How to Implement the ISO 27001 Standard

nqa.com/en-gb/certification/standards/iso-27001/implementation

Benefits of Implementation

Information security is becoming increasingly important to organizations, and the adoption

of ISO 27001 therefore more and more common. Most organizations now recognise that
it is not a question of if they will be affected by a security breach; it is a question of when.

Implementing an ISMS and achieving certification to ISO 27001 is a significant

undertaking for most organizations. However, if done effectively, there are significant
benefits for those organizations that are reliant on the protection of valuable or sensitive
information. These benefits typically fall into three areas:

COMMERCIAL

Having independent third-party endorsement of an ISMS can provide an organization with

a
competitive advantage, or enable it to ‘catch up’ with its competitors. Customers that are
exposed to significant information security risks are increasingly making certification to
ISO 27001 a requirement in tender submissions.

Where the customer is also certified to ISO 27001 they will, in the medium term, choose
to work only with suppliers whose information security controls they have confidence in
and that have the capability to comply with their contractual requirements.

For organizations that want to work with this type of customer, having an ISO 27001
certified ISMS is a key requirement for sustaining and increasing their commercial
revenues.

OPERATIONAL

The holistic approach of ISO 27001 supports the development of an internal culture that
is alert to information security risks and has a consistent approach to dealing with them.
This consistency of approach leads to controls that are more robust in dealing with

1/28
threats. The cost of implementing and maintaining them is also minimised, and in the
event of them failing the consequences will be minimised and more effectively mitigated.

PEACE OF MIND

Many organizations have information that is mission-critical to their operations, vital to

sustaining their competitive advantage or an inherent part of their financial value.

Having a robust and effective ISMS in place enables business owners and managers with
responsibility for managing risks to sleep easier at night knowing that they are not
exposed to a risk of heavy fines, major business disruption or a significant hit to their
reputation.

In today’s knowledge-based economy, almost all organizations are reliant on the security
of key information. Implementation of a formal ISMS is a proven method of providing such
security.

ISO 27001 is an internationally recognised framework for a best practice ISMS and
compliance with it can be independently verified to both enhance an organization’s image
and give confidence to its customers.

KEY PRINCIPLES AND TERMINOLOGY

The core purpose of an ISMS is to provide protection for sensitive or valuable information.
Sensitive information typically includes information about employees, customers and
suppliers. Valuable information may include intellectual property, financial data, legal
records, commercial data and operational data.

The types of risk that sensitive and valuable information are subject to can generally be
grouped into three catagories:
Confidentiality - where one or more persons gain unauthorised access to
information.

Integrity - where the content of the information is changed so that it is no longer

accurate or complete.

​Availability - where access to the information is lost or hampered.

These information security risk types are commonly referred to as “CIA”.

Risks in information security typically arise due to the presence of threats and
vulnerabilities to assets that process, store, hold, protect or control access to information
which gives rise to incidents.

Assets in this context are typically people, equipment, systems or infrastructure.

2/28
Information is the data set(s) that an organization wants to protect such as employee
records, customer records, financial records, design data, test data etc.

Incidents are unwanted events that result in a loss of confidentiality (e.g. a data breach),
integrity (e.g. corruption of data) or availability (e.g. system failure).

Threats are what cause incidents to occur and may be malicious (e.g. a burglar),
accidental (e.g. a key stroke error) or an act of God (e.g. a flood).

Vulnerabilities such as open office windows, source code errors, or the location of
buildings next to rivers, increase the likelihood that the presence of a threat will result in
an unwanted and costly incident.

In information security, risk is managed through the design, implementation and

maintenance of controls such as locked windows, software testing or the siting of
vulnerable equipment above ground floor levels.

An ISMS that complies with ISO 27001 has an interrelated set of best practice processes
that facilitate and support the appropriate design, implementation and maintenance of
controls.

The processes that form part of an ISMS are usually a combination of existing core
business processes (e.g. recruitment, induction, training, purchasing, product design,
equipment maintenance, service delivery) and those specific to maintaining and
improving information security (e.g. change management, information back-up, access
control, incident management, information classification).

Risk Based Thinking/Audits

Audits are a systematic, evidence-based, process approach to evaluation of your

Information Security Management System. They are undertaken internally and externally
to verify the effectiveness of the ISMS. Audits are a brilliant example of how risk-based
thinking is adopted within Information Security Management.

1ST PARTY AUDITS - INTERNAL AUDITS

Internal audits are a great opportunity for learning within your organization. They provide
time to focus on a particular process or department in order to truly assess its
performance. The purpose of an internal audit is to ensure adherence to policies,
procedures and processes as determined by you, the organization, and to confirm
compliance with the requirements of ISO 27001.

AUDIT PLANNING

Devising an audit schedule can sound like a complicated exercise. Depending on the
scale and complexity of your operations, you may schedule internal audits anywhere from
every month to once a year. There’s more detail on this in section 9 – performance
evaluation.

3/28
RISK-BASED THINKING

The best way to consider frequency of audits is to look at the risks involved in the process
or business area to be audited. Any process which is high risk, either because it has a
high potential to go wrong or because the consequences would be severe if it did go
wrong, should be audited more frequently than a low risk process.

How you assess risk is entirely up to you. ISO 27001 doesn’t dictate any particular
method of risk assessment or risk management.

2ND PARTY - EXTERNAL AUDITS

Second party audits are usually carried out by customers or by others on their behalf, or
you may carry them out on your external providers. 2nd party audits can also be carried
out by regulators or any other external party that has a formal interest in an organization.

You may have little control over the timing and frequency of these audits, however
establishing your own ISMS will ensure you are well prepared for their arrival.

3RD PARTY - CERTIFICATION AUDITS

Third party audits are carried out by external bodies, usually UKAS accredited
certification bodies such as NQA.
The certification body will assess conformance to the ISO 27001:2013 standard. This
involves a representative of the certification body visiting the organization and assessing
the relevant system and its processes. Maintaining certification also involves periodic
reassessments.

Certification demonstrates to customers that you have a commitment to quality.

CERTIFICATION ASSURES

regular assessment to continually monitor and improve processes.

credibility that the system can achieve its intended outcomes.

reduced risk and uncertainty and increase market opportunities.

consistency in the outputs designed to meet stakeholder expectations.

Process Based Thinking/Audits

A process is the transformation of inputs to outputs, which takes place as a series of

steps or activities which result in the planned objective(s). Often the output of one
process becomes an input to another subsequent process. Very few processes operate in
isolation from any other.

“Process: set of interrelated or interacting activities that use inputs to deliver an intended
result.”
ISO 27001:2013 Fundamentals and Vocabulary

4/28
Even an audit has a process approach. It begins with identifying the scope and criteria,
establishes a clear course of action to achieve the outcome and has a defined output (the
audit report). Using the process approach to auditing also ensures the correct time and
skills are allocated to the audit. This makes it an effective evaluation of the performance
of the ISMS.

“Consistent and predictable results are achieved more effectively and efficiently when
activities are understood and managed as interrelated processes that function as a
coherent system.”

ISO 27001:2013 FUNDAMENTALS AND VOCABULARY

Understanding how processes interrelate and produce results can help you to identify
opportunities for improvement and thus optimise overall performance. This also applies
where processes, or parts of processes, are outsourced.

Understanding exactly how this affects or could affect the outcome and communicating
this clearly to the business partner (providing the outsourced product or service) ensures
clarity and accountability in the process.
The final process step is to review the outcome of the audit and ensure the information
obtained is put to good use. A formal Management Review is the opportunity to reflect on
the performance of the ISMS and to make decisions on how and where to improve. The
Management Review process is covered in more depth in Section 9 – performance
evaluation.

The 10 Clauses of ISO 27001:2013 ISO 27001 is made of up 10 sections known as

Clauses.

As with most other ISO management system standards, the requirements of ISO 27001
that need to be satisfied are specified in Clauses 4.0 – 10.0. Unlike most other ISO
management system standards, an organization must comply with all of the requirements
in Clauses 4.0 – 10.0; they cannot declare one or more clauses as being not applicable to
them.

In ISO 27001, in addition to Clauses 4.0 - 10.0 there is a further set of requirements
detailed in a section called Annex A, which is referenced in Clause 6.0. Annex A contains
114 best practice information security controls. Each of these 114 controls needs to be
considered. To be compliant with ISO 27001 the organization must implement these
controls, or an acceptable justification must be given for not implementing a particular
control.

The following parts of this guide provide an overview explanation of the purpose of each
clause, highlight the type of evidence an auditor would expect to see to confirm that you
comply, and give tips on effective ways to comply with the requirements.

5/28
Section 1: Scope

The Scope section of ISO 27001 sets out

the purpose of the standard;

the types of organizations it is designed to apply to; and

the sections of the standard (called Clauses) that contain requirements that an
organization needs to comply with in order for the organization to be certified as
“conforming” to it (i.e. being compliant).

ISO 27001 is designed to be applicable to any type of organization. Regardless of size,

complexity, industry sector, purpose or maturity, your organization can implement and
maintain an ISMS that complies with ISO 27001.

Section 2: Normative References

6/28
In ISO standards, the Normative References section lists any other standards that contain
additional information that is relevant to determining whether or not an organization
complies with the standard in question. In ISO 27001 only one document is listed – ISO
27000 Information Technology - Overview and vocabulary.

Some of the terms used or requirements detailed in ISO 27001 are explained further in
ISO 27000. Reference to ISO 27000 is very useful in helping you to understand a
requirement better or identify the best way to comply with it.

TIP – External auditors will expect you to have taken the information contained in ISO
27000 into account in the development and implementation of your ISMS.

Section 3: Terms and Definitions

There are no terms and definitions given in ISO 27001. Instead, reference is made to the
most current version of ISO 27000 Information Security Management Systems –
Overview and vocabulary. The current version of this document contains 81 definitions of
terms that are used in ISO 27001.

In addition to the terms explained in the “Key Principles and Terminology” section
above, the most important terms used in ISO 27001 are:

‘Access Controls’ - processes that ensure that only the people that need to have access
to a certain asset have that access and the “need”is determined with reference to both
business and security requirements.
‘Effectiveness’ - the extent to which planned activities (e.g. processes, procedures) are
executed as planned or specified and achieve the planned results or outputs.

‘Risk’ - a combination of the likelihood of an information security event occurring and the
resulting consequences.

‘Risk Assessment’ - the process of identifying risks, analysing the level of risk posed by
each risk and evaluating whether additional action is needed to reduce each risk to a
more tolerable or acceptable level.

‘Risk Treatment’ - processes or actions that reduce identified risks to a tolerable or

acceptable level.

‘Top Management’ - the group of individuals who are the most senior decision makers in
an organization. They are likely to be accountable for setting its strategic direction and for
determining and achieving stakeholder objectives.

When you write your Information Security Management System documentation, you don’t
have to use these exact terms. However, it does help to clarify the meaning and intention
if you can define the terms you have used. Providing a glossary within your system
documentation may be useful.

7/28
Section 4: Context of the Organizations
The purpose of your ISMS is to protect your organization’s Information Assets, so that the
organization can achieve its goals.
How you go about this and the specific areas of priority will be driven by the context your
organization operates in, both:

Internal – the things over which the organization has some control; and

External – the things over which the organization has no direct control.

A careful analysis of the environment your organization operates in is fundamental to

identifying the inherent risks posed to the security of your Information Assets. The
analysis is the foundation that will enable you to assess what processes you need to
consider adding or strengthening to build an effective ISMS.

INTERNAL CONTEXT
The following are examples of the areas that can be considered when assessing the
internal issues that may have a bearing on the ISMS risks:

Maturity: are you an agile start-up with a blank canvas to work on, or a 30+ year old
institution with well-established processes and security controls?

Organization culture: is your organization relaxed about how, when and where
people work, or extremely regimented? Might the culture resist the implementation
of Information Security controls?

Management: are there clear communication channels and processes from the
organization’s key decision makers through to the rest of the organization?

Resource size: are you working with an Information Security Team, or is one person
doing it all?

Resource maturity: are the available resources (employees/ contractors)

knowledgeable, fully trained, dependable and consistent, or are personnel
inexperienced and constantly changing?

Information asset formats: are your information assets mainly stored in hard-copy
(paper) format, or are they stored electronically on a server on-site, or in remote
cloud-based systems?

Information asset sensitivity/value: does your organization have to manage highly

valuable or particularly sensitive information assets?

Consistency: do you have uniform processes in place across the organization, or a

multitude of different operating practices with little consistency?

8/28
 Systems: does your organization have many legacy systems running on software
versions that are no longer supported by the manufacturer, or do you maintain the
most up to date and best available technology?

System complexity: do you operate one main system that does all the heavy lifting,
or multiple departmental systems with limited information transfer between them?

Physical space: do you have a dedicated secure office facility, or do you operate in
a space shared with other organizations?

EXTERNAL CONTEXT

The following are examples of the areas that can be considered when assessing the
external issues that may have a bearing on the ISMS risks:

Competition: do you operate in a rapidly changing and innovative market, requiring

many system upgrades to stay competitive, or in a mature, stable market with little
innovation year-to-year?

Landlord: do you need approval to upgrade physical security?

Regulators / enforcement bodies: is there a requirement in your sector to make

regular statutory changes, or is there little oversight from regulators in your market
sector?

Economic/political: do currency fluctuations impact your organization; will Brexit in

the UK have an impact?

Environmental considerations: is your site on a flood plain with the server(s) located
in a basement? Are there factors making your site(s) a possible target for a break-in
or a terrorist attack (e.g. in a prominent city centre location; next to a possible
target)?

Prevalence of information security attacks: does your organization operate in a

sector which regularly attracts interest from hackers (criminals, hacktivists)?

Shareholders: are they very concerned about the vulnerability of the organization to
data breaches? How concerned are they about the cost of the organization’s efforts
to improve its information security?

INTERESTED PARTIES

An interested party is anyone who is, can be, or perceives themselves to be affected by
an action or omission of your organization. Your interested parties will become clear
through the process of carrying out a thorough analysis of internal and external issues.

They will probably include shareholders, landlords, regulators, customers, employees and
competitors and may extend to the general public and the environment, depending on the
nature of your business. You don’t have to try to understand or satisfy their every whim,

9/28
but you do have to determine which of their needs and expectations are relevant to your
ISMS. SCOPE OF THE MANAGEMENT SYSTEM
To comply with ISO 27001, you must document the scope of your ISMS. Documented
scopes typically describe:

the boundaries of the physical site or sites included (or not included);

the boundaries of the physical and logical networks included (or not included);

the internal and external employee groups included (or not included);

the internal and external processes, activities or services included (or not included);
and

key interfaces at the boundaries of the scope.

If you want to prioritise resources by building an ISMS that doesn’t cover all of your
organization, selecting a scope that is limited to managing key stakeholder interests is a
pragmatic approach. This can be done by including only specific sites, assets, processes
and business units or departments. Some examples of scope statements:

“All operations carried out by the IT Department”

“Support and management of email”

“All equipment, systems, data and infrastructure in the organization’s Data Centre
based at the Basingstoke site”

TIP – Document or maintain a file of all of the information collated in your analysis of your
organization’s context and interested parties such as:

Discussions with a senior representative of the organization, e.g. an MD, CEO or

CTO.

Minutes of meetings or business plans.

A specific document that identifies internal/external issues and interested parties

and their needs and expectations e.g. a SWOT analysis, PESTLE study, or high-
level business risk assessment.

Section 5: Leadership

THE IMPORTANCE OF LEADERSHIP

Leadership in this context means active involvement in setting the direction of the ISMS,
promoting its implementation and ensuring appropriate resources are made available.
This includes:
ensuring that the ISMS objectives are clear and aligned with overall strategy;

10/28
 that there is clarity on responsibilities and accountabilities;

that risk-based thinking is at the heart of all decision making; and

that there is clear communication of this information to all individuals within your
ISMS scope.

ISO 27001 places great importance on active engagement by Top Management in the
ISMS, based on
the assumption that the engagement of Top Management is crucial in ensuring the
effective implementation and maintenance of an effective ISMS by the wider employee
group.

INFORMATION SECURITY POLICY

A vital responsibility of the leadership is to establish and document an Information
Security Policy that is aligned with the key aims of the organization. At the top level it
must either include objectives, or a framework (guidelines) for setting them. To
demonstrate that it is aligned with your organization’s context and the requirements of key
stakeholders, it is recommended that it makes reference to, or contains a summary of, the
principal issues and requirements it is designed to manage. It must also include a
commitment to:

satisfying applicable requirements relating to Information Security, such as legal

requirements, customer expectations and contractual commitments; and

the continual improvement of your ISMS.

The Information Security Policy may refer to, or include sub-policies that cover, the key
controls of the organization’s ISMS. Examples include: the selection of suppliers critical to
Information Security, the recruitment and training of employees, clear desk and clear
screen, cryptographic controls, access controls etc.

To demonstrate the importance of the Information Security Policy, it is advisable that it is

authorised by the most senior member of your Top Management or each member of the
Top Management team.

TIP - To ensure your Information Security Policy is well communicated and available to
interested parties, it is a good idea to:
include it in induction packs and presentations for new employees and contractors;

post the key statement on internal noticeboards, intranets and your organization’s
website; and

make compliance with it and/or support for it a contractual requirement for

employees, contractors and information security-critical suppliers.

ROLES AND RESPONSIBILITIES

11/28
For Information Security activities to form part of the day-to- day activities for most people
within the organization, the responsibilities and accountabilities they have must be
defined and clearly communicated.

Although there is no requirement in the standard for a nominated Information Security

representative, it may be helpful for some organizations to appoint one to lead an
information security team to coordinate training, monitoring controls and reporting on the
performance of the ISMS to the Top Management. This individual may already hold
responsibility for data protection or IT services.

However, to carry out their role effectively they will ideally be a member of the Top
Management team and either have a strong technical knowledge of information security
management or access to individuals who do.
EVIDENCING LEADERSHIP TO AN AUDITOR

The Top Management will be the group of individuals who set the strategic direction and
approve resource allocation for the organization or business area with your ISMS scope.
Depending on how your organization is structured, these individuals may or not be the
day-to-day management team. An auditor will typically test leadership by interviewing one
or more members of your Top Management and assessing their level of involvement and
participation in the:

evaluation of risks and opportunities;

establishment and communication of policies;

setting and communication of objectives;

review and communication of system performance; and

allocation of appropriate resources, accountabilities and responsibilities.

TIP – Before your external audit, identify who from your Top Management will meet with
the external auditor and prepare them for the interview with a dry run-through of the likely
questions they will be asked.

Section 6: Planning
ISO 27001 is at heart a risk management tool that steers an organization to identify the
drivers of its information security risks from the full range of sources. As such, the
underlying purpose of an ISMS is to:

identify the strategically important, blatantly obvious, and hidden but dangerous
risks;

ensure that an organization’s day-to-day activities and operating processes are

designed, directed and resourced to inherently manage those risks; and

12/28
 automatically respond and adapt to changes to cope with new risks and continually
reduce the organization’s risk exposure.

Having a detailed action plan that is aligned, updated and supported by regular reviews
and monitoring is crucial, and provides the best evidence to the auditor of clearly defined
system planning.

RISK ASSESSMENT

Risk assessment is at the core of any effective ISMS. Even the most well-resourced
organization cannot completely eliminate the possibility of an information security incident
occurring. For all organizations, risk assessment is essential to:
increase the likelihood of identifying all potential risks through the involvement of
key individuals using systematic assessment techniques;

allocate resources to tackle the highest priority areas; and

make strategic decisions on how to manage significant information security risks

that will more likely realize their objectives.

Most risk assessment frameworks consist of a table containing the results of elements 1-
4 with a supplementary table or matrix covering point 5.

An external auditor will expect to see a record of your risk assessment, an assigned
owner for each risk identified and the criteria you have used.

TIP – Annex A (8.1.1) contains a requirement to maintain a list of information assets,

assets associated with information (e.g. buildings, filing cabinets, laptops) and information
processing facilities. If you complete your risk assessment by systematically assessing
the risks posed to every item on this list, then you will have satisfied two requirements
within the same exercise. Furthermore, for each item on the list, if you assign an owner
you will also have satisfied another requirement in Annex A (8.1.2). As the asset owner is
also likely to be the risk owner, this helps prevent duplication and potential confusion.
ISO 27005 – Information security risk management offers guidance on developing a risk
assessment technique for your organization. Whichever technique you select or develop,
it should include the following key elements:

1. Provide a prompt for systematic identification of risks (e.g. reviewing assets, groups
of assets, processes, types of information) one at a time, checking each for the
presence of common threats and vulnerabilities, and recording the controls you
currently have in place to manage them.

2. Provide a framework for assessing the likelihood of each risk occurring on a

consistent basis (e.g. once a month, once a year).Provide a framework for
assessing the consequences of each risk occurring on a consistent basis (e.g.
£1,000 loss, £100,000 loss).

13/28
 3. Provide a framework for scoring or categorizing each risk identified on a consistent
basis (e.g. 1-10, high/medium/low), taking into account your assessment of the
likelihood and consequences.

4. Set out documented criteria which specifies, for each risk score or category, what
type of action needs to be taken and the level or priority assigned to it.

RISK TREATMENT

For each risk identified in your risk assessment, you must apply consistent criteria to
determine whether you should:

accept the risk; or

treat the risk (called “Risk Treatment”)

The Risk Treatment options available are normally one of the following:

Avoidance – stop undertaking the activity or processing the information that is

exposed to the risk.

Removal – eliminate the source of the risk.

Change the likelihood – implement a control that makes it less likely that an
information security incident will occur.

Change the consequences – implement a control that will lessen the impact if an
incident occurs.

Transfer the risk – outsource the activity or process to a third party that has greater
capability to manage the risk.

Accept the risk – if there is no practical risk treatment available to the organization,
or the cost of the risk treatment is judged to be greater than the cost of the impact,
you may make an informed decision to accept the risk. This would need to be
approved by Top Management.

An external auditor will expect to see a Risk Treatment Plan (e.g. an action list) that
details the risk treatment actions you have implemented or plan to implement. The plan
must be sufficiently detailed to enable the implementation status of each action to be
verified. There will also need to be evidence that this plan has been approved by the
assigned risk owners and Top Management.

ANNEX A AND THE STATEMENT OF APPLICABILITY

All Risk Treatment options (with the exception of acceptance) involve the implementation
of one or more controls. Annex A to ISO 27001 contains a list of 114 best practice
information security controls. You will need to consider whether to implement each of
these controls when formulating your Risk Treatment Plan.

14/28
The description of most of the 114 controls is fairly vague, so it is strongly recommended
that you review ISO 27002 which contains more information on best practice ways of
implementing them.

As evidence of you having completed this assessment, an external auditor will expect you
to produce a document called a Statement of Applicability. Within this, for each of the 114
controls you must record:
whether it is applicable to your activities, processes and information security risks;

whether you have implemented it or not; and

if you have deemed it not applicable, your justification for doing so.

For most organizations, the majority of the 114 controls will be applicable, and they are
likely to have already implemented a number of them to some degree.

TIP - Your Statement of Applicability does not need to an overly complex document. A
simple table with column headings Control, Applicable?, Implemented?, and Justification
will suffice. It is also advisable to record some information on how the control has been
applied (e.g. reference a procedure or policy) to help you more readily answer any
questioning from your external auditor.

INFORMATION SECURITY OBJECTIVES AND PLANNING TO ACHIEVE THEM

At relevant levels within your organization you need to have a documented set of
information security- related objectives. These can be at a top level and apply
organization-wide (e.g. “achieve ISO 27001 certification”) or departmental (e.g. “complete
Information Security Briefings for all new starters within 1 week of their start date”).

Each objective you set must:

be measurable;

be aligned with your Information Security Policy;

take account of the organization’s information security requirements; and

take account of the output from the risk assessment and risk treatment process.

Typical objectives that are relevant to information security include:

Not exceeding a defined frequency of certain types of information security incidents.

Achieving a measurable level of compliance with information security controls.

Providing a defined availability of information services.

Not exceeding a measurable number of data errors.

15/28
 Making improvements to available resources through recruitment, training or
acquisition.

Implementation of new controls.

Achieving compliance with information security- related standards.

Each objective must be communicated to relevant persons. The objectives must be

updated when necessary to keep them relevant and to assess performance against them.

For each of the objectives you need to plan how you are going to achieve them.
This includes determining:
what needs to be achieved;

what resources are assigned;

who has ownership or primary responsibility for delivering against the objective;

whether there is a target date for completion or just an ongoing requirement; and

the method of assessing performance against the objective (i.e. what is your
measure).

TIP - Effective ways to communicate Information Security Objectives include covering

them in induction training, setting them as employee objectives or including them in
employee appraisals, establishing them in SLAs with suppliers, or evaluating
performance against them in supplier performance reviews.

ISO 27001 A GUIDE TO ANNEX A

ISO 27001:2013 is the international standard which outlines best practice for an
Information Security Management System (ISMS). If you are familiar with our previous
implementation guide available here, then you will have already examined the clauses
contained within the standard. You would have also learned that this standard follows a
risk- based approach when considering the information security of an organization. This
requires the identification of security risks and then the selection of appropriate controls to
reduce, eliminate or manage those risks.

The Standard has the controls required to meet those risk requirements at Annex A. In
total there are 114 controls sub-divided in to 14 different categories. When considering
these controls, it is important to note that they are simply possibilities or options.

When conducting the risk process; the risk identified should have appropriate controls
which have been selected from the list in Annex A. Not every control can be
implemented. For example; if your organization does not have premises and operate
remotely then using some controls from the physical security domain would not be
appropriate.

16/28
Similarly, the move to cloud based solutions attracts a fresh look at existing controls
within the Operations and Communications Security domains.

CATEGORIES OF CONTROLS

As mentioned the Annex contains 14 categories. They are listed as follows:

A.5 Information security policies:

Guidance on how policies are written and reviewed.

A.6 Organization of information security:

How to assign responsibilities for security tasks including:

Contact with third parties appropriate to the functionality of the ISMS

Security considerations for projects

Mobile and Teleworking policy provision

A.7 Human resource security:

Security considerations for recruiting and maintaining a workforce including

security considerations on departure within contracts.

A.8 Asset management:

Securing information assets through inventory and ownership of assets.

Includes labelling of information and media.

A.9 Access control:

Controlling access to information within an organization so that there is no

unauthorised access to information. Further; only appropriate entities have
administrative access where it is necessary.

A.10 Cryptography:

The encryption of sensitive information and the management of encryption

keys.

A.11 Physical and environmental security:

The security of premises, equipment and physical copy information.

17/28
 A.12 Operations security:

Securing information processing facilities; includes technical security

considerations such as malware protection, back up procedures, event capture
etc.

A.13 Communications security:

Security of networks; includes the use of electronic messaging.

A.14 System acquisition, development and maintenance:

Security in development operations. Ensures that security considerations are

considered fully in the development process.

A.15 Supplier relationships:

Agreements to include in contracts with any external entity. All third parties
should be subject to scrutiny before information is shared. These controls help
to manage that process.

A.16 Information security incident management:

Guide on how to identify, report and record information incidents. Provides

functionality to allow appropriately responsible person to learn from incidents.

A.17 Information security aspects of business continuity management:

Ensuring that your organization is well prepared to survive disruption and

ensure plans are viable.

A.18 Compliance:

Identify laws and regulations which will shape your organization and record any
review of your management system or security from an external source.

FURTHER CONSIDERATIONS

Before the certification audit, an organization must have produced a Statement of

Applicability (SoA).
The requirement is outlined at Clause 6 of ISO 27001. The SoA must contain at least 114
entries with each of the Categories and Controls listed. Once this is done then each
control must be either selected and justified or excluded with similar justification. All SoA
documents must be able to demonstrate that consideration has been given to each
control. This means that an SoA must contain all entries outlined, simply listing selected
controls will not meet the requirement.

18/28
This example here shows how a difference between a selected and excluded control
could be presented within a SoA:

Those controls which are selected will likely form part of the risk treatment evidence and
should be recorded as such. Typically this will be held within a risk register though can be
held as separate documentation. The methodology will vary between different
organizations; though demonstrating that the controls within Annex A are implemented is
a consistent need.

The security provisions of the standard are not something that an organizations IT or
Security team must adhere to alone. The standard requires that all aspects of the
organization be considered when examining the risks and treatment of risk.

The best placed individuals to remedy and risk issues may not always be in the IT
Department; the exact composition and siting of risk treatment will vary from one
organization to the other. Risk ownership is vital in ensuring the controls are subject to
review.

FINALLY
Annex A controls are just some of the options available to an organization. Additional
security controls not specifically outlined in Annex A can be used to provide treatment to
an identified risk. So long as the Clauses and Controls within the Standard are addressed
as appropriate, the ISMS will be functioning and provide good levels of Information
Security.

Section 7: Support

Clause 7 concerns itself with resources. This applies to people, infrastructure and
environment as much as physical resources, materials, tools etc. There is also a renewed
focus on knowledge as a significant resource within your organization. When planning
your quality objectives, a major consideration will be the current capacity and capability of
your resources as well as those you may need to source from external suppliers /
partners.

19/28
To implement and maintain an effective ISMS you need to have supporting resources in
place. These resources will need to be sufficiently:

capable – if they are equipment or infrastructure; and

competent – if they are people.

at Management Review meetings.

​COMPETENCE

The implementation of effective information security controls relies heavily on the

knowledge and skills of your employees, suppliers and contractors. To be certain of an
appropriate knowledge and skills base you need to:
define what knowledge and skills are required;

determine who needs to have the knowledge and skills; and

set out how you can assess or verify that the right people have the right knowledge
and skills.

Your auditor will expect you to have documents detailing your knowledge and skills
requirements. Where you believe the requirements are satisfied this will need to be
supported with records such as training certificates, course attendance records or internal
competency assessments.

TIP – Most organizations that already use tools such as training/skills matrices,
appraisals or supplier assessments can satisfy the requirement for competence records
by expanding the areas covered to include information security.
AWARENESS

In addition to ensuring specific competence of key personnel in relation to information

security, the wider group of employees, suppliers and contractors will need to be aware of
the basic elements of your ISMS. This is central to establishing a supportive culture within
the organization.

All staff, suppliers and contractors should be aware of the following:

That you have an ISMS and why you have one.

That you have an Information Security Policy and which particular elements of it are
relevant to them.

How they can contribute to your organization protecting its valuable information and
what they need to do to help the organization achieve its information security
objectives.

Which policies, procedures and controls are relevant to them and what the
consequences are of not complying with them.

20/28
TIP – The communication of this information can normally be done through existing
processes and documents such as inductions, employment contracts, toolbox talks,
supplier agreements, employee briefings or updates.

COMMUNICATION

To enable the processes in your ISMS to work effectively you will need to ensure you
have communication activities that are well planned and managed. ISO 27001 details
these concisely by requiring you to determine:

what needs to be communicated;

when it needs to be communicated;

to whom it needs be communicated;

who is responsible for communication; and

what is the processes for communication.

TIP – If your communication requirements are well defined in your processes, policies
and procedures then you do not need to do any more to satisfy this requirement. If they
aren’t then you should consider documenting your key communication activities in the
form of a table or procedure that includes the headings detailed above. Remember, the
content of these documents also needs to be communicated!

DOCUMENTED INFORMATION

To be of use, the documented information you use to implement and maintain your ISMS
needs to:
be accurate;

be understandable to the individuals who use it regularly or occasionally; and

support you to comply with legal requirements, manage information security risks
and achieve your objectives.

So that your documented information always satisfies these requirements you will need to
have processes in place to ensure that:

documented information is reviewed where required by appropriate individuals

before it is released into general circulation;

access to documented information is controlled so that it cannot be changed

accidentally, corrupted, deleted or accessed by individuals to whom it is not
appropriate;

information is deleted securely or returned to its owner when there this a

requirement to do this; and

21/28
 you can track changes to information to guarantee that the process is in control.

The source of your documented information may be either internal or external, so your
control processes need to manage documented information from both sources.

TIP – Organizations that have good document control typically have one or more of the
following in place:
A single person or small team responsible for ensuring that new/modified
documents are reviewed before they are issued, are stored in the right location, are
withdrawn from

circulation when superseded and that a register of changes is maintained.

An electronic document management system that contains automatic workflows and

controls.

Robust electronic data back-up and hard-copy file archiving/ storage processes.

Strong employee awareness of document control, record keeping and information

access/retention requirements.

Section 8: Operation

So, after all the planning and risk assessment, we’re ready to move on to the “do” stage.
Clause 8 is all about having appropriate control over the creation and delivery your
product or service.

Managing your information security risks and achieving your objectives requires the
formalisation of your activities into a set of clear and coherent processes.

Many of these processes are likely to exist already (e.g. induction, training) and will
simply need modifying to include elements relevant to information security. Other
processes may happen in an ad-hoc fashion (e.g. supplier approvals), while some may
not currently exist at all (e.g. internal audit).

To implement effective processes the following practices are crucial:

1. Processes are created by adapting or formalising an organization’s “business as
usual” activities.

2. Systematic identification of the information security risks relevant to each process.

3. Clear definition and communication of the set of activities required to manage the
associated information security risks when an event occurs (e.g. a new employee
joining the company).

4. Clear assignment of the responsibilities for carrying out related activities.

22/28
 5. Adequate allocation of resources to ensure that related activities can take place as
and when required.

6. Routine assessment of the consistency with which each process is followed and its
effectiveness in managing relevant information security risks.

TIP – For each process, designate an individual as accountable for ensuring that steps 2-
6 happen. This individual is often referred to as the Process Owner.

INFORMATION SECURITY RISK ASSESSMENT

The risk assessment methods and techniques described in Clause 6 must be applied to
all processes, assets, information and activities within the organization’s ISMS scope.

Since risks are not static, the results of these assessments must be reviewed at
appropriate frequencies. This is usually at least annually, or more frequently if the
assessment identifies the presence of one or more significant risks. Risks should also be
reviewed whenever:
any Risk Treatment actions are completed (see below);

there are changes to the organization’s assets, information or processes;

new risks are identified; or

experience or new information indicates that the likelihood and consequence of any
identified risk has changed.

TIP – To ensure your risk assessment process covers the types of events that would
require a review, you should also take into consideration the Annex A controls for
Technical Vulnerability Management (A.12.6), Security in Development and Support
Processes (A.14.2) and Supplier Service Delivery Management (A.15.2).

INFORMATION SECURITY RISK TREATMENT

The risk treatment plan you develop cannot simply remain as a statement of intent; it
must be implemented. Where changes are needed to take into account new information
about risks and changes to your risk assessment criteria, the plan needs to be updated
and re-authorised.

The impact of the plan must also be assessed and the results of this assessment
recorded. This may be done as part of your Management Review or Internal Audit
Processes or by using technical assessments such as network penetration tests, supplier
audits or unannounced third part audits.

Section 9: Performance Evaluation

There are three main ways in which the performance of an ISMS is evaluated. These are:

monitoring the effectiveness of the ISMS controls;

23/28
 through internal audits; and

at Management Review meetings.

MONITORING, MEASUREMENT, ANALYSIS AND EVALUATION

Your organization will need to decide what needs to be monitored to be assured that your
ISMS process and information security controls are operating as intended. It is impractical
for an organization to monitor everything all the time; if you attempt to do so, it is likely
that the volume of data would be so great that it would be virtually impossible to use it
effectively. Therefore, in practice, you will need to take an informed decision about what
to monitor.

The following considerations will be important:

Which processes and activities are subject to the most frequent and significant
threats?

Which processes and activities have the most significantly inherent vulnerabilities?

What is practical to monitor and generate meaningful and timely information from?

With each monitoring process you put in place, for it to be effective you must clearly
define:

how the monitoring is undertaken (e.g. is this defined in a procedure);

when it is undertaken;

who is responsible for undertaking it;

how are the results reported, when, to whom and what do they do with them; and

if the monitoring results identify unacceptable performance, what is the escalation

process or procedure to deal with this situation.

To demonstrate to an auditor that you have appropriate monitoring processing in place,

you will need to retain records of monitoring results, analysis, evaluation reviews and any
escalation activities.

INTERNAL AUDITS

The purpose of internal audits is to test your ISMS processes for weaknesses and identify
opportunities for improvement. They are also an opportunity to provide a reality check to
Top Management on how strongly the ISMS is performing. When done well, internal
audits can ensure that there are no surprises at your external audits.
The internal audits you perform should check:

how consistently processes, procedures and controls are followed and applied;

24/28
 how successful your processes, procedures and controls are at generating the
intended results; and

whether your ISMS remains compliant with ISO 27001 and the requirements of
interested parties.

To ensure that audits are undertaken to a high standard and in a way that is seen to
add value, they need to be undertaken by individuals who:

are respected;

competent

understand the requirements of ISO 27001; and

can quickly interpret your documentation and are well- practiced in sound auditing
techniques and behaviours.

Most importantly of all, they need to be allocated sufficient time to do the audit and
be assured of cooperation from relevant employees. You must maintain a plan for
carrying out your internal audits. An external auditor will expect this plan to ensure
that all of your ISMS processes are audited over a three-year cycle and that
processes which:

have shown evidence of poor performance (i.e. through previous audits, or

monitoring results or information security incidents); and/or

manage the most significant information security risks

are audited at a higher frequency.

The external auditor will also expect that any actions identified from audits are recorded,
reviewed by appropriate employees and actions implemented in a timely manner to rectify
any significant issues. They should make an allowance in the close-out time for any
improvement opportunities identified that require significant investment in resources.

MANAGEMENT REVIEW

Management Review is an essential element of an ISMS. It is the formal point at which

Top Management reviews the effectiveness of the ISMS and ensures its alignment to the
organization’s strategic direction. Management Reviews must take place at planned
intervals and the overall review programme (i.e. one meeting or several meetings) must
at a minimum cover a list of core areas specified within clause 9.3 of the standard.
It is not essential for one single Management Review meeting to take place covering the
full agenda.

If you currently hold a range of meetings that cover the inputs between them, there is no
specific need to duplicate them.

25/28
You will need to retain documented information on your Management Reviews. These
would normally be minutes of meetings or perhaps call recordings if you carry out
conference calls. These do not need to be extensive notes, but they must contain a
record of any decisions made and actions agreed, ideally with responsibilities and
timescales.

TIP – If you decide to adapt your existing schedule of management meetings and these
meetings cover a number of areas, you may want to consider summarising the areas that
these meetings cover in the form of a table or procedure so that it is clear to you and an
auditor which meetings cover each of the required review areas.

Section 10: Improvement

The key aim of implementing an ISMS should be to reduce the likelihood of information
security events occurring and their impact. No ISMS is likely to be perfect. However, a
successful ISMS will improve over time and increase the organization’s resilience to
information security attacks.

NONCONFORMITY AND CORRECTIVE ACTION

One of the main drivers of improvement is to learn from security incidents, issues
identified in audits, performance issues identified from monitoring, complaints from
interested parties and ideas generated at management reviews.

For each learning opportunity identified you must maintain a record of:
what occurred;

if the event had undesirable consequences, what action was taken to contain and
mitigate those;

the root cause of the event (if determined);

the action taken to eliminate the root cause (if needed); and

an assessment of the effectiveness of any action taken.

ROOT CAUSE ANALYSIS

To identify effective corrective action, it is strongly advisable to complete a root cause

analysis of the issue that occurred. If you don’t get to the bottom of why or how it
happened, then it is likely that whatever fix you implement will not be fully effective. A
simple approach such as “5 Whys” is a good root cause analysis tool: start with the issue,
then ask “Why” enough times to reach the root cause. Usually 5 times of asking is
enough, but for more complex problems you may need to dig deeper.

For example:

Problem statement:
The organization was infected by the Wannacry virus

26/28
Why?
Someone clicked on a link in an email and it downloaded the virus and infected their PC

Why?
They had not received any training in clicking on links in emails they are not expecting to
receive

Why?
The training manager is on maternity leave and the organization has not implemented
cover for them

Why?
The maternity leave process is not covered in the Change Management Procedure and
so a risk assessment was not completed to identify any information security risks.

TIP – You may not have sufficient resources to undertake root cause analysis for every
event. To prioritise your efforts, you should consider first completing a simple risk
assessment of an event and then undertake root cause analysis only for those that are
medium or high risk.

Get the Most From Your Management System

Top Tips for the successful implementation of an ISMS

1. Start with “Why?”. Make sure the reasons for implementing an ISMS are clear and
aligned with your strategic direction, otherwise you risk not getting the critical buy-in
from Top Management.

2. Next consider “What for?”. Implementing and maintaining an ISMS requires

significant commitment, so make sure your scope is broad enough to cover the
critical information that needs protecting, but is not so broad that you do not have
sufficient resources to implement and maintain it.

3. Get all of your key stakeholders involved at the appropriate times. Top Management
for context, requirements, policy and objectives setting; managers and employees
with valuable knowledge for risk assessments, process design and procedure
writing.

4. Communicate extensively throughout the process to all of your stakeholders. Let

them know what you are doing, why you’re are doing it, how you plan to do it and
what their involvement will be. Provide regular progress updates.

5. Get external help where you need it. Do not fail for lack of in-house technical skills
or knowledge. Management of information security risks often requires specialist
knowledge. However, be sure to check the credentials of a third party before
engaging them.

27/28
 6. Keep your processes and supporting documentation simple. It can develop to
become more extensive over time if needed.

7. Design and implement rules you can follow in practice. Don’t make the mistake of
documenting an over-elaborate rule that no-one can follow. It is better to accept a
risk and to continue to look for ways to manage it.

8. Remember your suppliers. Some suppliers will help you enhance your ISMS, some
will increase your risk. You need to ensure any high-risk suppliers have controls in
place that are at least as good as yours. If they don’t then look for alternatives.

9. Train, train and train again. Information Security is likely to be a new concept for
many or most of your employees. People may need to change habits ingrained over
many years. A single awareness briefing is unlikely to be sufficient.

10. Remember to allocate sufficient resources to routinely test your controls. The
threats your organization faces will constantly change and you need to test whether
you are able to respond to those threats.

You can download a PDF of this implementation guide here: NQA ISO 27001
Implementation Guide.

28/28