ISO 27001 Annex A 8.16 Monitoring Activities

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What is ISO 27001 Monitoring?

ISO 27001 Annex A 8.16 Monitoring is an ISO 27001 control that requires to check for inappropriate actions on networks, systems, applications and premises. It is about checking before the bad things happen to try to catch them.


ISO 27001 Annex A 8.16 is a detective control and corrective control to detect anomalous behaviour and potential information security incidents..


The ISO 27001 standard defines ISO 27001 Annex A 8.16 as:
Networks, systems and applications should be monitored for anomalous behaviour and appropriate actions taken to evaluate potential information security incidents.

ISO27001:2022 Annex A 8.16 Monitoring

Implementation Guide

Identify Requirements

Identify what requirements you have for monitoring so that you can understand what you need to implement.

This is going to be based on the risk assessments that you have conduct and the needs of the business and your clients.

Consider that we use monitoring to catch things either before or as they are happening and to support investigations if things do happen.

Topic Specific Policy

You will have a topic specific policy, the ISO 27001 Logging and Monitoring Policy that sets out what you do for logging and monitoring.

ISO 27001 Logging and Monitoring Policy Template

Monitoring Records

As with all logs and data you will need to define a data retention schedule for your monitoring records and put in place appropriate safeguards, protections and information security controls, as with any other data.

What to monitor

What you monitor is down to you and your identification of requirements but the standard provides some guidance on typical things that can be monitored being:

  • Traffic that is inbound and outbound
  • Access to resources
  • Critical configuration files
  • Security Tools Logs
  • Event Logs
  • Use of resource

Anomalous behaviour

Our monitoring is looking for behaviour outside the norm. Examples include:

  • Processes or applications that just stop, or restart
  • Malware traffic
  • Unusual system behaviour
  • Bottlenecks or spikes in resource usage
  • Unauthorised scans of systems and networks
  • Access attempts on restricted resources

Ensure You Meet the Laws

Monitoring is potentially dangerous when it comes to law and regulation, in that it can contain information and data protected by data protection laws and others. It is important to ensure that what you have and what you do complies. This is includes all steps of the process and lifecycle. It is recommended to get the advice of legal and data protection professionals in terms of your particular deployment.

Monitoring Tools

The use of monitoring tools is clearly recommended. Some of these are built into to systems and operating systems and some are off the shelf, dedicated solutions. It maybe that you have a hybrid of tools. They need to be able to handle large volumes of information and include real time notifications. Alerts should be configured and implemented and set against pre defined thresholds.

Monitoring is usually done be specialist software with examples being Host Intrusion Detection Systems (HIDS) or Network Intrusion Detection Systems (NIDS).


Staff will be trained to be able to use tools and interpret the information and appropriately respond. This can include the management of false positives, which do happen.

Continuous Monitoring

The standard advocates for continuous monitoring, in real time or at periodic intervals.

ISO 27001 Templates

ISO 27001 templates have the advantage of being a massive boost that can save time and money so before we get into the implementation guide we consider these pre written templates that will sky rocket your implementation. This ISO 27001 Toolkit has been specifically designed so you can DIY your ISO 27001 certification, build your ISMS in a week and be ISO 27001 certification ready in 30 days.


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ISO 27001 Toolkit Business Edition

How to comply

To comply with ISO 27001 Annex A 8.16 you are going to implement the ‘how’ to the ‘what’ the control is expecting.
In short measure you are going to:

  • Understand and record the legal, regulatory and contractual requirements you have for data
  • Conduct a risk assessment
  • Based on the legal, regulatory, contractual requirements and the risk assessment you will implement a monitoring solution
  • Implement a topic specific policy, the ISO 27001 Logging and Monitoring Policy
  • Document and implement your processes and technical implementations for monitoring
  • Check that the controls are working by conducting internal audits

What will an auditor check?

The audit is going to check a number of areas. Lets go through the main ones

That you have documentation

What this means is that you need to show that you have documented your legal, regulatory and contractual requirements for information and that you have taken this into account when building your monitoring solution. Where data protection laws exist that you have documented what those laws are and what those requirements are. That you have an information classification scheme and a topic specific policy for access control and that you have documented your monitoring taking all of this into account.

That you have have implemented monitoring appropriately

They will look at systems to seek evidence of monitoring. They want to see evidence of monitoring and the process in operation that includes the analysis of the monitoring data and what you do as a result of that analysis. In addition the use of cloud services and the cloud providers monitoring and monitoring capabilities will be reviewed.

That you have conducted internal audits

The audit will want to see that you have tested the controls and evidenced that they are operating. This is usually in the form of the required internal audits. They will check the records and outputs of those internal audits.

Top 3 Mistakes People Make

In my experience, the top 3 mistakes people make for ISO 27001 Annex A 8.16 monitoring are

You collect too much

Collecting too much data and logging everything is a common mistake we see. That in conjunction with storing all logs for ever. It is easy to be overwhelmed with information so it is important to work out what you are going to log and why. Then to be sure that the information is valuable, can be analysed and that analysis is actionable.

This is a massive mistake that we see, where people assume ISO 27001 is just information security and forget that it also checks that appropriate laws are being followed, and in particular data protection laws. Cost saving by not having a data protection expert or ignoring data protection law entirely is a common mistake we see people make when cutting corners and saving costs. Monitoring and in particular personal information, can get you in a lot of hot water depending how you implement it.

Your document and version control is wrong

Keeping your document version control up to date, making sure that version numbers match where used, having a review evidenced in the last 12 months, having documents that have no comments in are all good practices.

ISO 27001:2022 requirements

Organisational Controls - A5

ISO 27001 Annex A 5.1 Policies for information security

ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities

ISO 27001 Annex A 5.3 Segregation of duties

ISO 27001 Annex A 5.4 Management responsibilities

ISO 27001 Annex A 5.5 Contact with authorities

ISO 27001 Annex A 5.6 Contact with special interest groups

ISO 27001 Annex A 5.7 Threat intelligence – new

ISO 27001 Annex A 5.8 Information security in project management

ISO 27001 Annex A 5.9 Inventory of information and other associated assets – change

ISO 27001 Annex A 5.10 Acceptable use of information and other associated assets – change

ISO 27001 Annex A 5.11 Return of assets

ISO 27001 Annex A 5.11 Return of assets

ISO 27001 Annex A 5.13 Labelling of information

ISO 27001 Annex A 5.14 Information transfer

ISO 27001 Annex A 5.15 Access control

ISO 27001 Annex A 5.16 Identity management

ISO 27001 Annex A 5.17 Authentication information – new

ISO 27001 Annex A 5.18 Access rights – change

ISO 27001 Annex A 5.19 Information security in supplier relationships

ISO 27001 Annex A 5.20 Addressing information security within supplier agreements

ISO 27001 Annex A 5.21 Managing information security in the ICT supply chain – new

ISO 27001 Annex A 5.22 Monitoring, review and change management of supplier services – change

ISO 27001 Annex A 5.23 Information security for use of cloud services – new

ISO 27001 Annex A 5.24 Information security incident management planning and preparation – change

ISO 27001 Annex A 5.25 Assessment and decision on information security events 

ISO 27001 Annex A 5.26 Response to information security incidents

ISO 27001 Annex A 5.27 Learning from information security incidents

ISO 27001 Annex A 5.28 Collection of evidence

ISO 27001 Annex A 5.29 Information security during disruption – change

ISO 27001 Annex A 5.31 Identification of legal, statutory, regulatory and contractual requirements

ISO 27001 Annex A 5.32 Intellectual property rights

ISO 27001 Annex A 5.33 Protection of records

ISO 27001 Annex A 5.34 Privacy and protection of PII

ISO 27001 Annex A 5.35 Independent review of information security

ISO 27001 Annex A 5.36 Compliance with policies and standards for information security

ISO 27001 Annex A 5.37 Documented operating procedures 

Technology Controls - A8

ISO 27001 Annex A 8.1 User Endpoint Devices

ISO 27001 Annex A 8.2 Privileged Access Rights

ISO 27001 Annex A 8.3 Information Access Restriction

ISO 27001 Annex A 8.4 Access To Source Code

ISO 27001 Annex A 8.5 Secure Authentication

ISO 27001 Annex A 8.6 Capacity Management

ISO 27001 Annex A 8.7 Protection Against Malware

ISO 27001 Annex A 8.8 Management of Technical Vulnerabilities

ISO 27001 Annex A 8.9 Configuration Management 

ISO 27001 Annex A 8.10 Information Deletion

ISO 27001 Annex A 8.11 Data Masking

ISO 27001 Annex A 8.12 Data Leakage Prevention

ISO 27001 Annex A 8.13 Information Backup

ISO 27001 Annex A 8.14 Redundancy of Information Processing Facilities

ISO 27001 Annex A 8.15 Logging

ISO 27001 Annex A 8.16 Monitoring Activities

ISO 27001 Annex A 8.17 Clock Synchronisation

ISO 27001 Annex A 8.18 Use of Privileged Utility Programs

ISO 27001 Annex A 8.19 Installation of Software on Operational Systems

ISO 27001 Annex A 8.20 Network Security

ISO 27001 Annex A 8.21 Security of Network Services

ISO 27001 Annex A 8.22 Segregation of Networks

ISO 27001 Annex A 8.23 Web Filtering

ISO 27001 Annex A 8.24 Use of CryptographyISO27001 Annex A 8.25 Secure Development Life Cycle

ISO 27001 Annex A 8.26 Application Security Requirements

ISO 27001 Annex A 8.27 Secure Systems Architecture and Engineering Principles

ISO 27001 Annex A 8.28 Secure Coding

ISO 27001 Annex A 8.29 Security Testing in Development and Acceptance

ISO 27001 Annex A 8.30 Outsourced Development

ISO 27001 Annex A 8.31 Separation of Development, Test and Production Environments

ISO 27001 Annex A 8.32 Change Management

ISO 27001 Annex A 8.33 Test Information

ISO 27001 Annex A 8.34 Protection of information systems during audit testing