Auditing ISO 27001 Annex A.5.10 verifies that an organisation has established and enforced rules for the acceptable use of information and associated assets. The audit confirms the Primary Implementation Requirement of a formally documented and user-accepted Acceptable Use Policy (AUP). The Business Benefit is the reduction of human error, insider threats, and legal liability stemming from misuse.
Use this pass/fail checklist to strictly validate compliance with ISO 27001 Annex A 5.10 (Acceptable use of information and other associated assets). For a detailed methodology on how to conduct the interviews and system tests required to generate this evidence, refer to our Annex A 5.10 Audit Guide.
1. Acceptable Use Policy (AUP) Formally Documented
- Verification Criteria: A specific “Acceptable Use Policy” (or equivalent section in the IT Security Policy) exists, is written in clear language, and bears a recent approval date from senior management.
- Required Evidence: The Master Policy Document with a “Document Control” table showing approval within the last 12 months.
Pass/Fail Test: If the rules exist only in an email chain, intranet post, or verbal “common knowledge” rather than a formal controlled document, mark as Non-Compliant.
2. “Prohibited Behaviours” Explicitly Defined
- Verification Criteria: The policy explicitly lists specific banned activities (e.g., “installation of pirated software,” “running a personal business,” “sharing passwords”) rather than vague statements like “be secure.”
- Required Evidence: The specific “Unacceptable Use” section of the AUP containing a bulleted list of banned actions.
Pass/Fail Test: If the policy lists what users should do but fails to explicitly list what they must not do, mark as Non-Compliant.
3. Monitoring & Privacy Expectations Clarified
- Verification Criteria: The policy contains a clear clause stating that the organisation reserves the right to monitor systems and that users should have no expectation of privacy on corporate devices.
- Required Evidence: The “Monitoring and Privacy” clause within the AUP.
Pass/Fail Test: If the policy is silent on monitoring, creating a legal ambiguity regarding the organisation’s right to inspect logs during an incident, mark as Non-Compliant.
4. User Acceptance Actively Logged
- Verification Criteria: Evidence exists that 100% of active users have affirmatively accepted the current version of the policy.
- Required Evidence: A report from the HR/GRC system showing “Date Accepted” and “Version ID” for a random sample of 5 employees (including one new starter).
Pass/Fail Test: If you find a signed form for Version 1.0 but the current policy is Version 3.0, mark as Non-Compliant.
5. Cloud & Shadow IT Usage Addressed
- Verification Criteria: The policy explicitly covers the use of non-corporate assets (BYOD) and third-party cloud services (SaaS), setting rules for “Shadow IT.”
- Required Evidence: A section in the AUP or a separate “Cloud Usage Policy” referencing unauthorised cloud storage (e.g., “Do not upload corporate data to personal Dropbox”).
Pass/Fail Test: If the policy only mentions “Company Computers” and ignores mobile devices or cloud apps, mark as Non-Compliant.
6. Information Transfer Rules Defined
- Verification Criteria: Clear procedures are documented for how information should be securely transferred (e.g., “Use encrypted email for PII,” “Do not use WhatsApp for business”).
- Required Evidence: The “Information Transfer” procedure or specific AUP clauses regarding file sharing and instant messaging.
Pass/Fail Test: If users are sending sensitive data via unapproved tools (e.g., WeTransfer, personal email) because the policy doesn’t ban it, mark as Non-Compliant.
7. Remote Work & Physical Security Included
- Verification Criteria: The AUP includes specific requirements for physical security when working remotely (e.g., “Lock screen when away,” “Do not work on sensitive documents in public view”).
- Required Evidence: The “Remote Working” or “Clear Desk/Clear Screen” section of the policy.
Pass/Fail Test: If the policy fails to address risks specific to home working or public Wi-Fi usage, mark as Non-Compliant.
8. Return of Assets Obligation Stated
- Verification Criteria: The policy clearly states the obligation to return all assets and delete data from personal devices upon termination of employment.
- Required Evidence: A “Termination of Access” or “Return of Assets” clause in the AUP (linking to Annex A 5.11).
Pass/Fail Test: If the policy does not explicitly state that intellectual property created on personal devices belongs to the company, mark as Non-Compliant.
9. Reporting Procedures for Security Events
- Verification Criteria: The policy mandates that users must report suspected security weaknesses or incidents immediately and provides the contact channel.
- Required Evidence: The “Incident Reporting” section providing a specific email address, phone number, or portal for reporting.
Pass/Fail Test: If the policy says “Report incidents” but doesn’t say who to report them to, mark as Non-Compliant.
10. Lifecycle Management of the Policy Verified
- Verification Criteria: The AUP itself is subject to regular review and updates to reflect changing technology (e.g., AI usage).
- Required Evidence: Version history showing a review or update within the last 12 months, specifically checking for modern risks (e.g., “ChatGPT/Generative AI usage”).
Pass/Fail Test: If the policy was last updated in 2019 and fails to mention modern collaboration tools (Teams/Slack) or AI, mark as Non-Compliant.
| Control Requirement | The “Checkbox Compliance” Trap | The Reality Check |
|---|---|---|
| Active Acceptance | Tool sends a mass email with a “Read This” link. | Auditor must verify logs of interaction. Did the user actually click “I Accept”? Email open rates are not proof of agreement. |
| Version Sync | Tool updates the policy PDF but doesn’t reset acceptance status. | Auditor must check if users were forced to re-accept the new version. If users are “compliant” based on a signature from 3 years ago, the tool failed. |
| Onboarding Gating | Policy is available in the “Company Handbook” folder. | Auditor must verify if system access is gated by acceptance. Can a new user log in to Salesforce before signing the AUP? If yes, the control is weak. |
| Shadow IT Discovery | Tool lists “Approved Software” only. | Auditor must ask how the tool handles unknown apps. Does it scan for browser extensions or unauthorized SaaS logins? If it relies on manual entry, it misses Shadow IT. |
| Mobile Enforcement | Policy mentions BYOD rules textually. | Auditor must check for MDM profiles. Does the tool actually enforce the “PIN Code” or “Encryption” rule on the phone, or is it just a written request? |
| Quiz/Comprehension | User scrolls to bottom and clicks “Accept” in 2 seconds. | Auditor must check for time-spent logs or comprehension quizzes. “Click-through fatigue” invalidates the legal standing of the AUP. |
| Contractor Coverage | Tool manages “Employees” (Active Directory). | Auditor must verify external users. Are contractors and freelancers in the GRC tool? Often they are excluded, leaving a huge compliance gap. |