ISO 27001 A.5.35: independent security review, explained for startups
What A.5.35 asks of a small company, and what an auditor samples.
Have someone independent check your security approach at planned intervals. A fresh set of eyes catches gaps that internal teams may miss.
Why it exists: to have someone independent check that its security program works.
A.5.35 Independent review of information security
Someone independent checks the security program at planned intervals. What proves it: a dated independent review of the program or its controls, and what you did with the findings.
A certification auditor samples the most recent independent review or penetration test report and the actions taken on it. A file that usually does the job: a penetration test report, an external assessment report, or an independent audit report on your controls, with the tracked follow-up actions.
How to put it in place
Each step leaves a record, and the record is what the auditor samples rather than the step itself. Inside Polara, the control card for A.5.35 walks you through it in this order.
- Pick an independent reviewer: an external tester, an assessor, or an internal person outside the security team.
- Agree the scope and date, then record the findings and the actions you will take.
- Plan the next review, at least once a year.
No question in the readiness assessment covers A.5.35 directly, so the control card is its whole evidence path.
Policies, connectors and the SOC 2 overlap
In the ISO 27001 policy pack, the Information Security Policy covers A.5.35. An auditor reads the policy for the rule, then samples the records to see the rule was followed.
The same evidence counts toward SOC 2. The Trust Services criterion that cover this ground: CC4.1, control monitoring.
Organizational controls
A.5.35 is one of the 37 organizational controls in Annex A. How the company runs security: policies, roles, suppliers, incidents, continuity and legal duties. Most of these are written decisions and the records that show you follow them.
Nearby controls in the same theme:
- A.5.32, intellectual property
- A.5.33, protecting records
- A.5.34, personal data protection
- A.5.36, checking policy compliance
- A.5.37, written procedures
Before it: A.5.34, personal data protection. After it: A.5.36, checking policy compliance. Every control, by theme, is on the Annex A controls page.
Questions
What does ISO 27001 A.5.35 require?
What evidence does an auditor want for A.5.35?
Get ready for ISO 27001 certification.
The readiness assessment is free, with no payment and no card. ISO 27001 is part of Constellation, at $10,800 a year: everything in Orbit plus the management system, the policies, the evidence and the management review for ISO 27001, and your SOC 2 Type 2 audit is included in every contract year. You contract the certification body directly.
The internal audit is priced separately: Polara arranges it with an independent internal auditor from our partner network who works in the platform, and quotes it for your company.
Take the free assessmentPolara Labs is not a certification body. Certification audits are performed by independent accredited certification bodies.