Auditing ISO 27001 Clause 7.3 is the systematic verification that all personnel possess adequate awareness of the Information Security Policy. The audit validates that staff understand the Primary Implementation Requirement of their specific role and the implications of non-compliance. Effective auditing ensures the Business Benefit of a security-conscious culture and reduced human error.

Auditing ISO 27001 Clause 7.3 requires a deep dive into the human element of your Information Security Management System (ISMS). An auditor will look beyond simple completion certificates to determine if personnel truly understand their role in protecting data. This process involves verifying that every individual, from senior leadership to third-party contractors, recognises the implications of security non-conformity and the specific requirements of the organisation’s security policies.

1. Review HR Onboarding Records

Verify that all new personnel have undergone a formal security induction within their first week of employment to ensure immediate awareness of security obligations.

Inspect the onboarding checklist for signatures related to the Information Security Policy.
Ensure that IAM roles and access permissions were only provisioned after the induction was completed.
Cross-reference the Asset Register to confirm hardware was issued alongside security training.

2. Examine Policy Acknowledgement Logs

Formalise the review of digital signature logs to confirm that 100% of staff have read and accepted the most recent version of the Information Security Policy.

Check for version control timestamps to ensure signatures align with the latest policy iteration.
Identify any “ghost” accounts or personnel who have bypassed the sign-off process.
Validate that policy updates are communicated via official channels with a clear audit trail.

3. Conduct Spontaneous Staff Interviews

Interview a random sample of staff members to test their spontaneous knowledge of the organisation’s security objectives and the benefits of improved ISMS performance.

Ask employees to define how their specific role contributes to the effectiveness of the ISMS.
Test knowledge regarding the “Rules of Engagement” (ROE) for physical security and hardware usage.
Observe if staff can locate the security policy on the company intranet without assistance.

4. Inspect Awareness Training Materials

Audit the quality and technical density of the training curriculum to ensure it covers modern threats such as social engineering, MFA bypass, and data mishandling.

Verify that the content is updated at least annually to reflect the evolving threat landscape.
Confirm that training includes specific instructions on reporting security incidents or vulnerabilities.
Assess if the training is tailored to different job roles, such as developers versus administrative staff.

5. Evaluate Phishing Simulation Data

Analyse the results of internal phishing simulations to measure the practical application of awareness training across the organisation.

Review the “click rate” and “report rate” metrics to identify departments requiring additional support.
Check for evidence of remedial training for individuals who failed the simulation.
Ensure simulation scenarios are realistic and based on actual threats relevant to the industry.

6. Audit the Communication Plan

Review the internal communication register to confirm that security awareness is reinforced through regular, varied messaging rather than a single annual event.

Examine newsletters, posters, or digital signage used to promote security best practices.
Validate that security “top tips” or alerts are sent in response to emerging global security incidents.
Assess the frequency of communication to ensure security remains “top of mind” for all personnel.

7. Verify Privileged User Training

Audit the specific awareness requirements for staff with elevated IAM roles to ensure they understand the heightened risks associated with their access.

Check for additional training modules focused on server administration, database security, or cloud configuration.
Confirm that privileged users have signed a specific code of conduct or ROE document.
Verify that MFA is not only enforced but that users understand the risks of MFA fatigue attacks.

8. Cross-Reference Training with Disciplinary Logs

Examine HR disciplinary records to ensure that the implications of security non-conformity are communicated and, where necessary, enforced.

Verify that the disciplinary process is clearly outlined in the awareness materials.
Check if security breaches caused by negligence have resulted in documented warnings or retraining.
Ensure that “no-blame” reporting is encouraged to maintain a transparent security culture.

9. Assess Third-Party and Contractor Awareness

Verify that contractors and temporary staff working under the organisation’s control are included in the awareness programme to prevent security silos.

Inspect contract clauses that mandate security awareness training for third-party providers.
Check the visitor log and contractor portal for evidence of security briefings.
Ensure that temporary staff have restricted access that aligns with their documented awareness level.

10. Analyse Awareness Engagement Metrics

Review the analytics from the internal security portal or learning management system to quantify the reach and depth of the awareness programme.

Check for “time-on-page” or quiz scores to determine if staff are engaging with the content or simply clicking through.
Identify trends in security queries sent to the IT helpdesk as a result of increased awareness.
Use these metrics to justify the continuous improvement of the awareness strategy in management reviews.

ISO 27001 Clause 7.3 Audit Step Overview

Formal Audit Step Reference Table

A comprehensive breakdown of audit steps, methodologies, and evidence examples for Clause 7.3.
Audit Step	Audit Methodology	Evidence Example
1. HR Onboarding	Sample HR files for new starters within the last 6 months.	Signed induction checklist and IAM provision logs.
2. Policy Acknowledgement	Export a report from the document management system.	Timestamped PDF log showing 100% staff acceptance.
3. Staff Interviews	Conduct face-to-face or video calls with random departments.	Auditor notes confirming verbal understanding of ISMS.
4. Material Inspection	Review the slide decks or video content used for training.	Training syllabus covering MFA, ROE, and Phishing.
5. Phishing Analysis	Review the dashboard of the simulation tool.	Quarterly report showing improved reporting rates.
6. Communication Plan	Inspect the internal communications calendar.	Copies of security newsletters and intranet screenshots.
7. Privileged Training	Review training records for all system administrators.	Advanced security certificates and signed ROE docs.
8. Disciplinary Review	Interview HR regarding security-related misconduct.	Anonymised disciplinary logs following a security event.
9. Contractor Audit	Review onboarding logs for external consultants.	Signed non-disclosure agreements and induction logs.
10. Portal Analytics	Examine back-end data from the learning portal.	Heatmaps or quiz result distributions.

The Hidden Risks of SaaS GRC Platforms in Awareness Audits

10 Common SaaS Platform Audit Failures

Analysis of why automated compliance software often leads to non-conformities during a manual ISO 27001 audit.
SaaS Failure Mode	Audit Impact	Why It Fails
Automated Certificate Generation	Evidence Rejection	Auditors see certificates as “paper exercises” that do not prove actual knowledge retention.
Generic Content Modules	Non-Conformity	SaaS platforms provide “one-size-fits-all” content that ignores your specific Asset Register and ROE.
Dashboard Disconnect	False Security	A “100% Green” dashboard often masks the fact that employees are using browser extensions to skip videos.
Ignoring Physical Security	Scope Gap	Most SaaS tools focus only on digital threats, neglecting physical ROE and office security awareness.
Lack of Role-Specific Detail	Technical Failure	Generic platforms fail to provide the deep-dive training required for specific IAM and admin roles.
Inflexible Reporting	Verification Issues	Standard SaaS reports often lack the granular detail (timestamps, IP logs) required by rigorous auditors.
Predictable Phishing Templates	Skewed Metrics	Employees learn the SaaS tool’s templates rather than actual phishing tactics, leading to false low click-rates.
Contractor Exclusion	Incomplete Scope	License-based SaaS models often lead firms to exclude contractors to save costs, creating a major audit gap.
Culture of “Tick-Box” Compliance	Cultural Failure	Automated reminders encourage staff to treat security as a nuisance rather than a core responsibility.
No Offline Verification	Evidence Gap	SaaS platforms cannot track or verify “water-cooler” security awareness or physical poster engagement.

About the author

Stuart Barker

ISO 27001 Ninja

Stuart Barker is a veteran practitioner with over 30 years of experience in systems security and risk management. Holding an MSc in Software and Systems Security, he combines academic rigor with extensive operational experience, including a decade leading Data Governance for General Electric (GE).

As a qualified ISO 27001 Lead Auditor, Stuart possesses distinct insight into the specific evidence standards required by certification bodies. His toolkits represent an auditor-verified methodology designed to minimise operational friction while guaranteeing compliance.