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 ISO/IEC 27001 requirements, does the company need to provide evidence of implementation of the procedure regarding logs recording user activities? Refer to scenario 6.
