ISO 27701 program audit checklist

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When preparing for an ISO 27701 audit, organizations must ensure they have a comprehensive understanding of the requirements and how they apply to their Privacy Information Management Systems (PIMS). This is where a well-structured ISO 27701 program audit checklist becomes an invaluable tool.

A downloadable checklist, provided by TrustCloud, can streamline the audit process, enabling organizations to systematically verify the implementation and effectiveness of their privacy controls. An ISO 27701 audit checklist typically covers the privacy-specific requirements and controls that extend the ISO 27001 and ISO 27002 standards for information security management. It helps organizations assess their readiness for certification and identify any areas that require attention.

The checklist can be used as a guide to evaluate the scope of the PIMS, the processing of Personally Identifiable Information (PII), and the integration of data protection into the overall Information Security Management System (ISMS). Incorporating a downloadable checklist from a reputable source like TrustCloud not only ensures that you are using a tool aligned with the ISO 27701 standards but also provides a structured approach to your internal audit process.

These checklists often come with guidance notes on how to interpret and apply each control, making it easier for organizations to understand the requirements and how they apply to their specific context.

Furthermore, utilizing checklists aids in maintaining an evidence-based audit trail, which is crucial for demonstrating compliance during external audits. It is advisable that organizations thoroughly review each item on the ISO 27701 program audit checklist, document their findings, and take corrective actions where necessary to ensure they meet the stringent requirements of this international standard for privacy information management.

The ISO 27701 program audit checklist is a simplified checklist to follow and move forward with your audit preparation. You can download a copy of the checklist at the end of this article.

Read more about “ISO 27701 Overview and Guides.”

ISO 27701 program Audit Checklist

Learn more about TrustCloud’s continuous ISO 27001 compliance with TrustOps for ISO 27001.

ISO 27701 program audit checklist

ISO 27701 CHECKLIST

1 – SCOPE
☐ Identify the people, processes, and technology that support your business.

       ☐ Have you identified the relevant stakeholders needs for your product/service?

       ☐Have you identified the most relevant laws and regulations relevant to your product/service?

       ☐ Have you identified a critical physical location relevant for your product/service?

2 – STAGES
☐ Identify the people, processes, technology, stakeholder needs, applicable legislation, and location that support your          business. Both stages are performed during an ISO 27701 audit.

       ☐ Stage 1 if you were asked to demonstrate the design and execution of controls?

       ☐ Stage 2 if you were asked to demonstrate operating effectiveness of controls over a period of time?

3 – GAP ANALYSIS
☐ Identify your current documentation posture.

       ☐ Have you specified and properly documented the activities and procedures that make up your company’s control environment?

       ☐ Do you review documents on a regular basis to make sure they are up to date and accurate?

       ☐ Do you have your Information Security Management System (ISMS) policy documented?

      ☐ Do you have your Privacy Management System (PIMS) policy documented?

      ☐ Do you have an updated and accurate list of your subprocessors?

      ☐ Do you have your data processing agreement updated and documented?

☐ Identify your current control environment posture.

       ☐ What is the organization’s governance structure?

       ☐ What is the tone and example of executive leadership and management?

       ☐ Have you designed and implemented hiring and exit procedures?

       ☐ How are personnel who are implementing or directing internal controls evaluated for competency?

       ☐ Are possible threats being identified?

       ☐ Have you put any mitigating plans in place?

       ☐ Do you have a protocol for dealing with incidents and a disaster recovery plan in place?

       ☐ What kind of management supervision and governance do you have in place for your

control the environment and report events, security problems, and fraud?

       ☐ Have you established a Management Review Committee to discuss ISMS-PIMS specific topics?

☐ Identify your current security environment posture.

       ☐ Do you have access limited to positions that need it, with the appropriateness of the access being reviewed on a regular basis?

       ☐ Do you have policies in place for giving and taking away access from workers, customers, and other parties?

       ☐ Do you encrypt data while it’s in transit and while it’s at rest?

       ☐ Do you impose restrictions on administrative access to the technological stack?

☐ Identify your current risk mitigation environment posture.

       ☐ Have you conducted vulnerability assessments or penetration testing on a regular basis to detect weaknesses in your environment?

       ☐ Do you have backup processes in place?

       ☐ Do you test your disaster recovery procedures on a yearly basis to guarantee that you can restart operations in case of a calamity?

       ☐ Do you regularly check for intrusion attempts, system performance, and availability?

☐ Identify your current system changes environment posture.

       ☐ Are system modifications tested and authorized before they are implemented?

       ☐ Do you inform your employees about system changes?

       ☐ Are your controls being monitored on a regular basis?

       ☐ Have you enabled notification of settings changes?

       ☐ Is your technology up to date in terms of upgrades?

       ☐ Do you have a system in place for separating development and production tasks?

☐ Identify your current posture in a remote working environment.

       ☐ Is technology being used uniformly across all employee locations?

       ☐ Is time synchronization enabled on all employees workstations and software?

       ☐ Do you provide staff with regular security awareness training, address data privacy in common spaces, use secure connections while working from home, and raise awareness of phishing attempts?

       ☐ Do you use multifactor authentication to get into your company’s network and other systems?

       ☐ Have you deployed mobile device management to make sure that mobile devices are encrypted and authenticated?

4 – CONTROL IMPLEMENTATION
☐ Design the controls to address your gaps.

☐ Implement controls to address your gaps.

☐ Test the controls to ensure that they are operating effectively.

5 – STATEMENT OF APPLICABILITY (SOA)
☐ Document all your clause controls in an SOA (ISMS and PIMS).

☐ Document all your Annex A controls in an SOA (ISMS and PIMS).

☐ Document any non-applicability (i.e Physical Security).

6- INTERNAL AUDIT
☐ Identify an internal auditor.

☐ Grant them access to TrustCloud.

7 – AUDIT READY
☐ Identify the auditor.

☐ Initiate kickoff to set expectations.

☐ Grant them access to TrustCloud.

8 – MAINTENANCE
☐ Maintain the program to show continuous compliance via TC integrations.

☐ Perform surveillance audits every year.

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Download ISO 27701 Checklist (docx)

Download ISO 27701 Checklist (pdf)

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