10 access changes; 9 matched an approved ticket and 1 leaver kept repository access for 6 days. Result: Partly compliant (9 of 10, 90%). Cause: leaver ticket raised by the manager after the last day. Action: automate repository de-provisioning from the HR system, owner [@platform-lead], recorded as finding AF-2027-014 in the audit findings register.
7. Checklist C: technical compliance reviews (A.5.36)
| ID | Target | Baseline or rule | Method | Frequency (Example) | Result | Action |
|---|---|---|---|---|---|---|
| TC-01 | Cloud accounts and subscriptions | Secure configuration baseline (DOC-ISMS-060) | Posture management tool, read-only role (security/cloud-security-posture-review) | Monthly | [pass rate, exceptions] | [action] |
| TC-02 | Endpoints | Endpoint policy (DOC-ISMS-058) | MDM compliance report: encryption, patch level, EDR running | Monthly | [result] | [action] |
| TC-03 | Servers and containers | Hardening baseline, CIS Benchmarks where adopted (names only) | Configuration scanner | Monthly | [result] | [action] |
| TC-04 | Network rules | Network security standard (DOC-ISMS-063) | Firewall and security group review (security/firewall-rule-review) | Quarterly | [result] | [action] |
| TC-05 | User and privileged access | Access control policy (DOC-ISMS-041) | Access recertification (ops/access-review) | Quarterly | [result] | [action] |
| TC-06 | Vulnerabilities | Remediation time limits | Vulnerability scan, tracker (DOC-ISMS-072) | Weekly scan, monthly review | [result] | [action] |
| TC-07 | Cryptography | Cryptography standard | Certificate and key inventory check (DOC-ISMS-070) | Quarterly | [result] | [action] |
| TC-08 | Logging | Security logging standard | Log source coverage check against the inventory | Quarterly | [result] | [action] |
| TC-09 | Applications | Secure development policy (DOC-ISMS-065) | Penetration test (security/pentest-report), static analysis results | Annually and on major release | [result] | [action] |
Before any intrusive test, agree the scope, timing, accounts and rollback with the system owner, and record the approval. Penetration tests and vulnerability assessments are done by competent, authorized people only.
8. Ratings and findings
| Rating | Meaning in Checklist A | Meaning in Checklists B and C |
|---|---|---|
| Effective / Compliant | Approach fits the risks and runs as designed | Requirement met in every sampled item |
| Improvement opportunity | Works, but a change would make it more effective or efficient | Met, with a weakness that could lead to non-compliance |
| Partly effective / Partly compliant | Gaps in design or implementation that weaken the approach | Met in some sampled items, not all |
| Not effective / Not compliant | Approach does not address the risk or is not implemented | Requirement not met |
| Finding ID | Review ID | Checklist item | Rating | Description | Cause | Owner | Due | Register link |
|---|---|---|---|---|---|---|---|---|
| AF-2027-014 (Example) | CMR-2027-Q1-ENG | CR-02 | Partly compliant | Leaver kept repository access for 6 days | Manual de-provisioning after the last day | [@platform-lead] | YYYY-MM-DD | DOC-ISMS-086 |
| AF-2027-021 (Example) | ISR-2027-01 | IR-13 | Partly effective | Security monitoring depends on one engineer with no trained deputy | Growth without resourcing review | [@ciso] | YYYY-MM-DD | DOC-ISMS-086 |
| [AF-YYYY-NNN] | [review ID] | [item] | [rating] | [description] | [cause] | [@owner] | YYYY-MM-DD | [link] |
Findings that are nonconformities with ISMS requirements are handled through corrective action (cl. 10.2, DOC-ISMS-087). Improvement opportunities go to the continual improvement register (DOC-ISMS-088).
9. Reporting and follow-up
Report contents for an independent review:
- Terms of reference, scope, period and reviewer independence statement.
- Method: documents examined, interviews, samples, technical tests.
- Overall conclusion on suitability, adequacy and effectiveness.
- Results per Checklist A item with ratings.
- Findings and recommendations, ranked by risk.
- Management responses, including recommendations not accepted and why.
- Comparison with the previous review.
Compliance review results are summarized quarterly in the ISMS performance report (DOC-ISMS-081) as compliance rates per area and per technical check, with trends. Overdue actions are escalated to the ISMS steering committee (DOC-ISMS-007).
Worked example (Example): in the first quarter Quillmere Health Systems ran 6 management compliance reviews with 10 items each (60 items). 51 were compliant, 7 partly compliant and 2 not compliant (51 + 7 + 2 = 60). Compliance rate: 51 of 60, or 85%. The 9 findings were entered in the audit findings register with owners and dates.
10. Size tiers
| Aspect | Small: Quillmere Analytics Ltd (46 staff) | Medium: Quillmere Health Systems (320 staff) | Large: Quillmere Group (2,400 staff, 6 sites) |
|---|---|---|---|
| Independent review | External reviewer every year, because the part-time ISMS manager built most of the ISMS and cannot review it | Internal audit covers Checklist A in alternate years; external review in the other years | Group internal audit function reports to the audit committee; external review of the group approach every 2 to 3 years |
| Management compliance reviews | 3 areas (engineering, operations, people), twice a year | 6 areas, quarterly | Each of the 6 sites and each group function, quarterly, consolidated by the security office |
| Technical compliance reviews | Monthly cloud posture and endpoint reports, quarterly access review | Same plus colocation suite and network reviews by the 3-person security team | Includes OT networks at the plants, with read-only methods agreed with plant engineering |
| Reporting | Directly to the CEO | ISMS manager to the steering committee | Security office to the group risk committee and audit committee, aligned with the integrated management system |
11. Records and evidence
| Record | Proves | Owner | Location | Retention (Example) |
|---|---|---|---|---|
| Review programme (section 3) | Reviews are planned at intervals and on change | ISMS manager | This document | 3 years |
| Independence declarations and competence evidence | Reviewers were independent and competent | ISMS manager | Review file, training matrix (DOC-ISMS-026) | 3 years |
| Independent review reports | A.5.35 operates | Top management | Board or committee papers | 6 years |
| Completed Checklists B and C | A.5.36 operates in each area and system | Area managers, system owners | Review file, tool exports | 3 years |
| Findings and actions | Results lead to correction | ISMS manager | Audit findings register (DOC-ISMS-086), CAPA records (DOC-ISMS-087) | Until closed plus 3 years |
| Management review minutes | Top management considered results | ISMS manager | DOC-ISMS-085 | 3 years |
Set the final retention periods in the documented information register (DOC-ISMS-028).
12. References
| Reference | Edition | Use |
|---|---|---|
| ISO/IEC 27001:2022 + Amd 1:2024, information security management systems, requirements | 2022, Amd 1 published 2024-02-23 | A.5.35, A.5.36, cl. 9.2, cl. 9.3, cl. 10.2 |
| ISO/IEC 27002:2022, information security controls | 2022 | Guidance for A.5.35 and A.5.36 |
| ISO/IEC 27007:2020, guidelines for ISMS auditing | 2020 (a revision is in progress; check for a newer edition) | Audit practice that also helps review practice |
| ISO/IEC TS 27008:2019, guidance on the assessment of information security controls | 2019 (under revision) | Technical compliance review methods |
| ISO 19011:2026, guidelines for auditing management systems | 2026 | Reviewer principles and competence |
Official pages: ISO/IEC 27001 https://www.iso.org/standard/82875.html, Amd 1 https://www.iso.org/standard/88435.html, ISO/IEC 27002 https://www.iso.org/standard/75652.html, ISO/IEC 27007 https://www.iso.org/standard/77802.html, ISO/IEC TS 27008 https://www.iso.org/standard/67397.html, ISO 19011 https://www.iso.org/standard/88984.html.
Related templates: compliance/internal-audit-program,
isms/isms-internal-audit-checklist, isms/isms-internal-audit-report,
compliance/management-review, isms/audit-findings-register,
compliance/capa-nonconformity, isms/continual-improvement-register,
ops/access-review, security/firewall-rule-review,
security/cloud-security-posture-review, security/pentest-report,
isms/control-evidence-matrix.
Standard and licence note
Structure aligned with ISO/IEC 27001:2022 (including Amd 1:2024) Annex A controls A.5.35 and A.5.36 and clauses 9.2 and 9.3. The questions, checklists, rating scale, comparison table and examples are original wording. ISO/IEC text is not reproduced: clause and control numbers are given with short descriptions written for this template, not the official titles, requirements or guidance text. ISO and IEC standards are copyrighted; obtain the official standards from ISO or your national standards body before relying on this template. Check the current edition and amendments of each standard before use. This is a documentation format, not certification advice. Template licence: MIT.
Plantillas relacionadas
Offboarding Security Checklist Template (ISO/IEC 27001 A.6.5)
Leaver types L1 to L5 with revocation timing, HR triggers, leaver and mover checklists, privileged and urgent leavers, continuing duties, verification
SGSI e ISO/IEC 27001Project Information Security Checklist Template (ISO/IEC 27001 A.5.8)
Project security checklist for A.5.8: security tiers, gates G1 to G4, checks per stage, privacy by design, project types (software, cloud, M&A), risk log
SGSI e ISO/IEC 27001Cloud Services Security Policy Template (ISO/IEC 27001 A.5.23)
Cloud policy for A.5.23: shared responsibility, tiers, due diligence, contract terms, configuration, monitoring, exit, shadow IT, cloud register