When you’re preparing for an ISO 27001 audit, the last thing you want is for the audit itself to cause a security incident. This is the “audit paradox”: the very process meant to ensure your safety can, if poorly managed, lead to system downtime or data exposure. In the transition from the 2013 version to the ISO 27001:2022 update, the controls surrounding this risk have been refined and modernised.
Today, we are looking at Annex A 8.34, “Protection of information systems during audit testing.” If you are migrating your ISMS, understanding these specific tweaks is essential for a smooth transition.
Table of contents
From Control 12.7.1 to 8.34: The New Structure
In the ISO 27001:2013 standard, this requirement was known as Control 12.7.1, “Information systems audit controls.” It was housed within the “Operations Security” domain. In the 2022 revision, it has been moved into the “Technological Controls” theme and renumbered as 8.34.
While the core mission, minimising the impact of audit activities on operational systems, remains consistent, the 2022 version introduces a more structured, risk-adaptive approach suitable for today’s complex IT environments.
The New Requirement: Auditor Device Security
One of the most notable additions in the 2022 version is a requirement that simply wasn’t there in 2013. Under Annex A 8.34, organisations are now expected to verify the security of the devices used by auditors before granting them access to the network or systems.
According to the guidance from Hightable.io, this means you shouldn’t just hand over a login to an auditor without checking their “kit” first. You need to ensure that the auditor’s laptop or testing device meets your internal security standards, such as having active antivirus, up-to-date patches, and encryption to prevent them from inadvertently introducing malware into your environment.
Broadened Scope: Testing and Development Environments
The 2013 version focused heavily on “operational” or production systems. However, the 2022 update explicitly brings development and testing environments into the conversation. It recognises that an audit of a dev environment can be just as risky if it leads to the compromise of source code or intellectual property.
The supplementary guidance for ISO 27001:2022 cautions organisations to be particularly wary of integrity risks during these tests. If an auditor is testing your code repository or a staging environment, the controls in 8.34 ensure that their activities don’t accidentally corrupt your build or leak sensitive configuration data.
Emphasis on Least Privilege and “Read-Only” Access
While the 2013 version mentioned planning and agreement, the 2022 version is much firmer on the technical execution of the audit. It strongly advocates for the principle of “least privilege.”
Practical implementation advice from Hightable.io suggests that wherever possible, auditors should only be granted read-only access. If they need to see evidence, they should be looking at isolated copies of files rather than the “live” master data. If administrative access is required for a specific technical test, it should be strictly time-limited and monitored in real-time by a system owner.
Attributes: A New Way to Categorise
Like all controls in the 2022 update, Annex A 8.34 now comes with “Attributes.” This is a significant change from the 2013 version, which lacked this metadata. Control 8.34 is primarily tagged as a Preventive control.
This tells you that your primary focus during an audit should be on the pre-approval and planning stages. You need to prove that you have agreed on the scope, timing, and methods of the test before a single command is run. This shift helps security managers explain to leadership why “surprise audits” are generally a bad idea for technical systems.
How to Modernise Your Audit Procedures
To align with the updated requirements of Annex A 8.34, consider these steps:
- Joint Planning: Ensure every audit or penetration test has a formal “Rules of Engagement” document signed by both the auditor and the system owner.
- Device Checks: Add a step to your auditor onboarding process to verify their hardware security compliance.
- Logging Everything: Ensure all auditor activities are captured in your event logs, providing a clear trail of what was accessed and when.
- Clean-up Protocols: Establish a clear “post-audit” checklist to ensure all temporary accounts are disabled and any isolated data copies are securely deleted.
By moving to the ISO 27001:2022 framework for audit protection, you aren’t just ticking a compliance box; you are building a more resilient operation that can withstand the scrutiny of a check-up without breaking a sweat.