Security Audit Requirements

Who is required to undergo a cybersecurity audit?

An audit is mandatory for subjects of critical information systems (Categories I, II, and III), the list of which is approved by the Government of Georgia.

How often is the audit conducted?

Frequency depends on the subject category. Typically, for Category I subjects, the audit is annual, while for others, it is every two years.

Can I hire any auditor?

No, the auditor must be authorized or accredited by the relevant state agency (e.g., the Digital Governance Agency).

What happens if I fail the audit?

If the conclusion is negative, the organization is given a reasonable period to rectify deficiencies. Failure to do so leads to fines and other administrative sanctions.

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Security Audit Legal Requirements (ISO 27001)

Current legislation in Georgia, specifically the Law "On Information Security," obliges certain categories of organizations (subjects of critical information systems) to conduct regular audits. This audit is not merely a technical check; it is a legal process confirming that the organization meets minimum state-mandated standards, primarily based on the international ISO/IEC 27001 standard. Failure to meet audit requirements or receiving a negative conclusion results not only in administrative fines but can also become grounds for license suspension or restriction of market operations. Therefore, preparing for an audit requires coordinated work from both technical and legal departments.

Legal support for security audits helps you successfully pass mandatory inspections and satisfy regulatory requirements. The service includes:

  • Pre-audit Legal Assessment: Checking the organization's readiness, analyzing documentation completeness, and identifying non-conformities before the official audit.
  • Auditor Selection and Contracting: Selecting an authorized auditor in compliance with the law and legally formalizing the service agreement, ensuring confidentiality (NDA).
  • Legal Compliance with ISO 27001: Documenting fulfillment of standard requirements (e.g., A.18 - Compliance with legal and contractual requirements).
  • Regulatory Communication: Submitting audit results to the Operational-Technical Agency or the Digital Governance Agency; legally agreeing on a Remediation Plan for identified deficiencies.
  • Internal Audit Function Regulation: Developing charters and procedures for the internal audit service.

Practical problems often relate to the audit Scope. For instance, a bank might audit only head office systems and omit branches or a new digital product. The regulator may consider this an incomplete audit and fine the organization. Another common issue is the incorrect interpretation of "Non-conformities" found by the auditor. A lawyer can assist the organization in reasoned arguments with the auditor if their demands exceed legal bounds. Additionally, audits frequently reveal personal data breaches, requiring immediate legal response.

The audit obligation stems from the Law of Georgia on Information Security and relevant bylaws approving audit rules. Subjects of critical information systems are required to conduct audits at intervals prescribed by law (usually once a year or every two years, depending on the category). The ISO/IEC 27001 standard is also crucial, as it is recognized in Georgian legislation as the primary guiding document.

Working with a lawyer ensures the audit process is transparent and lawful. The lawyer helps the organization collect necessary evidence (policies, logs, minutes), attends interviews with the auditor, and reviews the draft audit report for factual and legal accuracy. This reduces the risk of receiving a negative conclusion.

Legal.ge allows you to connect with specialists experienced in both law and information security audits. A mandatory audit shouldn't be stressful; it is an opportunity to improve your security. Prepare professionally and pass your audit successfully with the help of our experts.

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