ISO 27001 • Nonconformities • Translation Companies
How Language Translation Companies Can Turn ISO 27001 Nonconformities Into Continuous Improvement
From Error to Excellence: Building an Evidence-Driven Security Culture
For language translation and localization companies, handling sensitive multilingual data means holding immense responsibility. Clients trust you with intellectual property, contracts, medical records, and confidential communications.
Even with the best processes, lapses can happen a translator using an unauthorized storage tool, an outdated data-handling checklist, or an internal control skipped under deadline pressure.
ISO/IEC 27001 doesn’t expect perfection it expects control and accountability. Clause 10.2, Nonconformity and Corrective Action, is designed to help you prove that when mistakes occur, they’re recorded, analyzed, fixed, and learned from.
At Canadian Cyber, our CC-ISMS-010 Nonconformity and Corrective Action Records Template empowers translation firms to build a measurable, audit-ready improvement system one that shows auditors and clients alike that security isn’t a one-time effort, but a living, improving process.
Why This Process Matters for Translation Companies
Translation service providers face unique compliance risks:
- Multiple linguists accessing shared client repositories.
- Handling confidential legal, medical, or government content.
- Varying privacy regulations (PIPEDA, GDPR, HIPAA).
- Pressure to deliver quickly across time zones and platforms.
Without a structured system, minor lapses can repeat and become systemic. An ISO 27001-aligned nonconformity and corrective-action process ensures:
- Every deviation is recorded and investigated.
- Root causes are identified and eliminated.
- Actions are tracked, verified, and evidenced.
- Continuous improvement is built into management reviews.
Inside the CC-ISMS-010 Template
The template is based on ISO 27001:2022 Clause 10.2 and Annex A controls 5.35–5.37. It defines scope, references, definitions, roles, policy, step-by-step process, and compliance mapping to ensure a closed-loop improvement system.
🧾 Sample Nonconformity & Corrective Action Record
(Based on the Canadian Cyber CC-ISMS-010 Template)
| Field | Details |
|---|---|
| Document Title | Nonconformity & Corrective Action Records |
| Document Number | LT-ISMS-010 |
| Version | 1.0 |
| Date | October 2025 |
| Company | LinguaTrust Translations Inc. |
| Classification | Confidential |
1. Purpose
To ensure all information-security nonconformities within LinguaTrust’s ISMS are identified, logged, corrected, and verified in accordance with ISO/IEC 27001 Clause 10.2, enabling continual improvement and demonstrable compliance.
2. Scope
Covers all departments and systems handling client data including TMS platforms, linguist access, vendor portals, and internal IT operations. Applies to nonconformities from audits, security incidents, client complaints, or monitoring activities.
3. References
| Reference | Description |
|---|---|
| CC-ISMS-001 | ISMS Scope |
| CC-ISMS-006 | Statement of Applicability |
| CC-ISMS-008 | Internal Audit Program & Reports |
| CC-ISMS-009 | Management Review Minutes |
| ISO/IEC 27006-1 | Certification Body Audit Guidelines |
4. Definitions & Acronyms
- Nonconformity: Failure to fulfill a requirement (e.g., policy not followed or control missing).
- Corrective Action: Action to eliminate the cause of a nonconformity and prevent recurrence.
- Root Cause: Underlying factor that triggered the problem.
- OFI (Opportunity for Improvement): Observation where processes could be enhanced beyond compliance.
5. Roles & Responsibilities
| Role | Responsibility |
|---|---|
| CEO (Marie Dupont) | Approves major corrective-action plans and allocates resources. |
| ISMS Manager (Ryan Carter) | Logs nonconformities, assigns owners, tracks actions, verifies closure, and reports to management. |
| Internal Auditor | Identifies and records NCs/OFIs in audit reports and verifies closure. |
| Process Owners | Implement actions and retain evidence of changes (e.g., updated procedures, training logs, TMS screenshots). |
6. Policy & Procedure
- Mandatory Logging: All nonconformities and significant OFIs must be recorded immediately.
- Timely Correction: Immediate actions contain the issue while long-term fixes are planned.
- Root Cause Analysis: Each nonconformity must include RCA to prevent recurrence.
- Verification & Closure: Independent review confirms effectiveness before closure.
- Management Oversight: Major NCs are reviewed in management meetings.
- Record Retention: All NC records are kept for six years for audit evidence.
7. Step-by-Step Process
- 1️⃣ Identification & Logging: NC reported via audit, incident, or complaint; assigned unique ID in SharePoint Log.
- 2️⃣ Immediate Correction: Quick containment (e.g., revoke access or delete shared link).
- 3️⃣ Root Cause Analysis: RCA using “5 Whys” or cause diagram.
- 4️⃣ Corrective Action Plan: Plan documented with tasks, owners, and deadlines.
- 5️⃣ Implementation: Actions executed and tracked.
- 6️⃣ Verification: Auditor confirms results.
- 7️⃣ Trend Analysis: Quarterly reviews identify systemic issues.
8. Sample Record (Excerpt)
| ID | Type | Description | Date Identified | Owner | Root Cause | Corrective Action Plan | Target Date | Status | Verification |
|---|---|---|---|---|---|---|---|---|---|
| NCR-2025-009 | Minor NC | Translator used personal email to submit client file instead of secure TMS portal | 2025-09-10 | Project Manager | Policy awareness gap and incomplete onboarding for freelancers | 1) Update translator onboarding checklist; 2) Mandatory TMS use training; 3) Add portal access audit reminder in workflow | 2025-09-25 | Closed | Verified by Internal Auditor on 2025-09-28 audit logs confirm 100% TMS usage since training |
9. Continuous Improvement Roadmap
| Improvement Initiative | Benefit | Effort | Owner | Deadline | Evidence |
|---|---|---|---|---|---|
| Automated Tracking System | Improves visibility and reminder automation | Medium | ISMS Manager + IT Support | Q4 2025 | System dashboard & alerts |
| Root-Cause Training | Enhances investigation quality | Low | ISMS Manager + HR | Q2 2026 | Attendance records |
| Quarterly NC Trend Reviews | Identifies systemic issues early | Low | ISMS Manager | Q1 2026 | Trend reports |
| Integrate ISMS with QMS | Aligns ISO 9001 & 27001 cycles | Medium | CEO / ISMS Manager | Q3 2026 | Joint review records |
10. Compliance Mapping
- Clause 10.2 – Nonconformity and Corrective Action
- Clause 10.1 – Continual Improvement
- Annex A Controls 5.35 – 5.37 – Review, Compliance, and Operating Procedures
How Canadian Cyber Helps Language Service Providers Stay Compliant
- Nonconformity & Corrective Action Templates (CC-ISMS-010)
- Audit Finding & Corrective Action Tracking Dashboards
- Root-Cause and Process Improvement Workshops
- Virtual CISO (vCISO) Oversight & Readiness Support
- Integration of ISMS and Quality Management (QMS) Processes
We turn nonconformities into measurable progress and progress into client confidence.
Ready to Build Your ISO 27001-Compliant Improvement Cycle?
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