An ISO 27001 audit provides valuable assurance that your Information Security Management System (ISMS) is functioning as intended, but it can also surface nonconformities that require action. Whether the audit is conducted internally or by a certifying body, handling these findings properly is crucial to maintaining your organization’s security posture and compliance. In this article, Boulay’s Risk Advisory team outlines a structured approach for identifying, addressing and learning from ISO 27001 audit nonconformities.
1. Understand the Nature and Severity of the Nonconformity
Nonconformities can range from minor documentation lapses to major gaps that threaten information security. Start by reviewing each finding carefully. Determine whether it’s:
- Minor (e.g., a missing policy reference or outdated risk assessment)
- Major (e.g., lack of evidence that controls are being followed or ineffective risk treatment)
Understanding the root cause and risk impact is essential for proper remediation.
2. Prioritize Root Cause Analysis
Avoid the temptation to treat symptoms. A solid root cause analysis (RCA) helps prevent repeat findings and demonstrates maturity in your ISMS. Use techniques such as:
- The “5 Whys”
- Fishbone diagrams
- Process walkthroughs with key stakeholders
Identify whether the issue stems from training, process design, tool limitations, lack of monitoring or management oversight.
3. Develop a Corrective Action Plan
Your corrective action plan (CAP) should be more than a quick fix; it should address the root cause and demonstrate sustained improvement over time. Include:
- Description of the nonconformity
- Root cause analysis summary
- Actions to correct the issue
- Timeline for completion
- Responsible owner
- Evidence of implementation
It’s helpful to align your CAP format with your audit body’s expectations to streamline follow-up reviews.
4. Implement, Monitor and Document
Execute your corrective actions and track progress. ISO 27001 auditors want to see that your plan is not only implemented but effective. Maintain a clear audit trail with:
- Updated policies or procedures
- Training records
- Tool or system changes
- Meeting minutes or review logs
If the issue is procedural, a management review or re-audit may be warranted to verify that the change has been effectively implemented and embedded.
5. Use Findings to Strengthen the ISMS
Nonconformities are an opportunity, not just a compliance task. Patterns of repeated findings often point to systemic gaps. Use audit results as part of your continual improvement cycle:
- Integrate them into your risk register
- Share lessons learned across departments
- Reassess related risks or controls
By taking a proactive approach, you transform audit feedback into a value-added benefit for the organization.
Connect with our ISO 27001 Professionals
Nonconformities can feel like setbacks, but with the right response, they’re a powerful driver of resilience and maturity. A thoughtful, structured approach shows auditors that your organization takes information security seriously—and reinforces your ISMS as a living, evolving framework. If you need guidance as you prepare for an ISO 27001 audit, Boulay’s Risk Advisory Team is here to help. To learn more about our ISO 27001 certification services, connect with us today.