ISO 27001 & BS 25999

If you think writing a bunch of information security documents is enough to get ISO 27001 certificate , you’re wrong. You need to implement all the activities described in your documentation, but that’s not all – you also need to follow certain steps in the final phase of your ISO 27001 project.

ISO 27001 certification process

Let’s start first with the certification process itself – it is divided in two steps: Stage 1 audit and Stage 2 audit. In Stage 1 audit (also called Documentation review) the certification auditor checks whether your documentation is compliant with ISO 27001; in Stage 2 audit (also called Main audit) the auditor checks whether all your activities are compliant with both ISO 27001 and your documentation.

Therefore, you need to pay attention to both writing appropriate documentation for your needs, and to really committing to implementation information security in your company. For details on required documentation, steps in the audit and how to deal with nonconformities read this article How to get certified against ISO 27001?.

Mandatory steps for finishing the implementation

After finishing all your documentation and implementing it, you need to perform these mandatory steps in your ISO 27001 project:

• Internal audit
• Management review
• Corrective and preventive actions

The purpose of internal audit is that someone independent checks out whether your Information Security Management System (ISMS) is working properly. Read more about internal audit here Dilemmas with ISO 27001 & BS 25999-2 internal auditors.

Management review is actually a formal way for management to take into account all the relevant facts about information security and make appropriate decisions. The point with ISO 27001 is to reach such decisions as part of a regular decision making process.

Finally, the company needs to correct all the problems detected by internal auditors, managers or someone else, and document how these problems were resolved – this process is called corrective actions. It is recommended to take preventive actions too – to try to prevent problems before they happen (something the certification auditor will appreciate quite a lot).

How to test ISO 27001 implementation?

However, before undertaking these mandatory steps, it is useful to check whether everything is in place. This step is not required by ISO 27001 (at least not in such an explicit way), but in my opinion it significantly increases the chances for successful certification.

Doing the ISO 27001 test (or check) means that everyone who has a role in ISMS has to check whether everything he/she is responsible for really functions as required by the standard, and by the company’s documentation.

Such test/check is not the same thing as internal audit because during internal audit it is the auditor who goes through the company checking out things, while what I’m talking about here is that almost every employee needs to think hard whether he/she has done really everything that is required. In such a way you not only decrease the chances for something going wrong, but also raise the awareness of your employees.

All these steps might seem complicated or you may think of them as costly overhead. But, believe me, they do serve their purpose – if implemented properly, you will see that they will actually increase your level of information security.

If you think your management doesn’t have a clue what information security is all about, keep in mind that misunderstanding usually goes both ways: management often thinks you have no idea about what is appropriate for the business.

So before suggesting to your management to start implementing your information security / ISO 27001 project, you should learn about your management’s way of thinking. Here are the five main concerns your management will have when you approach them:

Is it really necessary? You have to be prepared to present the main benefits of information security, because otherwise the management won’t understand its purpose. In most cases you can choose among the following benefits: (1) Compliance with various legislation and contractual requirements etc., (2) Achieving competitive advantage in the marketplace, (3) Lowering expenses by decreasing the number of incidents, and (4) Optimizing your business operations by clearly defining tasks and responsibilities. Read more on these four benefits here: Four key benefits of ISO 27001 implementation.

Does it fit into our company strategy? Strategic fit is very important for your top management – one of your management’s primary concerns is how to keep your company competitive for a longer time period. Therefore, you have to do your homework – find out how information security can underpin certain elements of your company’s corporate strategy.

How to decrease the costs? One of the most misunderstood aspects of information security is that most of the problems (i.e. incidents) happen not because of technology, but because of human behavior. Therefore, most of the investments needed will be in defining new policies and procedures, and training and awareness programs which will prevent such incidents from happening – such investments are usually far cheaper than new technology.

Sometimes, investment in technology will also be needed – in such cases you can try to calculate the Return on Security Investment. For instance, you might try to calculate the damage that would be caused by a fire, and calculate the investment needed to prevent such damage. Just be sure not to exaggerate here, because you’ll lose your management’s confidence.

How to make sure we’ve achieved what we wanted? First of all, you need to help your management set very clear objectives – usually, those objectives will derive from the four benefits mentioned above. The second step is to set up a measurement system which will define how to measure whether the company achieved the set objectives; that system must involve clear responsibilities of who will make the reports, in which form, and who is going to read them and interpret them. Finally, a system must be in place to correct all the deviations from the objectives (be sure that such deviations will certainly happen).

What risks are involved? Management usually wants to know what is the likelihood of failure of the investment they have made. Here you need to explain to them the balance between the risks you will identify during the risk assessment and the security measures your company will invest in – the higher the investment, the smaller the chances that something will go wrong. Of course, overinvesting is not a solution, and this is why you need to leave the decision about acceptable risks to the management – your role is to present them the risks and potential security measures in an objective manner. The decision what to do with those risks is up to the management.

The point here is – the problem is not that management doesn’t want to invest in information security, but that it is either uninformed about it, or that you cannot speak the same language with your management.

By understanding the five basic issues your management is concerned with and by establishing appropriate communication with them, you’ll dramatically increase your chances for your information security project.

Your management has given you the task to implement business continuity, but you’re not really sure how to do it? Although it is not an easy task, you can use the BS 25999-2 methodology to make your life easier – here are the main steps necessary to implement this standard:

1. Obtain management support

Although this is not a mandatory step in BS 25999-2, this is certainly the crucial step in the beginning – if the management does not understand the benefits of business continuity and is not committed to this project, your project is most probably going to fail.

2. Treat it as a project

It will take quite a lot of time and resources to set up your business continuity management system (BCMS) – you have to define clearly what needs to be done, in which timeframe, and what are the roles in project implementation. In other words, you have to apply project management methods.

3. Define objectives and scope; write down a BCM Policy

You have to define what is it you want to achieve with the BCMS – compliance, decreasing the level of risk, requirements of your customers/partners etc. You also have to define what you are going to include in your BCMS – the whole organization, or just a part of it. For instance, you may decide that you are going to include only your data centre if you are providing hosting services to your customers. All of these have to be documented in the BCM Policy.

4. Defining roles and responsibilities for BCMS

Because the BCMS is going to become a permanent activity in your organization, you have to define clear responsibilities for it, especially for the “sponsor” of the BCMS (someone accountable for the BCMS but not engaged in day-to-day BCMS activities) and “BCM coordinator”, “BCM manager” or something similar to it – one or more persons with active duties regarding the BCMS. It is the best to document these roles and responsibilities in your BCM Policy.

5. Implement mandatory procedures

BS 25999-2 requires the following four mandatory procedures to be implemented: document and records control, internal audit, preventive and corrective actions – these procedures are actually the foundation of your management system, similarly to ISO 27001 or ISO 9001.

6. Perform business impact analysis and risk assessment

Through business impact analysis you have to indentify the critical activities, their maximum tolerable period of disruption, the dependencies of those critical activities (including dependencies to suppliers and outsourcing partners), and set recovery time objectives.

By doing the risk assessment you actually find out what could be the causes to the disruption of your critical activities – those could be natural, but also man-made activities (either malicious or accidental). You would also need to do risk treatment, which means you need to decide how to decrease the possibility of something going wrong. Unfortunately, the risk assessment and treatment are not very well defined in this standard, so you might take a look at ISO 27001 which describes them in more detail.

7. Determining the business continuity strategy

Before you proceed with writing business continuity plans, you actually have to determine which resources you will need for resuming your critical activities – which people, locations, data, hardware, software, suppliers, outsourcing partners etc.

The business continuity strategy has to determine not only what you need, but also how you are going to provide those resources.

8. Developing incident management plans and business continuity plans

The purpose of incident management plans is to describe how you are going to respond directly to the occurrence of an incident (e.g. fire, earthquake, bomb threat, power failure etc.) in order to prevent it to spread, and to try to decrease its direct effects.

On the other hand, the purpose of business continuity plans is to describe how you are going to recover your critical activities – how you are going to put all the resources you have prepared into action. This means you have to describe who is going to do what, in which time, using which data and technology, in order to put your organization back into operation.

All of these plans have to be described in detail, because they must be executed even in case the main personnel is not available – therefore, they have to be written in such a way that somebody else would be able to execute them.

9. Training and awareness

You need to define the level of competence needed for the execution of business continuity plans in case of disruption, and then train all the personnel (both employees and external partners) to reach this level of competence.

However, this is not enough – you also need to explain to your personnel why BCM is necessary. Let’s face it – your business continuity plans will be used maybe only once in a life time, so most people consider it as a waste of time. Therefore, you have to explain to them why such a thing must exist. (See also How to deal with BCM sceptics)

10. BCMS exercising

If you thought you have written your plans perfectly, you are probably wrong – it is almost impossible to write a plan with no errors right at the beginning. This is why exercising is a mandatory part of BCMS – you have to test your plans in a situation that more or less resembles a real disruption. Only then will you find out what you planned well, and what you didn’t.

11. Maintaining and reviewing the BCMS

Another way to keep your BCMS up-to-date is by defining the intervals at which you will review your business continuity plans, but also other arrangements (e.g. contracts with suppliers and outsourcing partners, training and awareness etc.). There are all sorts of changes in the environment that are threatening your documentation to become obsolete – it is enough for an employee to leave the company to have an unusable telephone number in a plan if that person had a role in the BCMS.

It is also mandatory to perform post-incident review if an incident really occurred – the purpose is to find out how the organization really reacted – did it follow the plans or not.

12. Internal audit

The purpose of internal audit is to find out if there is something wrong, in an objective manner – the internal auditor should be a person who can find out if something is done wrong within your BCMS in order to correct it. If done properly, internal audit could be one of the best ways to improve your BCMS. (Read Dilemmas with ISO 27001 & BS 25999-2 internal auditors)

13. Management review

As said before, it is very important to get your management involved in the project – management review is designed exactly for that. The standard requires the management to examine all the relevant facts about BCM and decide whether it has fulfilled its purpose. Once that is done, the management has to decide which improvements must be made.

14. Preventive and corrective actions

The best thing would be to prevent mistakes (or in terms of BS 25999, the “non-conformities”) from happening – this is what the preventive actions are used for – they are a systematic way of correcting things before a problem occurs. Similar to preventive actions, there are also corrective actions which resolve the problem that has already occurred.

Now the question is – why would you use BS 25999-2? Although it is (still) not an international standard, it is the most popular standard for business continuity worldwide – the abovementioned steps are designed by the best business continuity experts, so if you want to implement the best accepted practices for business continuity, you have to look no further.

Here you can download the diagram of BS 25999-2 implementation process showing all these steps together with the required documentation (registration required).

If you are starting to implement ISO 27001, you are probably looking for an easy way to implement it. Let me disappoint you: there is no easy way to do it. However, I’ll try to make your job easier – here is the list of sixteen steps you have to go through if you want to achieve ISO 27001 certification:

1. Obtain management support

This one may seem rather obvious, and it is usually not taken seriously enough. But in my experience, this is the main reason why ISO 27001 projects fail – management is not providing enough people to work on the project or not enough money. (Read Four key benefits of ISO 27001 implementation for ideas how to present the case to management.)

2. Treat it as a project

As already said, ISO 27001 implementation is a complex issue involving various activities, lots of people, lasting several months (or more than a year). If you do not define clearly what is to be done, who is going to do it and in what time frame (i.e. apply project management), you might as well never finish the job.

3. Define the scope

If you are a larger organization, it probably makes sense to implement ISO 27001 only in one part of your organization, thus significantly lowering your project risk. (Problems with defining the scope in ISO 27001)

4. Write an ISMS Policy

ISMS Policy is the highest-level document in your ISMS – it shouldn’t be very detailed, but it should define some basic issues for information security in your organization. But what is its purpose if it is not detailed? The purpose is for management to define what it wants to achieve, and how to control it. (Information security policy – how detailed should it be?)

5. Define the Risk Assessment methodology

Risk assessment is the most complex task in the ISO 27001 project – the point is to define the rules for identifying the assets, vulnerabilities, threats, impacts and likelihood, and to define the acceptable level of risk. If those rules were not clearly defined, you might find yourself in a situation where you get unusable results. (Risk assessment tips for smaller companies)

6. Perform the risk assessment & risk treatment

Here you have to implement what you defined in the previous step – it might take several months for larger organizations, so you should coordinate such an effort with great care. The point is to get a comprehensive picture of the dangers for your organization’s information.

The purpose of the risk treatment process is to decrease the risks which are not acceptable – this is usually done by planning to use the controls from Annex A.

In this step a Risk Assessment Report has to be written, which documents all the steps taken during risk assessment and risk treatment process. Also an approval of residual risks must be obtained – either as a separate document, or as part of the Statement of Applicability.

7. Write the Statement of Applicability

Once you finished your risk treatment process, you will know exactly which controls from Annex you need (there are a total of 133 controls but you probably wouldn’t need them all). The purpose of this document (frequently referred to as SoA) is to list all controls and to define which are applicable and which are not, and the reasons for such a decision, the objectives to be achieved with the controls and a description of how they are implemented.

The Statement of Applicability is also the most suitable document to obtain management authorization for the implementation of ISMS.

8. Write the Risk Treatment Plan

Just when you thought you resolved all the risk-related documents, here comes another one – the purpose of the Risk Treatment Plan is to define exactly how the controls from SoA are to be implemented – who is going to do it, when, with what budget etc. This document is actually an implementation plan focused on your controls, without which you wouldn’t be able to coordinate further steps in the project.

9. Define how to measure the effectiveness of controls

Another task that is usually underestimated. The point here is – if you can’t measure what you’ve done, how can you be sure you have fulfilled the purpose? Therefore, be sure to define how you are going to measure the fulfilment of objectives you have set both for the whole ISMS, and for each applicable control in the Statement of Applicability.

10. Implement the controls & mandatory procedures

Easier said than done. This is where you have to implement the four mandatory procedures and the applicable controls from Annex A.

This is usually the most risky task in your project – it usually means the application of new technology, but above all – implementation of new behaviour in your organization. Often new policies and procedures are needed (meaning that change is needed), and people usually resist change – this is why the next task (training and awareness) is crucial for avoiding that risk.

11. Implement training and awareness programs

If you want your personnel to implement all the new policies and procedures, first you have to explain to them why they are necessary, and train your people to be able to perform as expected. The absence of these activities is the second most common reason for ISO 27001 project failure.

12. Operate the ISMS

This is the part where ISO 27001 becomes an everyday routine in your organization. The crucial word here is: “records”. Auditors love records – without records you will find it very hard to prove that some activity has really been done. But records should help you in the first place – using them you can monitor what is happening – you will actually know with certainty whether your employees (and suppliers) are performing their tasks as required.

13. Monitor the ISMS

What is happening in your ISMS? How many incidents do you have, of what type? Are all the procedures carried out properly?

This is where the objectives for your controls and measurement methodology come together – you have to check whether the results you obtain are achieving what you have set in your objectives. If not, you know something is wrong – you have to perform corrective and/or preventive actions.

14. Internal audit

Very often people are not aware they are doing something wrong (on the other hand they sometimes are, but they don’t want anyone to find out about it). But being unaware of existing or potential problems can hurt your organization – you have to perform internal audit in order to find out such things. The point here is not to initiate disciplinary actions, but to take corrective and/or preventive actions. (Dilemmas with ISO 27001 & BS 25999-2 internal auditors)

15. Management review

Management does not have to configure your firewall, but it must know what is going on in the ISMS, i.e. if everyone performed his or her duties, if the ISMS is achieving desired results etc. Based on that, the management must make some crucial decisions.

16. Corrective and preventive actions

The purpose of the management system is to ensure that everything that is wrong (so-called “non-conformities”) is corrected, or hopefully prevented. Therefore, ISO 27001 requires that corrective and preventive actions are done systematically, which means that the root cause of a non-conformity must be identified, and then resolved and verified.

Hopefully this article clarified what needs to be done – although ISO 27001 is not an easy task, it is not necessarily a complicated one. You just have to plan each step carefully, and don’t worry – you’ll get your certificate.

Here you can download the diagram of ISO 27001 implementation process showing all these steps together with the required documentation.

You have already implemented ISO 9001? You have heard that ISO 27001 might be a good idea? But how can something that has to do with quality help you implement information security?

It can, more than you may think. ISO 9001 specifies how the quality management systems (QMS) must look like, while ISO/IEC 27001 specifies the information security management systems (ISMS). Therefore, the “management systems” part is the same – so what is it actually?

The philosophy of management systems has grown from the theory developed by W. Edwards Deming during the second half of 20th century, and is based on the Plan-Do-Check-Act cycle. Basically, this cycle consists of the following: in the Plan phase you have to plan what you want to achieve with the management system, in the Do phase you implement it, in the Check phase you constantly monitor whether you have achieved what you planned, and in the Act phase you make improvements, i.e. fill the gap between what you have planned and what you have achieved.

Although this cycle was invented with quality management in mind, it was established as a foundation for all other management systems – information security (ISO/IEC 27001), environment (ISO 14001), business continuity (BS 25999-2), etc. It means that some of the elements you have implemented for the quality management system according to ISO 9001 you can use for the information security management system as well – here is the list:

• Document management – the procedure used for document management in QMS can be used for the same purpose in ISMS, with only minor adjustments
• Internal audit – the same procedure can be used for both QMS and ISMS, although the internal audit itself would usually be done by different people since it is not very likely that one person would have deep enough knowledge of both information security and quality
• Corrective and preventive actions – the procedure used for QMS can be used for the same purpose in ISMS, although it is likely that different persons will be solving issues related to QMS or ISMS
• Human resources management – the same cycle of HR planning, training and evaluation is used for both management systems; naturally, the difference is in the profile of needed skills and knowledge
• Management review – the principles for management review are the same for both management systems; although it would not be recommendable to perform both reviews in parallel, management will already be accustomed to making decisions in QMS, so they will have better understanding of how to make decisions in the context of ISMS
• Setting the business goals and tracking whether they have been achieved – the same mechanism is laid down in both standards, so management will be used to such systematic planning

Therefore, if you have already implemented ISO 9001, you will have an easier job implementing ISO 27001 (and vice versa) – you could save up to 30% of time. Further, you will have cheaper certification audits since certification bodies are offering the so called “integrated audits”, which means they will do both ISO 9001 and ISO 27001 in the same audit, charging you a smaller fee compared to separated audits.

If your QMS is functioning well, you will find your ISMS project developing rather smoothly – management will have better understanding of potential business benefits, while all organizational units will be accustomed to the necessity of defining precise procedures, responsibilities and documentation.

Having a QMS indeed provides very good foundation for information security – if you already have ISO 9001, do give a serious thought to ISO 27001.