ISO 27001 Annex A 5.22 Monitoring, review and change management of supplier services requires organisations to oversee third-party vendors regularly. Documented reviews ensure suppliers maintain agreed security standards, follow service terms, and manage operational changes safely.
Table of contents
Key Takeaways
- Monitor supplier performance: Review third-party service levels and security practices regularly to ensure ongoing contract compliance.
- Store review records centrally: Keep supplier audit logs, service level reports, and assessment files in a central document repository.
- Manage supplier changes: Assess risk and approve modifications before third parties alter their software, hosting, or service terms.
- Verify provider certifications: Check independent audit reports and security certifications to confirm external controls stay effective.
- Review incident response steps: Ensure suppliers report data breaches and technical failures within agreed contract deadlines.
- Scale reviews by supplier risk: Perform deeper, more frequent assessments on critical vendors handling sensitive business data.
- Enforce corrective actions: Require third-party partners to remediate identified security weaknesses within set timeframes.
- Maintain supplier registers: Keep an active inventory of all external service providers, contract owners, and review dates.
How to Implement ISO 27001 Annex A 5.22
- Draft a supplier review policy: Write clear instructions for monitoring third-party vendors and store them in your central document repository.
- Build a supplier review schedule: Establish planned calendar dates to review performance, compliance, and security for each active supplier.
- Track service level agreements: Monitor monthly uptime, response speed, and delivery metrics against contractual commitments.
- Review third-party audit reports: Request and inspect annual independent compliance certificates and audit reports from key vendors.
- Establish change notification rules: Require suppliers to give advance notice before making significant technical, architectural, or process changes.
- Conduct supplier security audits: Run questionnaires or on-site inspections for high-risk third parties processing confidential data.
- Log supplier security incidents: Track any service outages or data breaches caused by external vendors in a central incident log.
- Assign internal supplier managers: Appoint dedicated internal owners to oversee vendor relationships and conduct regular review meetings.
- Update contingency plans: Maintain backup options and exit routes in case a critical supplier fails or alters service delivery.
When you’re ready to bring compliance into one place
How to Audit ISO 27001 Annex A 5.22
- Review supplier review policies: Inspect written procedures to verify standard methods exist for monitoring and reviewing external services.
- Sample supplier review files: Check completed review records to confirm teams evaluated vendor security and performance on schedule.
- Verify change management logs: Check that teams evaluated and approved supplier-notified system changes before implementation.
- Inspect third-party certificates: Verify that valid security certificates and external audit reports exist for critical service providers.
- Check SLA performance reports: Review performance tracking dashboards to confirm suppliers consistently met contractual targets.
- Audit supplier corrective actions: Inspect remediation tracking lists to ensure vendors resolved flagged security gaps on time.
- Interview supplier relationship leads: Speak with contract owners to assess how they manage vendor changes, alerts, and performance dips.
- Review supplier incident records: Check past incident files to verify vendors reported security events within agreed contract windows.
Audit Evidence Checklist
- Supplier review procedure: Maintain a documented vendor review policy with full revision history in your central repository.
- Supplier risk register: Keep an active, up-to-date inventory of third-party suppliers, risk levels, and assigned internal managers.
- Periodic supplier review logs: Supply completed evaluation forms and minutes from annual vendor performance meetings.
- Third-party audit reports: Provide independent security certificates and assurance summaries collected from suppliers.
- Supplier change request records: Supply documentation showing formal impact reviews of supplier-initiated service changes.
- SLA performance dashboards: Provide reports tracking vendor uptime, availability, and ticket response times.
- Corrective action plans: Maintain logs showing resolved security findings and remediation proof from third-party partners.
What to Teach Employees
- Monitor supplier deliverables: Teach contract managers to review third-party work outputs and service quality against contract terms.
- Flag vendor changes early: Instruct teams to notify security leads when suppliers propose major software or operational updates.
- Report supplier incidents fast: Ensure staff know how to report vendor service outages, data leaks, or unapproved access immediately.
- Request security updates: Remind contract owners to collect renewed compliance certificates from suppliers annually.
- Avoid informal service changes: Warn staff against agreeing to supplier scope changes without formal review and approval.
- Track supplier access rights: Instruct teams to review and remove third-party system permissions as soon as projects finish.
Common Implementation Challenges
- Unmonitored ongoing services: Teams sign contracts and never assess suppliers again. Schedule mandatory annual reviews.
- Unnotified supplier updates: Vendors change platforms without warning. Include strict contractual change-notification clauses.
- Treating all vendors equally: Spending equal time on minor and critical suppliers wastes effort. Tier reviews based on data risk.
- Outdated compliance certificates: Supplier assurance reports expire without renewal. Track certificate expiry dates in a central log.
- No formal remediation tracking: Identified vendor flaws get forgotten. Require written corrective action plans for all findings.
- Siloed vendor management: Procurement, legal, and IT manage vendors separately. Consolidate supplier tracking into a single registry.
How to Measure Effectiveness (KPIs)
- Supplier review completion rate: Track the percentage of scheduled supplier security reviews completed on time.
- SLA compliance rate: Measure the proportion of third-party suppliers consistently meeting contract performance targets.
- Supplier assurance coverage: Track the percentage of critical vendors with current, valid security certifications on file.
- Supplier incident count: Monitor the total number of security incidents or data breaches caused by third-party providers.
- Vendor remediation speed: Measure the average number of days taken by suppliers to resolve flagged security weaknesses.
- Supplier audit finding count: Monitor the number of non-conformities raised against supplier monitoring during internal audits.
Related ISO 27001 Controls
ISO 27001 Control A 5.22 connects to several other ISO 27001 requirements:
Annex A 5.22 depends on Clause 5.19 for the initial supplier security policy. It supports Clause 5.20 by ensuring contractual obligations are met. This control also feeds into Clause 5.7 (Threat Intelligence) for supplier-specific risks. Each review contributes to the overall risk management process in Clause 6.1.2.
