According to ISO 19011:2018, which provides guidelines for auditing management systems, clause 6.7 requires the audit team leader to conduct a follow-up audit to verify the implementation and effectiveness of the corrective actions taken by the auditee in response to the nonconformities identified during a previous audit1. The follow-up audit should be conducted in accordance with the same principles and processes as the initial audit, and should result in a conclusion on the status of the nonconformities and any remaining issues1.
Therefore, when conducting a follow-up audit, an ISMS auditor should consider the following actions:
Recommend that the outstanding minor nonconformity is dealt with at the next surveillance audit: This action is appropriate because it reflects the fact that the auditee has cleared most of the nonconformities, including the major one, and only one minor nonconformity remains outstanding. 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. Therefore, this finding does not prevent or preclude the continuation of certification, as long as it is addressed by appropriate corrective actions within a reasonable time frame. The auditor should recommend that the outstanding minor nonconformity is dealt with at the next surveillance audit, which is a regular audit conducted by the certification body to confirm the ongoing conformity and effectiveness of an ISMS3.
Agree with the auditee/audit client how the remaining nonconformity will be cleared, by when, and how its clearance will be verified: This action is appropriate because it reflects the fact that the auditee has demonstrated commitment and capability to implement corrective actions for the nonconformities identified during the previous audit. The auditor should agree with the auditee/audit client on a realistic, achievable, and effective corrective action plan for the remaining nonconformity, including a clear deadline and verification method. The auditor should also document this agreement in the follow-up audit report1.
Advise the individual managing the audit programme of any decision taken regarding the outstanding nonconformity: This action is appropriate because it reflects the fact that the auditor has followed a systematic and consistent approach to conducting and reporting the follow-up audit. The auditor should advise the individual managing the audit programme of any decision taken regarding the outstanding nonconformity, such as recommending its closure at the next surveillance audit or agreeing on a corrective action plan with the auditee/audit client. The auditor should also provide sufficient information and evidence to support their decision1.
Close the follow-up audit as the organisation has demonstrated it is committed to clearing the nonconformities raised: This action is appropriate because it reflects the fact that the organisation has achieved satisfactory results in the follow-up audit. The auditor should close the follow-up audit as the organisation has demonstrated it is committed to clearing the nonconformities raised by implementing effective corrective actions for most of them and agreeing on a plan for the remaining one. The auditor should also communicate the follow-up audit conclusion to the auditee/audit client and other relevant parties1.