Audit Preparation for ISO 27018 Certification

Proper preparation is key to a successful ISO 27018 certification audit. This lesson covers everything you need to know to prepare for and pass your certification audit.

Understanding the Audit Process

Audit Stages

Stage 1: Document Review (Remote)

Duration: 1-2 days
Purpose: Review documentation completeness
Scope: Policies, procedures, records
Outcome: Readiness assessment, identification of gaps

Stage 2: On-site/Remote Audit

Duration: 2-5 days (depends on scope)
Purpose: Verify implementation of controls
Scope: Full ISO 27018 requirements
Outcome: Certification decision, findings

Surveillance Audits (Annual)

Duration: 1-2 days
Purpose: Verify continued compliance
Scope: Sampling of controls
Outcome: Certificate maintenance

Recertification (Every 3 Years)

Duration: Similar to Stage 2
Purpose: Full re-assessment
Scope: All controls
Outcome: Certificate renewal

Pre-Audit Preparation (60-90 Days Before)

1. Select Certification Body

Accredited Certification Bodies:

Check accreditation (UKAS, ANAB, etc.)
Verify ISO 27018 certification capability
Compare costs and timelines
Review auditor qualifications

Questions to Ask:

How many ISO 27018 audits have you conducted?
What is your audit methodology?
Who will be the lead auditor?
What are the costs (application, audit, annual fees)?
What is the typical timeline?
Do you offer pre-assessment audits?

2. Conduct Internal Audit

Purpose: Identify and fix issues before certification audit

Internal Audit Steps:

Create audit plan and checklist
Assign internal auditors (competent, independent)
Review all documentation
Interview process owners
Test technical controls
Verify records and evidence
Document findings
Create corrective action plan
Verify corrections
Report to management

Internal Audit Checklist:

All policies reviewed and current
Procedures documented and followed
Technical controls implemented
Records complete and accessible
Training completed
Incidents documented
Management reviews conducted
Corrective actions closed

3. Management Review

Purpose: Executive oversight and commitment

Required Topics:

Internal audit results
Compliance status
Incident summary
Changes to scope
Resource adequacy
Continual improvement
Certification readiness

Management Review Agenda:

ISO 27018 Management Review
Date: [Date]
Attendees: CEO, CTO, CISO, DPO, Legal

1. Review of Previous Actions
2. Current Compliance Status (Gap Analysis Results)
3. Internal Audit Findings
4. Security Incident Summary
5. Changes to Scope or Context
6. Resource and Budget Review
7. Certification Readiness Assessment
8. Decision on Proceeding with Certification Audit
9. Assignment of Final Preparations

Minutes: [Record decisions and actions]
Next Review: [Quarterly]

Documentation Preparation

Essential Documents for Audit

Policies (10-15 documents):

Privacy Policy
Information Security Policy
Data Protection Policy
Acceptable Use Policy
Access Control Policy
Encryption Policy
Incident Response Policy
Business Continuity Policy
Risk Management Policy
Training Policy

Procedures (15-20 documents):

Consent management
Data subject rights fulfillment
Data retention and deletion
Breach notification
Sub-processor management
Risk assessment
Internal audit
Management review
Corrective action
Document control

Records (Minimum 6 months, preferably 12):

Data processing register
Sub-processor registry
Consent records
Data subject requests and responses
Training records and attendance
Audit logs (6-12 months)
Internal audit reports
Management review minutes
Incident logs
Risk assessments
Vulnerability scans
Penetration test reports

Technical Evidence:

System architecture diagrams
Data flow diagrams
Network diagrams
Encryption verification
Access control matrices
Configuration screenshots
Monitoring dashboards
Backup verification

Document Organization

Create Audit Evidence Binder (Physical or Digital):

ISO 27018 Audit Evidence/
├── 1-Policies/
│   ├── Privacy-Policy-v2.1.pdf
│   ├── Information-Security-Policy-v3.0.pdf
│   └── ...
├── 2-Procedures/
│   ├── Consent-Management-Procedure.pdf
│   ├── DSAR-Procedure.pdf
│   └── ...
├── 3-Records/
│   ├── Data-Processing-Register.xlsx
│   ├── Training-Records-2025.xlsx
│   ├── Audit-Logs/
│   │   ├── 2025-Q1-Audit-Logs.pdf
│   │   └── ...
│   └── ...
├── 4-Technical-Evidence/
│   ├── Architecture-Diagrams/
│   ├── Encryption-Verification/
│   ├── Access-Control-Screenshots/
│   └── ...
├── 5-Audit-Reports/
│   ├── Internal-Audit-2025-Q2.pdf
│   ├── Penetration-Test-2025.pdf
│   └── ...
└── 6-Management-Reviews/
    ├── Management-Review-2025-Q1.pdf
    └── ...

Document Quality Checks

Before Audit, Verify:

All documents have version numbers
All documents have approval signatures
All documents have effective dates
No outdated documents in use
No conflicting information between documents
All references are correct
All templates are filled out
All required records are present

Staff Preparation

Identify Key Personnel

People Auditors Will Interview:

Privacy Officer / DPO
CISO / Security Manager
IT Manager
Development Lead
Operations Manager
Customer Support Manager
HR Manager
Legal Counsel

Staff Training

Train Staff On:

ISO 27018 requirements
Their role in compliance
What auditors will ask
How to respond to questions
Where to find documentation
Escalation procedures

Interview Tips for Staff:

Be honest and factual
If unsure, say "I don't know, but I can find out"
Don't speculate or guess
Refer to documented procedures
Show, don't just tell
Stay calm and professional

Mock Interviews

Practice Common Questions:

"Walk me through how you handle a data subject access request"
"How do you ensure consent is obtained before marketing?"
"Show me how you delete customer data"
"What would you do if you discovered a data breach?"
"How do you verify sub-processor compliance?"

Technical Environment Preparation

System Access for Auditors

Prepare:

Read-only audit accounts created
VPN access configured (if remote)
Screen sharing tools tested
Demo environments ready
Sample data prepared (no real PII shown to auditors)
Backup access methods

Technical Demonstrations

Be Ready to Demonstrate:

Encryption (at rest and in transit)
Access controls and authentication
Audit logging
Data deletion process
Backup and recovery
Monitoring and alerting
Incident response tools
Consent management system
Data subject rights portal

Create Demo Scripts:

Demo: Data Subject Access Request Process

1. Show DSAR request form
2. Demonstrate identity verification
3. Show data retrieval from systems
4. Display automated data compilation
5. Show review and redaction interface
6. Demonstrate secure delivery
7. Show audit log entry
8. Confirm 30-day SLA tracking

Audit Day Logistics

Opening Meeting Preparation

Attendees:

Executive sponsor (CEO, CTO)
Privacy Officer
CISO
Legal counsel
Process owners
Auditors

Opening Meeting Agenda:

Introductions
Audit scope and objectives
Audit schedule
Logistics and facilities
Communication protocols
Confidentiality
Questions

Audit Schedule Example

ISO 27018 Certification Audit Schedule

Day 1:
09:00 - Opening Meeting
10:00 - Document Review
12:00 - Lunch
13:00 - Management Interviews (CEO, DPO, CISO)
15:00 - Policy and Procedure Review
17:00 - Day 1 Wrap-up

Day 2:
09:00 - Technical Controls Review
     - Encryption verification
     - Access control testing
     - Audit log review
12:00 - Lunch
13:00 - Process Verification
     - Consent management demo
     - DSAR process walkthrough
     - Deletion demo
15:00 - Records Review
17:00 - Day 2 Wrap-up

Day 3:
09:00 - Sub-processor Management Review
10:30 - Data Subject Rights Verification
12:00 - Lunch
13:00 - Incident Response Review
14:00 - Sampling of Additional Controls
15:30 - Auditor Deliberation
16:30 - Closing Meeting
17:30 - End of Audit

Room and Facilities

Prepare:

Private conference room reserved
Reliable internet connection
Projector/screen for demonstrations
Whiteboard/flipchart
Power outlets
Refreshments
Parking/building access for auditors

During the Audit

Best Practices

Do:

Be welcoming and professional
Answer questions directly and honestly
Provide evidence when asked
Take notes of findings
Ask for clarification if needed
Escalate issues appropriately

Don't:

Volunteer information not asked for
Make excuses
Argue with auditors
Promise things you can't deliver
Guess or speculate
Panic over findings

Handling Findings

Finding Types:

Non-Conformity (Major):

Critical requirement not met
May block certification
Requires immediate correction
Response: Develop correction plan within 7-14 days

Non-Conformity (Minor):

Requirement partially met
Won't block certification
Needs correction before certificate issued
Response: Fix within 30-90 days

Observation:

Not a non-conformity yet
Potential future issue
Improvement opportunity
Response: Consider for continual improvement

Opportunity for Improvement:

Suggestion, not requirement
Best practice recommendation
Response: Optional, but consider

Closing Meeting

What to Expect:

Summary of audit
List of findings
Auditor recommendation (certify / not certify / conditional)
Next steps
Timeline for decision
Corrective action requirements

Post-Audit Actions

If Findings Require Correction

1. Develop Corrective Action Plan (Within 7 Days)

Root cause analysis
Corrective action
Preventive action
Evidence required
Timeline
Responsible person

2. Implement Corrections

Make required changes
Document actions taken
Gather evidence

3. Submit to Certification Body

Corrective action report
Evidence of implementation
Request review

4. Verification

Auditor reviews evidence
May require follow-up audit
Final certification decision

Certification Issued

What You Receive:

ISO 27018 certificate
Certification mark usage rights
Public registry listing
Validity period (3 years)
Surveillance audit schedule

Next Steps:

Announce certification
Update marketing materials
Inform customers
Plan surveillance audit preparation
Continue compliance

Audit Preparation Checklist

90 Days Before:

Select certification body
Conduct internal audit
Address internal audit findings
Conduct management review

60 Days Before:

Submit application to certification body
Schedule Stage 1 audit
Finalize documentation
Train staff

30 Days Before:

Submit documents for Stage 1 review
Prepare technical demonstrations
Create audit evidence binder
Conduct mock interviews

14 Days Before:

Address any Stage 1 findings
Confirm audit schedule
Brief all participants
Test auditor access
Reserve facilities

1 Week Before:

Final document review
Verify all evidence accessible
Confirm attendee availability
Prepare opening meeting materials
Mental preparation

Day of Audit:

Welcome auditors
Be professional and helpful
Take notes
Provide requested evidence
Stay calm

After Audit:

Implement corrective actions
Submit evidence
Receive certification
Celebrate!
Plan continuous improvement

Next Lesson: Common audit findings - learn from others' mistakes and avoid common pitfalls.