ISO 27001 Implementation Guide
ISO 27001 Implementation Guide
ISO 27001 Implementation Guide
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> ISO 27001:2013
IMPLEMENTATION GUIDE
ISO 27001 is the internationally-recognised standard for Information Security Management Systems (ISMS). It
provides a robust framework to protect information that can be adapted to all types and sizes of organization.
Organizations that have significant exposure to information-security related risks are increasingly choosing to
implement an ISMS that complies with ISO 27001.
4 ISO 27001:2015
27001:2013 IMPLEMENTATION GUIDE
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:
THE TYPES OF
RISKS THAT
SENSITIVE
The types of risks
that
ANDsensitive
VALUABLE and
valuable information
INFORMATION
are subject to
AREgenerally
SUBJECT beTO
can Confidentiality Integrity Availability
CAN GENERALLY
grouped into three
categories:
BE GROUPED where one or where the content of the where access to the
more persons gain information is changed information is lost
INTO THREE
unauthorised access so that it is no longer or hampered.
CATEGORIES: to information. accurate or complete.
These information security risk types are commonly referred to Vulnerabilities such as open office windows, source code
as “CIA”. errors, or the location of buildings next to rivers, increase
the likelihood that the presence of a threat will result in an
Risks in information security typically arise due to the unwanted and costly incident.
presence of threats and vulnerabilities to assets that
process, store, hold, protect or control access to information In information security, risk is managed through the design,
which gives rise to incidents. implementation and maintenance of controls such as locked
windows, software testing or the siting of vulnerable equipment
Assets in this context are typically people, equipment, systems above ground floor levels.
or infrastructure.
An ISMS that complies with ISO 27001 has an interrelated
Information is the data set(s) that an organization wants to set of best practice processes that facilitate and support the
protect such as employee records, customer records, financial appropriate design, implementation and maintenance of
records, design data, test data etc. controls. The processes that form part of an ISMS are usually
a combination of existing core business processes (e.g.
Incidents are unwanted events that result in a loss of
recruitment, induction, training, purchasing, product design,
confidentiality (e.g. a data breach), integrity (e.g. corruption
equipment maintenance, service delivery) and those specific
of data) or availability (e.g. system failure).
to maintaining and improving information security (e.g. change
Threats are what cause incidents to occur and may be management, information back-up, access control, incident
malicious (e.g. a burglar), accidental (e.g. a key stroke error) or management, information classification).
an act of God (e.g. a flood).
In brief:
ESTABLISH
INTERESTED ISMS INTERESTED
PARTIES PARTIES
Plan Do
MAINTAIN IMPLEMENT
AND IMPROVE AND OPERATE
THE ISMS THE ISMS
INFORMATION
SECURITY Act Check MANAGED
REQUIREMENTS INFORMATION
AND MONITOR SECURITY
EXPECTATIONS AND REVIEW
THE ISMS
Plan-Do-Check-Act is an example of a closed-loop system. This ensures the learning from the ‘do’ and ‘check’ stages are
used to inform the ‘act’ and subsequent ‘plan’ stages. In theory this is cyclical, however it’s more of an upward spiral as the
learning moves you on each time you go through the process.
£
£
VULNERABILITIES
clauses as being not applicable to them. THREATS INFORMATION RISKS
CONFIDENTIALITY
In ISO 27001, in addition to Clauses 4.0-
INTEGRITY
10.0 there is a further set of requirements
detailed in a section called Annex A, AVAILABILITY
which is referenced in Clause 6.0. Annex
A contains 114 best practice information CONTROL
ACCESS
security controls. Each of these 114
controls needs to be considered. To be
ASSETS
compliant with ISO 27001 the organization
must implement these controls, or an CONTROLS
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
CONTINUAL
each clause, highlight the type of evidence MONITOR
IMPROVEMENT
an auditor would expect to see to confirm
that you comply, and give tips on effective
ways to comply with the requirements.
CLAUSE 1:
SCOPE
The Scope section of ISO 27001 sets out
• the purpose of the standard;
‘Effectiveness’
– the extent to which planned activities (e.g. processes,
procedures) are executed as planned or specified and When you write your Information
achieve the planned results or outputs. Security Management System
documentation, you don’t have to
‘Risk’ use these exact terms. However, it
– a combination of the likelihood of an information security
event occurring and the resulting consequences. does help to clarify the meaning and
intention if you can define the terms
‘Risk Assessment’ you have used. Providing a glossary
– the process of identifying risks, analysing the level of risk within your system documentation may
posed by each risk and evaluating whether additional
action is needed to reduce each risk to a more tolerable or
be useful.
acceptable level.
• 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
• 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.
Most risk assessment frameworks consist of a 2 Provide a framework for assessing the likelihood
table containing the results of elements 1-4 with a of each risk occurring on a consistent basis
supplementary table or matrix covering point 5. (e.g. once a month, once a year).
An external auditor will expect to see a record of your risk 3 Provide a framework for assessing the
assessment, an assigned owner for each risk identified consequences of each risk occurring on
and the criteria you have used. a consistent basis (e.g. £1,000 loss,
£100,000 loss).
TIP – Annex A (8.1.1) contains a requirement to maintain
a list of information assets, assets associated with 4 Provide a framework for scoring or categorizing
information (e.g. buildings, filing cabinets, laptops) and each risk identified on a consistent basis (e.g.
information processing facilities. If you complete your risk 1-10, high/medium/low), taking into account your
assessment by systematically assessing the risks posed assessment of the likelihood and consequences.
to every item on this list, then you will have satisfied two
requirements within the same exercise. Furthermore, for 5 Set out documented criteria which specifies,
each item on the list, if you assign an owner you will also for each risk score or category, what type of
have satisfied another requirement in Annex A (8.1.2). action needs to be taken and the level or priority
As the asset owner is also likely to be the risk owner, this assigned to it.
helps prevent duplication and potential confusion.
Awareness
To implement and maintain an In addition to ensuring specific competence of key personnel
effective ISMS you need to have in relation to information security, the wider group of
employees, suppliers and contractors will need to be aware of
supporting resources in place. These the basic elements of your ISMS. This is central to establishing
resources will need to be sufficiently: a supportive culture within the organization.
• capable – if they are equipment or All staff, suppliers and contractors should be aware of the
infrastructure; and following:
• competent – if they are people. • That you have an ISMS and why you have one.
• at Management Review meetings. • 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.
Competence • Which policies, procedures and controls are relevant to them
and what the consequences are of not complying with them.
The implementation of effective information security controls
relies heavily on the knowledge and skills of your employees, TIP – The communication of this information can normally
suppliers and contractors. To be certain of an appropriate be done through existing processes and documents such
knowledge and skills base you need to: as inductions, employment contracts, toolbox talks, supplier
agreements, employee briefings or updates.
• 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 Communication
have the right knowledge and skills.
To enable the processes in your ISMS to work effectively you
Your auditor will expect you to have documents detailing will need to ensure you have communication activities that are
your knowledge and skills requirements. Where you believe well planned and managed. ISO 27001 details these concisely
the requirements are satisfied this will need to be supported by requiring you to determine:
with records such as training certificates, course attendance
records or internal competency assessments. • what needs to be communicated;
• when it needs to be communicated;
TIP – Most organizations that already use tools such as • to whom it needs be communicated;
training/skills matrices, appraisals or supplier assessments can • who is responsible for communication; and
satisfy the requirement for competence records by expanding • what is the processes for communication.
the areas covered to include information security.
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!
1 Processes are created by adapting or formalising an • any Risk Treatment actions are completed (see below);
organization’s “business as usual” activities. • there are changes to the organization’s assets, information or
processes;
2 Systematic identification of the information security risks • new risks are identified; or
relevant to each process. • experience or new information indicates that the likelihood
and consequence of any identified risk has changed.
3 Clear definition and communication of the set of activities
required to manage the associated information security TIP – To ensure your risk assessment process covers the types
risks when an event occurs (e.g. a new employee joining of events that would require a review, you should also take into
the company). consideration the Annex A controls for Technical Vulnerability
Management (A.12.6), Security in Development and Support
4 Clear assignment of the responsibilities for carrying out Processes (A.14.2) and Supplier Service Delivery Management
related activities. (A.15.2).
Nonconformity and
Corrective Action Root cause analysis
One of the main drivers of improvement is to learn from security To identify effective corrective action, it is strongly
incidents, issues identified in audits, performance issues advisable to complete a root cause analysis of the issue
identified from monitoring, complaints from interested parties and that occurred. If you don’t get to the bottom of why or
ideas generated at management reviews. how it happened, then it is likely that whatever fix you
implement will not be fully effective. A simple approach
For each learning opportunity identified you must maintain a such as “5 Whys” is a good root cause analysis tool:
record of: start with the issue, then ask “Why” enough times
to reach the root cause. Usually 5 times of asking is
• what occurred; enough, but for more complex problems you may need
• if the event had undesirable consequences, what action was to dig deeper.
taken to contain and mitigate those;
• the root cause of the event (if determined); For example:
• the action taken to eliminate the root cause (if needed); and
• an assessment of the effectiveness of any action taken. Problem statement:
The organization was infected by the Wannacry
virus
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.
1. Start with “Why?”. Make sure the 6. Keep your processes and supporting
reasons for implementing an ISMS are documentation simple. It can develop
clear and aligned with your strategic to become more extensive over time if
direction, otherwise you risk not needed.
getting the critical buy-in from Top
Management. 7. Design and implement rules you
can follow in practice. Don’t make
2. Next consider “What for?”. the mistake of documenting an over-
Implementing and maintaining an ISMS elaborate rule that no-one can follow. It
requires significant commitment, so is better to accept a risk and to continue
make sure your scope is broad enough to look for ways to manage it.
to cover the critical information that
needs protecting, but is not so broad 8. Remember your suppliers. Some
that you do not have sufficient resources suppliers will help you enhance your
to implement and maintain it. ISMS, some will increase your risk. You
need to ensure any high-risk suppliers
3. Get all of your key stakeholders have controls in place that are at least
involved at the appropriate times. Top as good as yours. If they don’t then look
Management for context, requirements, for alternatives.
policy and objectives setting; managers
and employees with valuable knowledge 9. Train, train and train again. Information
for risk assessments, process design Security is likely to be a new concept
and procedure writing. for many or most of your employees.
People may need to change habits
4. Communicate extensively throughout ingrained over many years. A single
the process to all of your stakeholders. awareness briefing is unlikely to be
Let them know what you are doing, why sufficient.
you’re are doing it, how you plan to do
it and what their involvement will be. 10. Remember to allocate sufficient
Provide regular progress updates. resources to routinely test your controls.
The threats your organization faces will
5. Get external help where you need it. constantly change and you need to test
Do not fail for lack of in-house technical whether you are able to respond
skills or knowledge. Management of to those threats.
information security risks often requires
specialist knowledge. However, be sure
to check the credentials of a third party
before engaging them.
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