According to ISO/IEC 17021-1:2015, which specifies the requirements for bodies providing audit and certification of management systems, clause 9.4.9 requires the certification body to make a certification decision based on the information obtained during the audit and any other relevant information1. The certification body should also consider the effectiveness of the corrective actions taken by the auditee to address any nonconformities identified during the audit1. Therefore, when making a recommendation to the audit programme manager, an ISMS auditor should consider the nature and severity of the nonconformities and the proposed corrective actions.
Based on the scenario above, the auditor should recommend certification after their approval of the proposed corrective action plan and recommend that the findings can be closed out at a surveillance audit in 1 year. The auditor should provide the following justification for their recommendation:
Justification: This recommendation is appropriate because it reflects the fact that the auditee has only two minor nonconformities and one opportunity for improvement, which do not indicate a significant or systemic failure of their ISMS. A minor nonconformity is defined as a failure to achieve one or more requirements of ISO/IEC 27001:2022 or a situation which raises significant doubt about the ability of an ISMS process to achieve its intended output, but does not affect its overall effectiveness or conformity2. An opportunity for improvement is defined as a suggestion for improvement beyond what is required by ISO/IEC 27001:20222. Therefore, these findings do not prevent or preclude certification, as long as they are addressed by appropriate corrective actions within a reasonable time frame. The auditor should approve the proposed corrective action plan before recommending certification, to ensure that it is realistic, achievable, and effective. The auditor should also recommend that the findings can be closed out at a surveillance audit in 1 year, to verify that the corrective actions have been implemented and are working as intended.
The other options are not valid recommendations for the audit programme manager, as they are either too lenient or too strict for the given scenario. For example:
Recommend certification immediately: This option is not valid because it implies that the auditor ignores or accepts the nonconformities, which is contrary to the audit principles and objectives of ISO 19011:20182, which provides guidelines for auditing management systems. It also contradicts the requirement of ISO/IEC 17021-1:20151, which requires the certification body to consider the effectiveness of the corrective actions taken by the auditee before making a certification decision.
Recommend that a full scope re-audit is required within 6 months: This option is not valid because it implies that the auditor overreacts or exaggerates the nonconformities, which is contrary to the audit principles and objectives of ISO 19011:20182. It also contradicts the requirement of ISO/IEC 17021-1:20151, which requires the certification body to determine whether a re-audit is necessary based on the nature and extent of nonconformities and other relevant factors. A full scope re-audit is usually reserved for major nonconformities or multiple minor nonconformities that indicate a serious or widespread failure of an ISMS.
Recommend that an unannounced audit is carried out at a future date: This option is not valid because it implies that the auditor distrusts or doubts the auditee’s commitment or capability to implement corrective actions, which is contrary to the audit principles and objectives of ISO 19011:20182. It also contradicts the requirement of ISO/IEC 17021-1:20151, which requires the certification body to conduct unannounced audits only under certain conditions, such as when there are indications of serious problems with an ISMS or when required by sector-specific schemes.
Recommend that a partial audit is required within 3 months: This option is not valid because it implies that the auditor imposes or prescribes a specific time frame or scope for verifying corrective actions, which is contrary to the audit principles and objectives of ISO 19011:20182. It also contradicts the requirement of ISO/IEC 17021-1:20151, which requires the certification body to determine whether a partial audit is necessary based on the nature and extent of nonconformities and other relevant factors. A partial audit may be appropriate for minor nonconformities, but the time frame and scope should be agreed upon with the auditee and based on the proposed corrective action plan.
[References: ISO/IEC 17021-1:2015 - Conformity assessment – Requirements for bodies providing audit and certification of management systems – Part 1: Requirements, ISO 19011:2018 - Guidelines for auditing management systems, , ]
