Corrective Action

Corrective action is a formal process required by ISO 27001 Clause 10.1 and is fundamental to the continuous improvement cycle that underpins all management system standards. When a nonconformity is identified — whether through internal audits, external audits, incident investigations, or management reviews — the organization must react to the nonconformity, evaluate the need for action to eliminate the root cause, implement the necessary action, review the effectiveness of the corrective action, and make changes to the management system if necessary. The distinction between correction (fixing the immediate problem) and corrective action (preventing recurrence) is crucial.

The corrective action process follows a structured methodology. First, the nonconformity is clearly described and its immediate impact is addressed. Then, a root cause analysis is performed to understand why the nonconformity occurred — not just the symptoms, but the underlying systemic factors. Based on the root cause, an appropriate corrective action is designed and implemented. The action is then verified for effectiveness — has it actually prevented recurrence? Finally, the entire process is documented for accountability and audit evidence. SOC 2 auditors evaluate whether organizations have processes for identifying and remediating control deficiencies. NIS2 requires entities to implement measures for handling security incidents, which includes corrective actions following incidents.

Effective corrective action management requires several organizational capabilities. Organizations need a tracking system (often integrated into their GRC platform or issue tracker) that ensures corrective actions are assigned, scheduled, and followed through to completion. Root cause analysis skills are essential — techniques such as the Five Whys, Ishikawa diagrams, or fault tree analysis help teams move beyond surface-level fixes. Management oversight ensures that corrective actions receive appropriate resources and attention. Most importantly, organizations should view nonconformities and corrective actions as improvement opportunities rather than failures — a culture that punishes the identification of problems will discourage the transparency needed for effective corrective action.