ISO/IEC 27001:2022 A.5.35 — Independent review of information security

What this control requires

The organization's approach to managing information security and its implementation including people, processes and technologies shall be reviewed independently at planned intervals, or when significant changes occur.

In plain English

The organization's approach to managing information security and its implementation including people, processes and technologies shall be reviewed independently at planned intervals, or when significant changes occur. In practice, this means you can prove you policy information security-level controls on a defined cadence.

Why it matters

ISO 27001 certification depends on showing each Annex A control is either implemented or explicitly justified for exclusion in the Statement of Applicability (SoA). Certification bodies sample controls during surveillance audits, and a missing SoA entry — or implementation that doesn't match the SoA wording — is a finding.

What an auditor looks for

An ISO 27001 lead auditor looks for: (1) an SoA entry covering the control with justification, (2) a documented procedure or policy implementing it, (3) records that prove the procedure runs (logs, tickets, training records) and (4) management-review evidence that effectiveness is monitored.

Within Organizational controls, the assessor will trace your implementation back to the catalogue reference (Annex A A.5.35) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Policy. Document the trigger, the owner and the cadence.
• Information. Document the trigger, the owner and the cadence.
• Management. Document the trigger, the owner and the cadence.
• Independent Review. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Scope: information security, management, people, when significant changes occur.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Signed policy or standard documents the safeguard. Focus: Independent review of information security.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
• ISO/IEC 27701:2025 A.3.3 — Information security policies
• BSI C5:2020 SP-02 — Review and Approval of Policies and Instructions
• SOC 2 (2017 TSC) C1.2 — Confidential Information Disposal
• NIST SP 800-171 Rev. 3 3.12.1 — Security Assessment

Related controls in ISO/IEC 27001:2022

• Annex A A.5.1 — Policies for information security
• Annex A A.5.4 — Management responsibilities
• Annex A A.5.12 — Classification of information
• Annex A A.5.29 — Information security during disruption
• Annex A A.5.31 — Legal, statutory, regulatory and contractual requirements
• Annex A A.5.36 — Compliance with policies, rules and standards for information security

References

• ISO/IEC JTC 1/SC 27 — ISO/IEC 27001:2022
• Catalogue identifier: Annex A A.5.35

Topics: governance riskpolicy management