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ISO 22301: An overview of BCM implementation process


September 10, 2014


Dilemmas with ISO 27001 & BS 25999-2 internal auditors

'By 'Dejan Kosutic on March 22, 2010

If this is the first time you have come across the notion of internal auditor, you are probably puzzled – Why would I need another control? Who is going to pay for it? Who should I employ to do it? It is such a waste of time…

Well, it doesn’t have to be so bad – besides complying with ISO 27001 & BS 25999-2 standards, internal audits could be quite useful for your other business affairs (whether related to information security & business continuity or not).

The point with internal audits is that they should discover problems that would otherwise stay hidden and would therefore harm the business. Let’s be realistic – it is human to make mistakes, so it‘s impossible to have a system with no mistakes; it is however possible to have a system which improves itself and learns from its mistakes. Internal audits are a crucial part of such a system.

There are a few ways to perform internal audit:

a) Employ a full time internal auditor – this is suitable only for larger organizations who would have enough work for such a person (some types of organizations – e.g. banks – are obliged by law to employ such functions)

b) Employ part time internal auditors – this is the most common situation – the organizations use their own employees to perform internal audits alongside their regular job functions. One important thing to pay attention to: in order to avoid conflict of interest (the auditors cannot audit their own work), there should be at least two internal auditors so that one could audit the regular job of the other.

c) Employ internal auditor from outside of the organization – although this is not a person employed in the organization, it is still considered internal audit because the audit is performed by the organization itself, according to its own rules. Usually this is done by a person who is knowledgeable in this field (independent consultant etc.).

However, from my experience as an auditor, the sad truth is that most of the organizations perform internal audits just to satisfy the certification body. The result of such internal audits are a few non-conformities which do not get deep into the real problems of information security management system (ISMS) or business continuity management system (BCMS). This is a waste of time – if the companies have invested time of their internal auditors to perform such jobs, they should gain some benefits out of it.

But how then to approach internal audits in the right way – here are some thoughts:

  1. The management should view the internal audit as one of the best tools to improve the system, not only as a means to get certified.
  2. The internal auditor should be qualified – this means he/she must have experience in information security, information technology and auditing techniques. It does not mean that the auditor must be an expert in those fields.
  3. The internal audit should be performed in a positive way – the aim should be to improve your system, not to blame the employees for their mistakes.

On the positive side, as a certification auditor I did see some organizations performing internal audits in a right way. Although their employees did feel a little uncomfortable about someone checking their activities, very soon they saw the benefits of such approach – problems became transparent, and were resolved rather soon.

You can also check out our video tutorial How to Write ISO 27001/ISO 22301 Internal Audit Procedure and Audit Program (commercially sold video).

  • Alen Gojceta

    I believe that the 3rd point above is the most important one. Audits often become purpose of their own, especially when this is a full time employment role within an organization. “The positive way” that you stated could be interpreted as “work for the purpose of business, and not for the purpose of the standard itself”.

  • Vishwas N

    Very informative!
    In fact in small orgonisations, where people are so hard pressed with their own work, i feel it is prudent to appoint agency to asssist in maintanance of certification and get audit done by different group from that agenncy to leverage on expertise in domain as well as to reduce the burden on people in that orgonisation. This model works very fine in many orgonisations as it becomes cost effective solution as well as delivers quality work with involvement of internal staff.

  • Dejan Kosutic


    I agree that you can hire an external auditor that would perform internal audit, however I do not think it would be wise to hire an external help to “maintain your certification”. In my view, maintaining the ISO 27001 certification is not some extra administrative work, but everyday activities you have to perform in order to keep your data secure – for instance, you have to perform your data backup, you have to watch out for your laptop if you carry it outside of your organization, you have to instruct your employees to observe all the security rules. It doesn’t make much sense to outsource these activities to someone else.

  • SivakumarTv

    To add on to the point from Vishwas on appointing two different groups from the same agency, i think that will result in conflict of interests from the Agency standpoint since they are auditing their own work. This must be avoided since the certification auditors might decide not to bring up any serious gaps in the ISMS as that will harm their own company’s reputation. And to clarify on Dejan’s opinion, the external agency will only help in defining the controls ( such as installing encryption s/w in all laptops and best practices around physical security of laptops ) but obviously they can not do anything more than that.