In this Help Net Security interview, Robin Long, founder of Kiowa Security, shares insights on how best to approach the implementation of the ISO/IEC 27001 information security standard.
Long advises organizations to establish a detailed project roadmap and to book certification audits at an early stage. He also recommends selecting an internal team that includes a leader with the ISO 27001 Lead Implementer qualification and suggests that in some cases, the best approach to the standard may be to start by prioritizing a limited number of “security wins” before embarking on full implementation.
A few general points about ISO 27001, before getting onto the questions:
1. The documentation behind ISO/IEC 27001:2022 (“ISO 27001”) is broken into two main parts: ISO/IEC 27001 itself, which contains the primary guidance, and a ‘guidance document’ called ISO/IEC 27002, which lists suggested information security controls that may be determined and implemented based on the risk analysis that is carried out according to the requirements of the primary document.
ISO 27001 is also supported by the other standards ISO/IEC 27000:2018 (IT security techniques) and ISO/IEC 27005:2022 (Information security, cybersecurity, and privacy protection), among others.
All these are developed and maintained by the International Organization for Standardization (ISO), which is based in Geneva, Switzerland.
2. Although there are a number of things that you are obliged to do if you’re seeking certified conformity to the standard, it is actually quite flexible about the details. Even the “requirements” – the obligatory clauses in the 27001 document – generally allow a fairly broad range of interpretation. This makes sense when you think that ISO 27001 has been developed as a one-size-fits-all system for all types and sizes of organization that handle sensitive information.
When you look at it like that, it immediately becomes less intimidating.
3. If you decide to go ahead and implement ISO 27001, it’s highly recommended to put together a detailed road map that defines targets of what should be achieved by what date in the timeline of the project (Gantt charts are good for this – look them up!). This helps to keep the project under control and reduces the risk of time and budget overrun. Breaking the project up into weekly components also makes it less daunting.
4. You’ll also need to define a (small) group of people to carry out, maintain and be accountable for implementation of the standard. You might call this the ‘ISMS Team’ (where ISMS means Information Security Management System, another way to describe ISO 27001). This team should ideally incorporate expertise and experience in IT, business development and data protection, and have a channel to senior management.
How do you recommend organizations approach understanding and implementing ISO 27001’s wide range of controls and requirements, especially those new to information security management?
As a consultant myself, I’m aware of the conflict of interest, but I have to say that I do think it makes sense to hire external advice for assistance with implementation of ISO 27001, for internal audit, and interaction with certification auditors.
One of the main responsibilities of such an advisor is to assist with understanding of the standard and information security management generally, at both high and low levels. The range of ISO27002 controls – for example – is wide indeed, but a competent consultant will break them down into manageable portions that are taken on one by one, in a carefully planned order.
Whether or not you decide to hire a consultant, it’s a pretty good idea also to send the leader of the ISMS Team on an ISO2 7001 Lead Implementer (LI) course. These courses typically run for about three days, and they are helpful. Note that ISO 27001 requires the organisation to provide evidence of the competence of key participants in the project, and the LI qualification for a team member indicates a reasonable degree of knowledge and commitment regarding the standard.
Implementing ISO 27001 can be resource-intensive. What advice do you have for organizations, particularly SMEs, in effectively allocating resources and budget for ISO 27001 implementation?
It’s true that implementation of ISO 27001 necessarily consumes resources, in terms of money and other assets – particularly people’s time. The critical question is whether the resource cost is offset by perceived gains, and this is largely about efficiency of allocation. Among other methods that we can use to attempt to optimise this are:
1. Use of a roadmap – as mentioned above – that takes the organisation all the way through to the two-stage certification audit process at a granular (weekly) level.
2. Early selection of the certification auditor and agreement of tentative dates for the certification audits. The benefits of doing this include the psychological one of getting an end date in the diary to help define the project roadmap. The cost of certification audits is also an important part of the overall budget, and the certification body will provide quotes for these at this stage.
Note that along with the two initial certification audits, there are a couple of (roughly annual) surveillance audits and a recertification audit after three years. These audits all cost money, of course, and require budgeting.
3. Watching out for some of the less obvious costs, including the potential charges associated with:
- Legal work on modifications/additions to employment contracts, NDAs etc.
- Pen testing/vulnerability scanning if necessary
- Software that you choose to install e.g., anti-malware, IDS, etc.
What strategies can be employed to convince top management of the necessity and benefits of ISO 27001 compliance?
Consultancy companies love to answer this question – on their websites – with a list of bullet points.
However, I can tell you that in nearly all cases there is just a single key factor at play, and it is a commercial one: Potential important clients or partners have been identified that require certification to the standard. Organisations that operate in sensitive sectors (finance, critical infrastructure, healthcare…) have already learned this or are in the process of learning it, and don’t need to be told about it. If they don’t know, then by all means tell them!
Other reasons that I consider completely valid and credible include:
- Perceived improvement in the level of an organisation’s information security provides assurance to other stakeholders apart from clients – investors, senior management, regulators, suppliers and so on – regarding information security risks to the organisation.
- Implementation of ISO 27001 can help smaller companies with their expansion. For example, it can help with the development of sound HR policies, with procedures around business continuity, disaster recovery and change management, and several other areas.
- Note that ISO 27001 isn’t by any means just about personal data but is also concerned with other types of sensitive information, in particular intellectual property or “IP” (including trade secrets and source code). For many tech start-ups, these are the main assets of the business, and need to be well protected.
Risk management and performance evaluation are critical yet challenging aspects of ISO 27001. How should organizations approach these elements to ensure an effective Information Security Management System (ISMS)?
These are indeed arguably the core areas of ISO 27001. Among the critical things to remember regarding risk assessments are:
- You should really at least try to come up with all the possible information security risks (internal and external) that are or might be faced by your organisation. This is best done by brainstorming in a group based around the ISMS Team.
ISO 27001 fundamentally breaks down to: “What information security risks do we face? How should we best manage them?”
- Just as the chicken may come before the egg, note that what should happen in this case is that you identify the risks first and then select the controls that help to manage those risks.
You definitely don’t have to apply all of the controls, and nearly all organisations treat some, validly, as non-applicable in their Statement of Applicability. For example, businesses where all employees work remotely simply don’t have the full range of risks that can benefit from mitigation by the physical controls.
When it comes to performance evaluation, it’s largely a case of working through the relevant clauses and controls and agreeing how good a job the organisation is doing trying to meet the associated requirements. The ones that are selected for monitoring, measurement and evaluation will depend on the type and size of the organisation and its business objectives. These are basically key performance indicators (KPIs) for information security and might include supplier evaluations and documented events, incidents, and vulnerabilities.
Specifically for cloud solutions like Microsoft 365, what unique challenges do organizations face in implementing ISO 27001, and how can they be addressed?
The switch towards remote working and use of cloud resources has been quite disruptive for ISO 27001. The 2022 version has been somewhat adapted (via modifications to the controls) to reflect the change in working conditions. However, it still gives a lot of attention to traditional physical places of work, networks, and pre-SaaS style suppliers.
The big switch away from locally downloaded software to cloud services means that we need to take advantage of the flexibility of ISO 27001 to interpret the 27002 controls in a corresponding way, for example:
- Thinking less about networks and more about secure configuration of cloud resources.
- Focusing on aspects of the ‘supplier relationships’ controls that are relevant to SaaS suppliers.
- Remembering that if cloud resources are very important for handling and storage of sensitive data in your business, then the new control 5.23 (Information security for use of cloud services) is correspondingly important for your business and must be tackled carefully and rigorously. It almost definitely applies to you – and there’s a lot there.
- Note that business continuity/disaster recovery for an organisation with employees that work remotely using cloud services becomes largely a question of how the relevant cloud provider(s) manage backups, redundancy of storage/compute etc.
ISO 27001 requires a commitment to continuous improvement. How should organizations approach this, particularly regarding incident management and response?
This is an enigmatic section of clause 10 (Improvement) that organisations tend to struggle with (the second part is about dealing with non-conformities and is much clearer regarding what needs to be done).
It seems to me that the best approach is to raise the question of ‘how can we make the ISMS better?’ at the periodic ISMS management meetings, come up with some examples whereby this may be achieved and then provide any observed progress in the right direction. That means that by the time of the first follow-up (surveillance) audit you should be able to present a list of several potential improvements along with how they are being achieved.
I’d like to finish up by mentioning that nothing stops your organisation implementing ISO 27001 without getting the certification, or even doing a partial implementation. Many businesses like the concept of ISO 27001 but aren’t quite ready to commit fully. In that case, I highly recommend the following implementation model:
1. Decide which areas of information security are priorities for your organisation in terms of incremental increase in security, resources (money, time, personnel) required and ease of implementation. You can call these your ‘lowest-hanging security fruit’ if you must. Possible examples include access control, HR security or endpoint security.
2. Work through these one by one according to the relevant 27002 controls.
3. Once you have the highest priority areas covered off, start working on lower levels of priority.
4. After a few months of this, you may feel that ISO 27001 isn’t quite so formidable, and that you are ready to tackle it. Go for it!