Auditing Backup and Recoverability Under ISO 27001
Backup is one control, and recoverability is not. A.8.13 covers backup copies of information, software and systems. Whether the organisation could actually carry on is spread across A.8.14 redundancy, A.5.29 information security during disruption and A.5.30 ICT readiness for business continuity, and an audit that stops at the backup control has looked at one of the four.
Backup is one control, and recoverability is not. A.8.13 covers backup copies of information, software and systems. Whether the organisation could actually carry on is spread across A.8.14 redundancy, A.5.29 information security during disruption and A.5.30 ICT readiness for business continuity, and an audit that stops at the backup control has looked at one of the four.
The organisation in the worked finding on this page is invented, and so is the finding.
Four ISO 27001 backup and continuity controls, four different questions
| Control | The question it asks |
|---|---|
| A.8.13 Information backup | Are backup copies of information, software and systems maintained and regularly tested, in accordance with the agreed topic-specific policy on backup? |
| A.8.14 Redundancy of information processing facilities | Are the facilities implemented with redundancy sufficient to meet availability requirements? |
| A.5.29 Information security during disruption | Has the organisation planned how to maintain information security at an appropriate level during disruption? |
| A.5.30 ICT readiness for business continuity | Is ICT readiness planned, implemented, maintained and tested against business continuity objectives and ICT continuity requirements? |
The four are not alternatives. An organisation can hold complete backups, have no redundancy, have never considered how information stays protected while it is recovering, and have no idea what the business actually needs. Those are four findings against four controls, and telling them apart is part of what a lead auditor is examined on.
Start at the Statement of Applicability. All four are controls the organisation selected at Clause 6.1.3, and what it claims about each is your first criterion. A.8.14 and A.5.30 are the two most often marked applicable and implemented on the strength of equipment existing rather than of anything having been determined.
The ISO 27001 backup requirement that is easy to read past
A.8.13 says backup copies are to be maintained and regularly tested, in accordance with the agreed topic-specific policy on backup. Two limbs and a criterion, and the criterion is the organisation’s own policy. That has a consequence auditors sometimes miss in the other direction: the standard does not set a testing frequency, a retention period or a copy count. If the organisation’s policy sets them, they are the criteria. If its policy is silent, the gap is in the policy, and the finding is a different one.
So the first question in this area is not about backups at all. It is: what does your backup policy actually require, and when was it last agreed?
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Where ISO 27001 recoverability lives, and the requirement people forget
A.5.30 is the control that connects all of this to the business, and it is the one most often absent. It asks for ICT readiness to be planned, implemented, maintained and tested against business continuity objectives and ICT continuity requirements. Those requirements are an input the organisation has to have determined, and most have not.
That produces a question worth asking early, because the answer shapes everything after it. How long can this organisation be without this system, and who decided that? An organisation that cannot answer has no criterion against which any of its arrangements can be evaluated — and neither have you. An organisation that can answer has just handed you the measure for everything else in the area.
A.5.29 is the quiet one. Its subject is information security during disruption, which is the period when controls are most likely to be suspended in the interests of getting going again. Ask what happens to access control, logging and approval during a recovery. The honest answer is often that nobody has thought about it, and that is the control’s whole point.
A worked ISO 27001 finding on Annex A.8.14
Netherfield Assurance operates a claims platform with nightly backups to a second site, a documented backup policy, and a schedule of restore exercises that runs and is recorded.
| Statement | The availability requirements against which the sufficiency of redundancy for the claims platform would be established have not been determined, and the redundancy provided has not been shown to meet any such requirement. |
|---|---|
| Objective evidence | The Statement of Applicability, version 7, marks A.8.14 applicable and implemented, with the justification “secondary site provides resilience for claims processing”. The claims platform runs at a primary data centre with a warm standby at a second site. No document stating an availability requirement, a recovery time objective or a maximum tolerable outage for the claims platform was produced, and the information security manager and the head of claims gave materially different answers when asked separately what the business could tolerate. The standby has never been brought into service, in an exercise or otherwise; the infrastructure manager stated that failover is estimated at four to six hours and that the estimate has not been tested. The risk assessment records availability of the claims platform as a risk, treated by the entry “secondary site”, with no stated target. |
| Requirement | ISO/IEC 27001 Annex A.8.14 requires information processing facilities to be implemented with redundancy sufficient to meet availability requirements. |
| Grade | Major — sufficiency cannot be established because the availability requirement it would be measured against has never been determined, so the control as selected is not implemented rather than implemented imperfectly; the untested failover and the divergent accounts from the two accountable managers show the gap is in the organisation’s knowledge of its own requirement, not in the records of it. |
Read the control’s wording before you write anything here. A.8.14 asks for redundancy sufficient to meet availability requirements. Sufficiency is a comparison, and a comparison needs two terms. Where the second term does not exist, the finding is not that the redundancy is inadequate — you cannot know that — but that the organisation has no basis on which to say it is adequate. Those are different findings, and only one of them survives being argued with.
One discipline in writing any of these. Record what you were told where it establishes how far the failure reaches, and leave your own account of why it happened out of the box. The two managers’ divergent answers are recorded because they establish that the requirement is genuinely undetermined rather than merely undocumented. The finding stops there.
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The audit trail for ISO 27001 backup and recoverability
Start with the policy, not the technology. What has the organisation agreed about backup: what is copied, how often, held how long, held where, and tested how? Those are the criteria, and without them everything you look at afterwards is an observation with nothing to measure it against.
Then ask what the business needs, and who decided it. This is the A.5.30 question and it is the most useful one on the page.
Then look at A.8.14 and A.5.30 together. Redundancy has to be sufficient to meet availability requirements, and ICT readiness has to be planned against continuity objectives and requirements. Both are comparisons, and both need a second term the organisation has determined. Where it has not, the finding is that sufficiency cannot be established rather than that anything is inadequate.
And ask about the disruption period itself. What controls apply while systems are being brought back, and who is allowed to bypass what.
Major or minor in an ISO 27001 backup finding
Major territory: no backup policy, so nothing has a criterion; a control marked implemented whose sufficiency has never been capable of being assessed; continuity arrangements that exist for the business and were never extended to ICT.
Minor territory: a system outside the schedule the policy sets; one exercise late in a programme that runs; a retention setting that does not match the policy on one system.
Escalation: arrangements across the whole area that were configured once and never revisited is a case about review rather than about backup, and belongs where the checking should have happened.
And the criteria are the standard and the organisation’s own requirements, not your view of good practice. Nowhere is that easier to forget than here, because most auditors have a number in their head for how often a restore should be exercised, and the standard has none.
ISO 27001 backup and continuity: which question does each control ask?
Pick a control to see the question it asks.
How to use it: Choose the option that fits you from the list. The answer appears below.
From the table in this article. Each control asks a different question, so match the evidence to the question.
Frequently asked questions about auditing backup and recoverability under ISO 27001
Which ISO 27001 control covers backup?
A.8.13, information backup, which requires backup copies of information, software and systems to be maintained and regularly tested in accordance with the agreed topic-specific policy on backup. Recoverability more broadly is also carried by A.8.14 redundancy, A.5.29 and A.5.30.
How often does ISO 27001 require backups to be tested?
It sets no frequency. The control requires testing in accordance with the organisation’s agreed topic-specific policy on backup, so the organisation’s own policy supplies the interval and becomes the criterion. An auditor who supplies a figure from experience has invented a requirement.
What is the difference between ISO 27001 Annex A.5.29 and A.5.30?
A.5.29 is about maintaining information security at an appropriate level during disruption. A.5.30 is about ICT readiness, planned and tested against business continuity objectives and ICT continuity requirements. A.5.30 is one of the eleven controls new in the 2022 revision; A.5.29 is not.
Does ISO 27001 require a disaster recovery plan?
Not by that name. What it requires is that ICT readiness be planned, implemented, maintained and tested against the organisation’s continuity objectives and requirements, and that information security be maintained during disruption. Whether the organisation calls the result a disaster recovery plan is its own business.
Is backup an ISO 27001 Clause 8 matter or an Annex A one?
Both can apply. The control is A.8.13. If the failure is that a risk treatment decision about availability was never carried out, that is Clause 8.3; if the Statement of Applicability misstates whether the control is implemented, that is Clause 6.1.3 d).
The other ISO 27001 control areas
auditing supplier and third-party security
For the controls behind these areas, the four Annex A theme pages set out what each group requires: the A.5 organizational controls, the A.6 people controls, the A.7 physical controls, the A.8 technological controls.
3FOLD TRAINING is a CQI and IRCA Approved Training Partner, ATP number 6039853. Its ISO 27001 Lead Auditor training course is the CQI and IRCA Certified ISO/IEC 27001:2022 Lead Auditor (Information Security Management Systems) Training Course. The course identification number is 2889. Both the partner approval and the course certification are on 3FOLD TRAINING’s Approved Training Partner record, and any provider’s certified courses can be looked up in CQI and IRCA’s own directory of certified courses and approved training partners. The course page carries the schedule and what the course includes. If you would rather ask a person first, use the course enquiry form.
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