Auditing ISO 27001 Clause 7.1 verifies that the organisation has determined and provided the resources needed for the establishment, implementation, maintenance, and continual improvement of the ISMS. The audit confirms the Primary Implementation Requirement of allocating adequate financial, human, and technical resources to manage information security risks effectively. The Business Benefit is assurance that the security strategy is sustainable and supported by tangible investment.
Use this pass/fail checklist to strictly validate compliance with ISO 27001 Clause 7.1 (Resources). For a detailed methodology on how to conduct the interviews and system tests required to generate this evidence, refer to our Clause 7.1 Audit Guide.
1. Resource Identification Process Verified
- Verification Criteria: A documented methodology exists to identify the resources (financial, human, technical) required to implement and maintain the ISMS based on risk.
- Required Evidence: Management Review minutes or a Business Case document where resource needs were explicitly discussed and defined.
Pass/Fail Test: If the organization cannot show how they calculated the security budget (e.g., it was just “copied from last year”), mark as Non-Compliant.
2. Competence & Skills Matrix Validated
- Verification Criteria: The organization has determined the necessary competence for people doing work under its control and verified they possess these skills.
- Required Evidence: A “Skills Matrix” or “Competency Framework” mapping ISMS roles (e.g., CISO, Admin) to required certifications or experience.
Pass/Fail Test: If the “Security Manager” role requires a CISM certification but the current holder has no qualifications or relevant experience, mark as Non-Compliant.
3. Infrastructure Capacity Provision Confirmed
- Verification Criteria: Adequate infrastructure (servers, networks, secure facilities) is provided to support the ISMS objectives.
- Required Evidence: Capacity planning reports or infrastructure purchase orders showing investment in required hardware/software.
Pass/Fail Test: If the security team complains of “server lag” preventing log analysis and no budget request was approved to fix it, mark as Non-Compliant.
4. Financial Budget Allocation Verified
- Verification Criteria: A dedicated budget for information security is formally approved and is sufficient to cover identified risks.
- Required Evidence: The approved Annual Budget showing specific line items for “Information Security” (tools, training, audits).
Pass/Fail Test: If the CISO has a risk treatment plan requiring a $50k firewall but the approved budget is $0, mark as Non-Compliant.
5. Top Management Support Evidence Present
- Verification Criteria: Senior management actively demonstrates support by providing the requested resources rather than just signing a policy.
- Required Evidence: Email correspondence or meeting minutes where Leadership approves a resource request to address a non-conformity.
Pass/Fail Test: If a critical resource gap (e.g., lack of staff) has been raised in Management Reviews for 2 years with no action, mark as Non-Compliant.
6. Resource Maintenance & Upkeep Verified
- Verification Criteria: Resources are maintained over time (e.g., software subscriptions renewed, hardware refreshed), not just purchased once.
- Required Evidence: Asset lifecycle logs or a “Renewals Calendar” showing active maintenance contracts for security tools.
Pass/Fail Test: If the core SIEM tool license expired 3 months ago and hasn’t been renewed due to “lack of funds,” mark as Non-Compliant.
7. Outsourced Resource Management Verified
- Verification Criteria: Where resources are outsourced (e.g., MSSP, Consultants), the organization retains control and monitors their performance.
- Required Evidence: Service Level Agreements (SLAs) and monthly performance review meetings with third-party providers.
Pass/Fail Test: If the organization relies entirely on an external MSP but has never audited their performance or checked if they are delivering, mark as Non-Compliant.
8. Documentation of Resource Allocation
- Verification Criteria: The allocation of resources is recorded (e.g., who is responsible for what), ensuring no ambiguity in duties.
- Required Evidence: An “Accountability Matrix” (RACI) or Organizational Chart with clear security reporting lines.
Pass/Fail Test: If the Incident Response plan lists “Security Analyst” as the lead, but no one in the company actually holds that job title, mark as Non-Compliant.
9. Regular Resource Adequacy Review Confirmed
- Verification Criteria: The sufficiency of resources is reviewed at planned intervals (at least annually) during Management Review.
- Required Evidence: Minutes from the Annual Management Review meeting specifically answering the agenda item: “Are resources adequate?”
Pass/Fail Test: If the meeting minutes are silent on resources or simply say “Yes” without data to back it up, mark as Non-Compliant.
10. Continual Improvement of Resource Use Verified
- Verification Criteria: The organization looks for ways to optimize resource use (e.g., automation) to improve ISMS efficiency.
- Required Evidence: Project plans showing automation of manual tasks (e.g., automated patching) to free up human resources.
Pass/Fail Test: If the security team is drowning in manual log reviews and management has rejected all requests for automation tools, mark as Non-Compliant.
| Control Requirement | The “Checkbox Compliance” Trap | The Reality Check |
|---|---|---|
| Competency Tracking | Tool lists “Users” but not their qualifications. | Auditor must check for a Skills Module. Does the tool store the CISO’s certificates? If it just lists names without proving competence, it fails Clause 7.2/7.1. |
| Budget Management | Tool has no field for financial data. | Auditor must verify Budget linkage. Can you attach a PO or budget approval to a Risk Treatment? Most GRC tools isolate risk from money, making Clause 7.1 hard to prove. |
| Resource Capacity | Tool assigns 100 tasks to one person. | Auditor must check Workload Analysis. If the tool allows assigning 500 hours of work to a single “Security Officer” in one month, it proves resources are inadequate. |
| Outsourced Oversight | Tool lists MSP as a “User.” | Auditor must check for SLA Monitoring. Does the tool track if the MSP met their 24/7 monitoring SLA? Simply giving them a login is not “managing” the resource. |
| Asset Availability | Tool inventory lists laptops but not status. | Auditor must verify Lifecycle Status. Does the tool show which assets are “End of Life”? Reliance on obsolete hardware is a failure to provide adequate infrastructure resources. |