ISO-IEC-27001-LEAD-AUDITOR practice question 4 of 35

Scenario 6: Sinvestment is an insurance company that offers home, commercial, and life insurance. The company was founded in North Carolina, but have…

Full set: 368 questions
Scenario 6: Sinvestment is an insurance company that offers home, commercial, and life insurance. The company was founded in North Carolina, but have recently expanded in other locations, including Europe and Africa. Sinvestment is committed to complying with laws and regulations applicable to their industry and preventing any information security incident. They have implemented an ISMS based on ISO/IEC 27001 and have applied for ISO/IEC 27001 certification. Two auditors were assigned by the certification body to conduct the audit. After signing a confidentiality agreement with Sinvestment. they started the audit activities. First, they reviewed the documentation required by the standard, including the declaration of the ISMS scope, information security policies, and internal audits reports. The review process was not easy because, although Sinvestment stated that they had a documentation procedure in place, not all documents had the same format. Then, the audit team conducted several interviews with Sinvestment's top management to understand their role in the ISMS implementation. All activities of the stage 1 audit were performed remotely, except the review of documented information, which took place on-site, as requested by Sinvestment. During this stage, the auditors found out that there was no documentation related to information security training and awareness program. When asked, Sinvestment's representatives stated that the company has provided information security training sessions to all employees. Stage 1 audit gave the audit team a general understanding of Sinvestment's operations and ISMS. The stage 2 audit was conducted three weeks after stage 1 audit. The audit team observed that the marketing department (which was not included in the audit scope) had no procedures in place to control employees’ access rights. Since controlling employees' access rights is one of the ISO/IEC 27001 requirements and was included in the information security policy of the company, the issue was included in the audit report. In addition, during stage 2 audit, the audit team observed that Sinvestment did not record logs of user activities. The procedures of the company stated that "Logs recording user activities should be retained and regularly reviewed," yet the company did not present any evidence of the implementation of such procedure. During all audit activities, the auditors used observation, interviews, documented information review, analysis, and technical verification to collect information and evidence. All the audit findings during stages 1 and 2 were analyzed and the audit team decided to issue a positive recommendation for certification. According to scenario 6, the marketing department employees were not following the access control policy. Which option is correct in this case?
Answer options
A: The marketing department is not included in the audit scope, so the issue should only be communicated to Sinvestment's representatives
B: The employees' access right control is included in Sinvestment’s information security policy, so the issue must be communicated to Sinvestment's representatives and included in the audit report Correct answer
C: Sinvestment is not controlling the employees' access rights, which represents a potential information security risk and should be reported as a major nonconformity
Correct Answer:
B. The employees' access right control is included in Sinvestment’s information security policy, so the issue must be communicated to Sinvestment's representatives and included in the audit report
Explanation

Even though the marketing department is outside the defined ISMS scope, it is still part of the organization which is governed by the overall information security policy. The policy itself is a core component of the ISMS and is in scope. A failure to adhere to the policy in any part of the organization can indicate a systemic weakness in policy communication, enforcement, or governance. This weakness represents a potential risk to the in-scope assets and processes. Therefore, it is a valid audit finding that must be communicated and included in the audit report for management's attention.

Why Incorrect

A. This is insufficient. While the finding should be communicated, its inclusion in the report is necessary because it reflects on the overall effectiveness of the ISMS policy's implementation.
C. This is an overstatement. A major nonconformity implies a systemic ISMS failure. An issue in an out-of-scope department is more likely a minor nonconformity or an observation, not a major one.

References

1. ISO/IEC 27001:2022, Information security, cybersecurity and privacy protection — Information security management systems — Requirements. Clause 5.2 requires top management to establish an information security policy that is communicated within the organization. An auditor must verify its effective implementation.

2. ISO/IEC 17021-1:2015, Conformity assessment — Requirements for bodies providing audit and certification of management systems — Part 1: Requirements. Clause 9.5.3.2 states the audit report shall provide a record of the audit, including all audit findings.

3. Calder, A., & Watkins, S. (2019). IT Governance: An International Guide to Data Security and ISO 27001/ISO 27002 (7th ed.). Kogan Page Publishers. Chapter 14 discusses the audit process, noting that auditors look for evidence of policy implementation across the organization.

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