ISO 27001 Annex A 5.11 Audit Checklist

ISO 27001 Annex A 5.11 Audit Checklist

Auditing ISO 27001 Annex A 5.11 validates the secure offboarding process to ensure all physical and digital assets are recovered from terminating employees. The audit confirms the Primary Implementation Requirement of cross-referencing returned hardware against the Asset Register and verifying data deletion. The Business Benefit is preventing data leakage and unauthorized access post-employment.

Use this pass/fail checklist to strictly validate compliance with ISO 27001 Annex A 5.11 (Return of Assets). For a detailed methodology on how to conduct the interviews and system tests required to generate this evidence, refer to our Annex A 5.11 Audit Guide.

1. Return of Assets Policy Formally Defined

  • Verification Criteria: A documented policy exists (often part of the Asset Management Policy) explicitly stating that all employees and contractors must return assets upon termination or contract change.
  • Required Evidence: The “Asset Management Policy” or “Acceptable Use Policy” (Version controlled and approved).
Pass/Fail Test: If the requirement to return assets is only “implied” or verbal and not written in a formal policy, mark as Non-Compliant.

2. Employment Contract Terms Verified

  • Verification Criteria: Standard employment contracts and contractor agreements contain specific clauses mandating the return of equipment and data deletion upon exit.
  • Required Evidence: A sample of 3 recent employment contracts (redacted PII) showing the “Return of Property” clause.
Pass/Fail Test: If the contract mentions “confidentiality” but fails to explicitly demand the physical return of hardware (laptops, keys), mark as Non-Compliant.

3. Exit Interview Asset Reconciliation Verified

  • Verification Criteria: The offboarding process includes a mandatory step where the leaver’s assigned assets (from the Asset Register) are cross-checked against what they are physically handing back.
  • Required Evidence: Completed “Leaver Checklists” for the last 3 terminated employees, signed by both HR/IT and the employee.
Pass/Fail Test: If the leaver form has a generic checkbox for “Assets Returned” but does not list the specific serial numbers returned, mark as Non-Compliant.

4. Hardware Return Log Validated

  • Verification Criteria: A log exists tracking the physical receipt of returned hardware, its condition, and its subsequent storage or re-assignment.
  • Required Evidence: The IT Asset Management (ITAM) log showing date of return, assessor name, and status (e.g., “Returned to Stock”).
Pass/Fail Test: If a laptop was returned 3 months ago but the Asset Register still lists it as “Assigned to [Leaver Name],” mark as Non-Compliant.

5. Data Retrieval from Personal Devices Confirmed

  • Verification Criteria: For BYOD environments, a process exists to confirm company data has been wiped from personal devices (e.g., email, Teams, files).
  • Required Evidence: Logs from the Mobile Device Management (MDM) system showing “Remote Wipe” or “Container Removal” commands executed on leavers’ devices.
Pass/Fail Test: If the organisation relies solely on the user’s verbal promise that they deleted the data without technical verification or a signed declaration, mark as Non-Compliant.

6. Access Rights Revocation Synchronised

  • Verification Criteria: The return of physical assets is synchronised with the revocation of logical access rights to prevent “zombie” accounts.
  • Required Evidence: Ticket logs showing that Active Directory/SaaS accounts were disabled before or on the final day of employment.
Pass/Fail Test: If an employee left on Friday but their VPN token was still active on Monday (allowing them to copy data), mark as Non-Compliant.

7. Intellectual Property & Knowledge Transfer Verified

  • Verification Criteria: Non-tangible assets (code repositories, admin passwords, documentation) are explicitly transferred back to the organisation.
  • Required Evidence: A “Handover Document” or ticket showing ownership transfer of Git repositories, cloud root keys, or critical project files.
Pass/Fail Test: If a developer leaves and their code is inaccessible because it was stored on a personal GitHub account or local drive, mark as Non-Compliant.

8. External Contractor Offboarding Verified

  • Verification Criteria: The return of assets process is applied equally to external contractors and third-party suppliers when their project ends.
  • Required Evidence: Offboarding records for a recent contractor showing the return of building passes, tokens, and hardware.
Pass/Fail Test: If a contractor retained a building access pass “in case they are needed later” without formal re-approval, mark as Non-Compliant.

9. Non-Return / Damage Procedure Evidence Present

  • Verification Criteria: A clear procedure exists for handling cases where assets are lost, damaged, or not returned (e.g., withholding salary, legal action).
  • Required Evidence: Documented “Asset Loss Incident Reports” or email correspondence from HR/Legal regarding unreturned items.
Pass/Fail Test: If an asset is missing and marked “Lost” in the register but no incident report or follow-up action exists, mark as Non-Compliant.

10. Secure Storage of Returned Assets

  • Verification Criteria: Returned assets are stored securely (wiped and locked away) pending re-issue or disposal, not left in open areas.
  • Required Evidence: Visual inspection of the secure storage area (e.g., locked IT cupboard) and evidence of disk wiping for re-stocked laptops.
Pass/Fail Test: If returned laptops are piled in an unlocked corridor or open office shelf accessible to visitors, mark as Non-Compliant.
ISO 27001 Annex A 5.11 SaaS / GRC Platform Failure Checklist
Control Requirement The “Checkbox Compliance” Trap The Reality Check
Asset Linking Tool has a button to “Offboard User.” Auditor must verify if clicking “Offboard” automatically flags all assigned hardware for return. Most tools just disable the user account but leave the laptop status as “Active.”
Granular Tracking Tool lists “Laptop” as a returned item. Auditor must check for Serial Numbers. If the system accepts a generic checkmark without validating which laptop was returned, it fails asset integrity.
SaaS License Reclaim Tool disables Single Sign-On (SSO). Auditor must check if the license was reclaimed. Often, the account is disabled, but the company continues paying for the Salesforce/Adobe seat for months.
BYOD Wiping Tool sends an email asking user to delete data. Auditor must look for MDM logs or API confirmations. An email request is not evidence; a “Wipe Successful” system log is.
Knowledge Transfer Tool reassigns “Ticket Owner” to manager. Auditor must check cloud Asset Ownership. Did the root ownership of the AWS account or Google Drive folders actually transfer, or are they now orphaned?
Timestamps Offboarding task marked “Complete.” Auditor must compare the Task Completion Date vs. Termination Date. If the task was completed 3 weeks after the employee left, the control failed.
Physical Receipt Digital signature on a PDF form. Auditor must verify the physical location. The form says “Returned,” but is the laptop actually in the secure cupboard, or is it missing?

About the author

Stuart Barker
🎓 MSc Security 🛡️ Lead Auditor 30+ Years Exp 🏢 Ex-GE Leader

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.

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