The Challenge
The organisation had held ISO 27001 certification for approximately ten years, but the Information Security Management System (ISMS) had evolved organically over time. Documentation was largely aligned to the 2017 version of the standard, with limited structured review as requirements and business operations changed.
Midway through the certification cycle, it became clear that the ISMS required a comprehensive refresh to ensure continued compliance, relevance, and audit readiness — particularly ahead of a full three-year recertification audit.
Key challenges included:
– Out-of-date documentation aligned to the 2017 standard
– Accumulated legacy policies and procedures with unclear relevance
– Limited recent internal audit coverage
– Risk documentation that no longer fully reflected how the organisation operated
What We Found
Following an initial gap analysis, we identified that while the organisation had a mature ISMS in principle, it required consolidation and alignment to the ISO 27001:2022 standard.
Specific findings included:
– Policies and procedures that referenced superseded controls
– A Statement of Applicability (SoA) that required review and restructuring
– Risk assessments that needed stakeholder validation to ensure continued relevance
– Historic documentation retained without clear ownership or purpose
– An internal audit programme that needed refreshing to reflect current scope and risk
– The ISMS itself was sound, but needed active ownership, rationalisation, and evidence-led governance to withstand recertification scrutiny.
The Solution
We assumed responsibility as Fractional Information Security Manager, providing continuity and ownership through the remainder of the certification cycle.
Our work included:
– Conducting a structured ISO 27001:2022 gap analysis
– Updating existing documentation and creating new policies where required by the updated standard
– Reviewing and updating the Statement of Applicability
– Reviewing the risk register with stakeholders to confirm accuracy, relevance, and treatment decisions
– Auditing the full document set, archiving obsolete material, and clarifying document ownership
– Re-establishing and executing the internal audit programme, including updating the audit schedule
– Acting as the organisation’s ISM throughout the three-year UKAS-aligned recertification audit with British Assessment Bureau (BAB)
– Throughout the process, we worked closely with leadership and operational teams to ensure the ISMS reflected how the organisation actually operated, rather than becoming a paper exercise.
The Result
The organisation successfully completed its three-year ISO 27001 recertification audit with no major nonconformities, no minor nonconformities, and no observations or opportunities for improvement.
The outcome was:
– Continued UKAS-aligned ISO 27001 certification
– A streamlined, current, and defensible ISMS
– Clear ownership of policies, risks, and controls
– An internal audit programme aligned to real organisational risk
– Increased confidence in the ISMS as a living management system rather than static documentation