Auditing ISO 27001 Annex A 5.1 Policies for Information Security is the definitive assessment of governance structures and management intent. This process validates the Primary Implementation Requirement of maintaining a formally approved, topic-specific policy framework. The Business Benefit ensures organizational alignment and legal defensibility by clearly defining security expectations for all personnel and stakeholders.
This technical verification tool is designed for lead auditors to conduct a definitive assessment of policy governance. Use this checklist to validate compliance with ISO 27001 Annex A 5.1 (Policies for Information Security) by focusing on the integrity of management approval and the operationalisation of topic-specific requirements.
1. High-Level Information Security Policy Approval Verified
Verification Criteria: The primary Information Security Policy must be formally approved by top management, demonstrating leadership commitment to the ISMS.
Required Evidence: Signed policy document or Management Review Meeting (MRM) minutes explicitly recording the board-level approval of the current policy version.
Pass/Fail Test: If the policy lacks a formal signature, digital approval stamp, or corresponding minute-entry from executive leadership, mark as Non-Compliant.
2. Topic-Specific Policy Architecture Validated
Verification Criteria: A comprehensive suite of topic-specific policies (e.g., Access Control, Cryptography, Physical Security) exists to support the high-level policy as defined by the ISMS scope.
Required Evidence: Document register showing a structured hierarchy of active, approved topic-specific policies.
Pass/Fail Test: If significant control areas identified in the Statement of Applicability (SoA) lack supporting topic-specific documentation, mark as Non-Compliant.
3. Policy Accessibility for Relevant Personnel Confirmed
Verification Criteria: All policies must be published in a format and location (e.g., Intranet, DMS) that is accessible to all employees and contractors within the ISMS scope.
Required Evidence: Live demonstration of the policy repository and verification of “Read Only” access permissions for general staff.
Pass/Fail Test: If policies are stored in a restricted folder inaccessible to the staff expected to follow them, mark as Non-Compliant.
4. Policy Communication and Acknowledgement Records Present
Verification Criteria: Evidence must exist that personnel have been notified of policy updates and have formally acknowledged their understanding of their responsibilities.
Required Evidence: Logs from a Learning Management System (LMS), signed acknowledgement forms, or automated read-receipt reports from a GRC platform.
Pass/Fail Test: If more than 10% of the sampled personnel list lacks a record of policy acknowledgement within the last 12 months, mark as Non-Compliant.
5. Formal Policy Review Cycle Evidence Identified
Verification Criteria: Policies must be reviewed at planned intervals (at least annually) to ensure their continuing suitability, adequacy, and effectiveness.
Required Evidence: Document revision history showing review dates even if no changes were required, or MRM minutes documenting the annual policy review agenda item.
Pass/Fail Test: If the “Last Reviewed” date on any mandatory policy exceeds the frequency defined in the organisation’s own governance framework, mark as Non-Compliant.
6. Ad-Hoc Review Triggers for Significant Changes Verified
Verification Criteria: A mechanism must exist to trigger policy reviews outside the annual cycle in response to significant organisational or technical changes (e.g., major breach, merger, or tech stack migration).
Required Evidence: Internal audit reports or change management records showing policy updates following a major business milestone or security incident.
Pass/Fail Test: If a significant infrastructure change occurred without a corresponding review of the related security policies, mark as Non-Compliant.
7. Policy Alignment with Organisational Objectives Validated
Verification Criteria: Information security policies must reflect the organisation’s specific business requirements, legal obligations, and contractual security commitments.
Required Evidence: Mapping document or policy statements that explicitly reference relevant legislation (e.g., GDPR, UK DPA 2018) or industry standards.
Pass/Fail Test: If policy content is found to be “generic template” material that contradicts actual business workflows or legal jurisdictions, mark as Non-Compliant.
8. Stakeholder Distribution and Access Controls Confirmed
Verification Criteria: Relevant policies or policy excerpts must be communicated to external interested parties (e.g., vendors, partners) who have access to organisational assets.
Required Evidence: Third-party contracts containing security policy appendices or evidence of policy distribution via a secure vendor portal.
Pass/Fail Test: If external consultants have system access but have not been provided with the relevant Acceptable Use Policy (AUP), mark as Non-Compliant.
9. Version Control and Distribution Integrity Maintained
Verification Criteria: Only the latest authorised version of any policy must be available for use, with obsolete versions archived and removed from circulation.
Required Evidence: Inspection of the document management system to ensure no “draft” or “deprecated” versions are visible to general users.
Pass/Fail Test: If an employee is found to be using an outdated version of a policy that lacks current control requirements, mark as Non-Compliant.
10. Continuous Policy Improvement Evidence Identified
Verification Criteria: The organisation must demonstrate that policies are updated based on feedback from internal audits, management reviews, or evolving threat landscapes.
Required Evidence: “Changelog” or “Version History” sections within policies detailing the rationale for specific updates made over the last two cycles.
Pass/Fail Test: If policy versions are incremented without any descriptive record of what was changed or why, mark as Non-Compliant.
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Management Approval | GRC tool shows a green tick because a file was uploaded to the “Policy” slot. | The auditor must verify the *authority* of the person who signed the document, not just the file’s presence. |
| Personnel Awareness | SaaS dashboard shows 100% “Policy Acknowledged” based on a single “Accept All” button click. | Verify through staff interviews if they actually understand the *content* of the policy they “clicked” to accept. |
| Review Frequency | The platform automatically updates the “Next Review Date” field to 365 days in the future. | Demand evidence of a *qualitative* review (minutes/notes) rather than just a metadata update in the GRC system. |
| Topic-Specific Detail | Using the “Default SaaS Template” which covers 20 policies in 5 pages. | Check if the policy provides enough technical detail to be actionable (e.g., specific password length vs “strong passwords”). |
| Version Control | The tool displays “Version 2.0” but has no record of what changed from Version 1.0. | A real auditor requires a clear “Summary of Changes” to ensure improvements were actually implemented. |
| External Communication | GRC tool assumes all policies are internal-only. | Verify how security requirements are communicated to suppliers who don’t have access to your GRC portal. |
| Contextual Alignment | The tool provides a “Standard Policy” that mentions AWS, but the company uses on-premise servers. | Identify “template leftovers” that prove the policy has not been tailored to the organisation’s actual tech stack. |
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