This may be a strange question, but is it OK to audit the legal requirements by an internal auditor, by the review / scrutiny of all available / provided legal documents and records connected to EMS, and then make records of the audit and NC based upon the evidences found. There is no person as auditee in the entire audit process. No oral questions asked and no person answering?.
Please also note that auditor as defined in ISO9000:2005 is a person, while auditee is the organization / area being audited.
Please also note that auditor as defined in ISO9000:2005 is a person, while auditee is the organization / area being audited.