Module 9: Maintaining the Kingdom

Recertification

Worksheet
20 min
+75 XP

Recertification Preparation

Year 3—time for full recertification. Prove that three years of ISMS operation have created lasting value.

What is Recertification?

Full re-assessment audit at the end of your 3-year cycle.

Recertification vs Initial

AspectInitialRecertification
ScopeFull ISMSFull ISMS
Duration3-5 days3-5 days
FocusCan you do it?Have you been doing it?
EvidencePoint-in-time3 years of operation
MaturityNew systemProven track record
OutcomeFirst certificateNew certificate

What Auditors Look For

1. Continuous Operation

  • Three years of management reviews
  • Three years of internal audits
  • Ongoing risk assessment updates
  • Active corrective actions
  • Evolution and improvement

Questions:

  • "Show me reviews from all three years"
  • "How has risk profile changed?"
  • "What major improvements made?"
  • "How do you know ISMS is effective?"

2. ISMS Maturity

Maturity Levels:

  • Level 1: Ad hoc, reactive
  • Level 2: Processes defined
  • Level 3: Standardized (aim for this)
  • Level 4: Quantitatively managed
  • Level 5: Continuous improvement culture

Signs of Maturity:

  • Integrated into operations, not bolted on
  • Strong security culture
  • Optimized processes
  • Metrics drive decisions
  • Leadership genuinely engaged

3. Effectiveness of Controls

Proof controls actually work, not just exist.

Examples:

  • Incident response: Show detection and response
  • Access control: Regular reviews prevent unauthorized access
  • Vulnerability management: Trending over time
  • Training: Improved awareness (reduced phishing clicks)
  • Backup: Successful restoration tests

4. Non-Conformities Handling

From previous audits:

  • Were NCs corrected?
  • Root causes addressed?
  • Similar issues recurred?
  • What was learned?

From internal processes:

  • How identify NCs?
  • How tracked and resolved?
  • Closure rate?
  • Continuous improvement evidence?

5. Changes and Change Management

Over three years:

  • How has organization changed?
  • How has ISMS adapted?
  • How are changes managed?
  • ISMS part of change management?

Preparation Timeline

6-12 Months Before

  • Review certificate expiry
  • Assess ISMS maturity
  • Identify improvement areas
  • Budget for recertification
  • Check standard version (2013 vs 2022)

3-6 Months Before

  • Comprehensive doc review
  • Update all policies
  • Verify SoA accuracy
  • Update risk assessment
  • Compile 3 years of records

Key Records:

  • Management review minutes
  • Internal audit reports
  • Risk assessments
  • Training records
  • Incident logs
  • Corrective actions
  • Change management
  • Control evidence

2-3 Months Before

  • Comprehensive internal audit
  • Cover all scope areas
  • Test all controls
  • Document findings
  • Implement corrections
  • Verify effectiveness

6-8 Weeks Before

  • Comprehensive management review
  • 3-year performance summary
  • Assess effectiveness and maturity
  • Strategic decisions for next 3 years
  • Confirm resources
  • Renew executive commitment

4-6 Weeks Before

  • Confirm audit dates with CB
  • Arrange logistics
  • Provide updated docs
  • Schedule key personnel

2-4 Weeks Before

  • Brief all personnel
  • Readiness review
  • Organize evidence folders
  • Test system demos
  • Practice questions
  • Prepare workspace

1 Week Before

  • Final walkthrough
  • Test system access
  • Confirm availability
  • Print key documents
  • Mental preparation

The Recertification Audit

Stage 1: Documentation Review (1-2 Days)

  • Usually remote
  • Review doc package
  • Assess readiness
  • Identify gaps

Stage 2: Full Assessment (3-5 Days)

Day 1:

  • Opening meeting
  • Management interviews
  • Risk assessment review
  • Documentation review

Days 2-3:

  • All Annex A controls tested
  • Process walkthroughs
  • Employee interviews
  • System demonstrations
  • Evidence examination
  • 3-year record reviews

Final Day:

  • Closing meeting
  • Non-conformities (if any)
  • Opportunities for improvement
  • Recommendation
  • Next steps

Common Findings

  1. Stale Documentation - Not meaningfully updated
  2. Lack of Improvement - System unchanged in 3 years
  3. Ineffective Metrics - Data collected but not used
  4. Management Review Theater - Perfunctory, no real discussion
  5. Control Gaps - Never fully implemented or degraded
  6. Records Retention Issues - Can't produce Year 1-2 evidence

Decision Outcomes

  1. Recommended - New certificate issued (2-4 weeks)
  2. Minor NCs - Address within 90 days, then issued
  3. Major NCs - Correct issues, possible additional audit
  4. Not Recommended - Must re-apply (rare)

Post-Recertification

Immediate

  • Debrief with team
  • Celebrate success
  • Document lessons
  • Submit corrective actions
  • Update stakeholders

Next Three Years

Use Insights:

  • What feedback received?
  • What was harder than expected?
  • What improvements possible?
  • What to do differently?

Strategic Planning:

  • Set objectives for next 3 years
  • Plan major improvements
  • Allocate resources
  • Integrate lessons

Marketing

  • Update website (new certificate)
  • Update sales collateral
  • Customer communications
  • Celebrate internally

Readiness Self-Assessment

Rate 1-5 (5 = excellent):

Documentation (20%):

  • All policies reviewed (past 12 months)
  • SoA reflects control status
  • Risk assessment current
  • Procedures match practice

Evidence (30%):

  • 3 years management reviews
  • 3 years internal audits
  • All corrective actions closed
  • Control effectiveness evidence

Operations (25%):

  • ISMS integrated into daily ops
  • Staff aware of responsibilities
  • Processes followed consistently
  • Metrics drive improvement

Maturity (15%):

  • Visible security culture
  • Continuous improvement mindset
  • Leadership genuinely engaged
  • ISMS evolved and improved

Readiness (10%):

  • Team prepared and confident
  • Evidence organized
  • Logistics confirmed
  • Previous findings addressed

Scoring:

  • 90-100: Ready
  • 75-89: Minor improvements needed
  • 60-74: Some work needed
  • <60: Significant preparation required

Final Thought

Three years ago: You implemented ISMS to get certified. Today: Your ISMS is how you run your business securely.

That's the story to tell your auditor.

Next Lesson: Avoiding pitfalls that jeopardize certification.

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