ISO/IEC 27001

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Corrective Action Tracker

1. Purpose

The Corrective Action Tracker provides a central record for tracking actions identified from information security incidents, investigations, audits, risk assessments, security reviews, vulnerability assessments, supplier reviews, and management reviews.

The tracker ensures that corrective actions are:

  • Clearly defined
  • Assigned to an accountable owner
  • Prioritised according to risk
  • Given realistic target dates
  • Supported by evidence
  • Monitored until completion
  • Independently verified where appropriate
  • Formally closed

A corrective action should address the underlying cause or control weakness, not simply record that an immediate incident-response activity was completed.


2. Tracker Information

FieldDetails
Tracker NameCorrective Action Tracker
Organisation
Reporting Period
Tracker Owner
Last Updated
Review FrequencyWeekly / Monthly / Quarterly
Management Review Date
Version

3. Corrective Action Register

Action IDSourceFinding / IssueRoot CauseCorrective ActionRiskOwnerPriorityDue DateStatusEvidenceVerified ByClosure Date
CA-001IncidentHighOpen
CA-002AuditMediumIn Progress
CA-003Risk AssessmentLowOpen

Recommended Status Values

  • Open
  • Assigned
  • In Progress
  • Pending
  • Blocked
  • Awaiting Verification
  • Closed
  • Risk Accepted
  • Cancelled

4. Action Identification

Action ID

Source

☐ Security Incident
☐ Incident Investigation
☐ Incident Closure Report
☐ Internal Audit
☐ External Audit
☐ Risk Assessment
☐ Vulnerability Assessment
☐ Penetration Test
☐ Supplier Review
☐ Management Review
☐ Security Review
☐ Compliance Assessment
☐ Customer Finding
☐ Regulatory Requirement
☐ Other

Source Reference

Finding / Issue

Date Identified

Identified By


5. Finding Description

Describe the issue using factual and evidence-based information.

What Was Observed?

What Requirement or Control Was Not Adequately Addressed?

Evidence

Business/Security Impact


6. Root Cause

A corrective action should normally address the reason the issue occurred.

Immediate Cause

Contributing Factors

Root Cause

Why Did Existing Controls Not Prevent or Detect the Issue?

Root Cause Confirmed?

☐ Yes
☐ No
☐ Under Investigation


7. Corrective Action

Action Required

The action should be specific enough that another person can determine whether it has actually been completed.

Expected Outcome

Success Criteria

Related Control / Process


8. Corrective vs Immediate Action

TypeDescriptionCompleted?
Immediate CorrectionAction taken to address the current problemYes/No
ContainmentAction taken to prevent further impactYes/No
Corrective ActionAction addressing the underlying causeYes/No
Preventive ImprovementAction intended to reduce recurrenceYes/No

Example

Finding: Developer credentials were exposed.

Immediate Correction: Revoke exposed credential.

Containment: Review and restrict affected access.

Corrective Action: Implement controlled secret management and credential scanning.

Preventive Improvement: Add secure-development controls and developer awareness training.


9. Risk Assessment

Risk FactorAssessment
Confidentiality ImpactLow / Medium / High
Integrity ImpactLow / Medium / High
Availability ImpactLow / Medium / High
Customer ImpactLow / Medium / High
Regulatory ImpactLow / Medium / High
Business ImpactLow / Medium / High
LikelihoodLow / Medium / High
Overall RiskLow / Medium / High / Critical

Risk Description

Existing Controls

Residual Risk After Action


10. Priority

Priority

☐ Critical
☐ High
☐ Medium
☐ Low

Priority Rationale

Priority should consider:

  • Security impact
  • Likelihood of recurrence
  • Customer impact
  • Regulatory/contractual obligations
  • Business criticality
  • Exposure
  • Availability of compensating controls

11. Ownership

ResponsibilityPerson/Team
Action Owner
Supporting Team
Risk Owner
Process Owner
Security Reviewer
Final Approver

The Action Owner is responsible for ensuring the corrective action is implemented and evidence is provided.


12. Target Date

Target Completion Date

Original Due Date

Revised Due Date

Reason for Extension

Extension Approved By

Repeated extensions should be reviewed as a potential risk rather than treated as routine administrative changes.


13. Action Plan

Break complex corrective actions into manageable activities.

StepActivityOwnerTarget DateStatusEvidence
1
2
3
4

14. Implementation Evidence

Evidence should demonstrate that the corrective action was actually implemented.

Evidence IDEvidence DescriptionSourceDateLocationReviewed
E-001Yes/No
E-002Yes/No

Possible evidence:

  • Updated policy
  • Procedure
  • Configuration screenshot
  • System configuration
  • Access review
  • Security scan
  • Vulnerability report
  • Ticket
  • Change record
  • Training record
  • Log
  • Monitoring alert
  • Test result
  • Meeting record
  • Supplier confirmation
  • Technical validation
  • Audit evidence

15. Verification

Completion should not automatically mean closure.

Implementation Completed?

Yes / No

Evidence Reviewed?

Yes / No

Control Operating as Intended?

Yes / No / Not Yet Demonstrated

Verification Performed By

Verification Date

Verification Method

Verification Result


16. Effectiveness Review

Determine whether the corrective action actually addressed the problem.

Did the Action Address the Root Cause?

Yes / No / Partially

Has the Risk Been Reduced?

Yes / No / Partially

Is Recurrence Still Possible?

Yes / No / Unknown

Additional Action Required?

Yes / No

Effectiveness Review Notes


17. Overdue Action Management

Action IDOwnerDue DateDays OverdueReasonEscalated?New Date

Escalation Triggers

Consider escalation when:

  • Critical/high-risk actions become overdue
  • The same action is repeatedly delayed
  • Compensating controls are insufficient
  • Customer or regulatory exposure remains
  • Risk exceeds accepted tolerance
  • The action owner cannot complete the action
  • Dependencies remain unresolved

18. Blocked Actions

Action ID

Blocking Issue

Dependency

Temporary Control

Risk During Delay

Escalation Owner

Expected Resolution


19. Risk Acceptance

If a corrective action cannot be implemented within the required timeframe, the organisation should determine whether the remaining risk is acceptable.

Risk Acceptance Required?

Yes / No

Reason

Compensating Controls

Residual Risk

Risk Owner

Approval

Expiry/Review Date

Risk acceptance should not be used simply to avoid implementing an important corrective action.


20. Corrective Action Closure

Closure Criteria

☐ Action implemented
☐ Root cause addressed
☐ Required evidence collected
☐ Evidence reviewed
☐ Control tested where appropriate
☐ Effectiveness assessed
☐ Residual risk assessed
☐ Supporting documentation updated
☐ Related risk register updated
☐ Related incident/audit record updated
☐ No further action required
☐ Closure approved

Closure Decision

☐ Closed
☐ Closed – Risk Accepted
☐ Closed – Compensating Control
☐ Reopened
☐ Further Action Required

Closure Comments


21. Management Review

Corrective actions should be periodically reviewed by management or the appropriate security/compliance owner.

Review Date

Number of Open Actions

Number of Overdue Actions

Critical/High-Risk Open Actions

Repeated Findings

Actions Requiring Escalation

Management Decisions


22. Corrective Action Metrics

Track trends rather than only individual actions.

MetricResult
Total Open Actions
New Actions This Period
Closed Actions This Period
Overdue Actions
Critical Actions Open
High-Risk Actions Open
Average Closure Time
Reopened Actions
Risk Accepted Actions
Repeated Findings

Useful Trend Questions

  • Are corrective actions being closed on time?
  • Are the same findings recurring?
  • Are high-risk actions receiving appropriate attention?
  • Are actions being closed based on evidence?
  • Are root causes being addressed?
  • Are incidents generating meaningful security improvements?

23. Recurring Finding Analysis

Repeated findings may indicate a systemic weakness.

FindingPrevious OccurrenceCurrent OccurrenceRoot CausePatternAdditional Action

Recurring Issue Identified?

Yes / No

Management Attention Required?

Yes / No


24. Example — AWS SaaS Startup

Finding

A security incident identified that an AWS access key belonging to a developer had been exposed.

Immediate Action

The exposed key was disabled and active sessions were reviewed.

Root Cause

The development process allowed credentials to be handled outside the approved secrets-management mechanism.

Corrective Action

Implement centralised secrets management and automated credential scanning across source-code repositories and CI/CD pipelines.

Owner

Engineering Lead

Priority

High

Evidence

  • Secrets-management configuration
  • Repository scanning results
  • CI/CD configuration
  • Test alert
  • Updated developer procedure

Verification

Security team confirms that:

  1. New credentials are stored through the approved mechanism.
  2. Repository scanning is active.
  3. Test credentials trigger the expected alert.
  4. Developers cannot bypass the approved process without an approved exception.

Closure

The action is closed only after implementation evidence and effectiveness have been reviewed.


25. Corrective Action Lifecycle

Use the following lifecycle for every significant action:

Finding Identified

↓

Issue Analysed

↓

Root Cause Determined

↓

Risk Assessed

↓

Corrective Action Defined

↓

Owner Assigned

↓

Target Date Established

↓

Action Implemented

↓

Evidence Collected

↓

Effectiveness Verified

↓

Residual Risk Assessed

↓

Management/Owner Approval

↓

Action Closed


26. Relationship With Other ISMS Records

Corrective actions may originate from or feed into:

Incident

→ Incident Investigation

→ Root Cause

→ Corrective Action

→ Risk Assessment

→ Risk Treatment

→ Verification

→ Closure

Similarly:

Internal Audit

→ Finding

→ Corrective Action

→ Evidence

→ Effectiveness Review

→ Closure

And:

Risk Assessment

→ Risk

→ Treatment Decision

→ Action

→ Implementation

→ Residual Risk

→ Review

This creates a traceable relationship across the ISMS.


27. Audit Evidence Trail

A complete corrective action record should demonstrate:

Finding Identified

→ Evidence Recorded

→ Root Cause Analysed

→ Risk Assessed

→ Corrective Action Defined

→ Owner Assigned

→ Due Date Established

→ Action Implemented

→ Evidence Collected

→ Implementation Verified

→ Effectiveness Reviewed

→ Residual Risk Assessed

→ Management Review

→ Action Closed


28. ISO 27001 Connection

The Corrective Action Tracker supports the organisation’s process for addressing identified issues and improving the effectiveness of the information security management system.

It can be used to track actions arising from:

  • Information security incidents
  • Internal audits
  • External audits
  • Risk assessments
  • Security assessments
  • Vulnerability assessments
  • Penetration testing
  • Supplier assessments
  • Management reviews
  • Customer findings
  • Compliance assessments
  • Security monitoring

The organisation should determine the appropriate action, ownership, priority, verification method, and evidence based on the nature and risk of the finding.


29. Startup Implementation Approach

A startup can maintain one central corrective-action tracker rather than creating separate trackers for every security process.

For example:

SourceActionOwnerPriorityDueStatus
IncidentRotate exposed credentialsEngineeringHighClosed
VAPTFix critical vulnerabilityEngineeringCriticalIn Progress
Internal AuditComplete access reviewITMediumOpen
Risk AssessmentEnable additional monitoringSecurityHighOpen
Supplier ReviewObtain missing evidenceProcurementMediumClosed

The key principle is:

One Finding → One Owner → One Due Date → One Evidence Trail → One Verification Decision.


Final Principle

Identify the Problem + Find the Root Cause + Assess the Risk + Assign Ownership + Define the Action + Set the Deadline + Implement + Verify Effectiveness + Track Residual Risk + Close With Evidence.

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