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security audit of a hypothetical supplier
Hi Victor
The audit should go on how the provider complies with the contract your company did pass with them. Controls A15.1.1 to A15.2.2 are pertinent for the security clauses when they are included in the SOA:
A15.1.1 Information policy for supplier relationship;
A15.1.2 Addressing security within supplier agreements;
A15.1.3 Information and communication technology supply chain;
A15.2.1 Monitoring and review supplier services;
A15.2.2 managing changes to supplier services.
Here is an article that is applicable to your situation: 6-step process for handling supplier security according to ISO 27001: https://advisera.com/27001academy/blog/2014/06/30/6-step-process-for-handling-supplier-security-according-to-iso-27001/
Best regards
Jean-Luc -
To whom to handover confidential data in case of a disaster?
As part of your business continuity plans, you have to define the deputies/substitutes for each and every person who perform certain important activity. Therefore, you have to define upfront who will be responsible to manage those important files in case the persons who are normally in charge for that would be unavailable.
This article can also help you: Business continuity plan: How to structure it according to ISO 22301 https://advisera.com/27001academy/knowledgebase/business-continuity-plan-how-to-structure-it-according-to-iso-22301/ -
Mandatory processes
There is a crucial difference between ISO 27001 and ISO 27002. The first one is a set of requirements for an information security management system. The second one a code of practice with a list of controls to operate and manage information security and can be uses without relation with ISO 27001.
SO 27001 requires an audit and a system of audits. This is a mandatory procedure to make sure the ISMS still complies with the documentation and, if certified, with the certificate.
This is not the case for ISO 27002 where the controls are to be selected them through a risk management process. None is, initially a mandatory procedure.
ISO 27002:2013 control 12.7.1 covers the risk that an audit would disturb the business process and the operation. So the intention is completely different to the requirement in ISO 27001 and there is no reason worry about.
The following references may help you further:
- ISO 27001 vs. ISO 27002 (103): https://advisera.com/27001academy/knowledgebase/iso-27001-vs-iso-27002/
- MANDATORY DOCUMENTED PROCEDURES REQUIRED BY ISO 27001 (108): https://advisera.com/27001academy/knowledgebase/list-of-mandatory-documents-required-by-iso-27001-2013-revision/
- How to maintain the ISMS after the certification (3): https://advisera.com/27001academy/blog/2014/07/14/how-to-maintain-the-isms-after-the-certification/ -
List of Legal, Regulatory, Contractual and Other Requirements
First of all, you should list laws and regulations that are applicable to your company; if you don't have supplier contracts you should list all your partners and customers with whom you have contracts or other arrangements. You should list only those that have an influence on your information security - e.g. those with requirements on backup, access control, physical protection, etc.
The whole point of this document is to list who is expecting what from your ISMS (i.e. interested parties and their requirements), so that you can start building the ISMS accordingly. See also this article: How to identify interested parties according to ISO 27001 and ISO 22301 https://advisera.com/27001academy/knowledgebase/how-to-identify-interested-parties-according-to-iso-27001-and-iso-22301// -
ISO 22301 Maintenance Audit requirements
In your first question I assume you refer to surveillance visits performed by certification bodies? They won't re-audit everything, just some areas of your BCMS they think are not developed enough. See also this article: Surveillance visits vs. certification audits https://advisera.com/27001academy/knowledgebase/surveillance-visits-vs-certification-audits/
There is no special preparation for those surveillance visits, you just have to make sure you do everything you have written in your BCMS documentation. Here is one article that speaks about ISO 27001, but it is completely applicable to ISO 22301 as well: How to maintain the ISMS after the certification https://advisera.com/27001academy/blog/2014/07/14/how-to-maintain-the-isms-after-the-certification/
Regarding the internal audit, it doesn't really matter whether it is performed internally or by an external party as long as in this internal audit the auditor checks whether your company (1) complies with ISO 22301, and (2) complies all the policies, procedures and plans you have written in your BCMS. This article can help you: How to make an Internal Audit checklist for ISO 27001 / ISO 22301 https://advisera.com/27001academy/knowledgebase/how-to-make-an-internal-audit-checklist-for-iso-27001-iso-22301/ -
Senior management does not want to spend money and resources
Of course they won't if they do not see a reason why they should do it. See also this article: ISO 27001 project How to make it work https://advisera.com/27001academy/blog/2013/04/22/iso-27001-project-how-to-make-it-work/
What level of training a Business Owner [who is in charge of many applications] is required to manage the risk in the applications with PII, with many partners?
Answer: In my view, business owners should be trained in the following: (1) to understand why the risk assessment and treatment are important for their job, and (2) how to assess the risks (i.e. which scales to use), and (3) how to treat the risks (i.e. which options exist). See also this article: How to organize initial risk assessment according to ISO 27001 and ISO 22301 https://advisera.com/27001academy/blog/2014/04/29/how-to-organize-initial-risk-assessment-according-to-iso-27001-and-iso-22301/
How to I bring these Business Owners on board to manage risk in their applications?
[Frankly they will attest any documentation that I ask for..., without understanding the full implications; but that do not mitigate data security specially under PII].
Answer: You must teach them what the benefits for their job are - once they accept this, everything else will be easier. Read this article: Four key benefits of ISO 27001 implementation https://advisera.com/27001academy/knowledgebase/four-key-benefits-of-iso-27001-implementation/
Poor Compliance (just signing the documents..) does not mitigate risks. How to educate these sr. managers - VPs, Div. heads, div. presidents., etc.)
Again, find the benefits of information security implementation and communicate those to your top management. This webinar will teach you the techniques: ISO 27001 benefits: How to obtain management support https://advisera.com/27001academy/webinar/iso-27001-benefits-how-to-get-management-buy-in-free-webinar-on-demand/ -
Applicability of A14 for Data Centre
Concern is Reference to Annex A: the 14th domain of ISO 27001:2013 - System acquisition, development and maintenance
Can the entire controls of 14th domain be excluded from Statement of Applicability with appropriate justifying statements?
OR
Would certain sub domains of the 14th domain, which do not specify application relevance and in general addresses 'systems' have to be included in Statement of Applicability?
Answer :
You should select the controls based on 1) legal, regulatory and contractual requirements, 2) risk management activity.
You dont tell if A14 controls are excluded due to the rule above or Application Development and Maintenance are outsourced (because you dont have the internal capability) or are simply excluded from the scope for any other reason.
In the second case, what you out source has to be covered by the controls A15.
However, it sounds me strange to certify an empty IT infrastructure. You probably have data and applications on it. A14.1 is then fully mandatory based on the rule in the first sentence. -
ISMS and Cloud computing
Why would you go for 27017? Are you a client or a provider (IaaS, PaaS or Saas)?
1) ISO 27017 isn't out yet (last CD stage). It has to be used as a complement to ISO 27002:2013 in Cloud environments, as ISO 27018 is for Privacy protection in the Cloud environment (Published last year).
2) You are certified against ISO 27001 not against anything else in informations security. One may use any reference' (s)he wants in complement to Annex A (= ISO 27002:2013).
You may introduce the Cloud in your scope, as more and more IT companies are doing. As a client its an outsourced service; as a provider its part of your activities with possible outsourcing of elements of the cloud.
This article may hop you: « Cloud computing and ISO 27001 / BS 25999 »: https://advisera.com/27001academy/blog/2011/05/30/cloud-computing-and-iso-27001-bs-25999/ -
How do we identify what are the regulatory, contractual and other requirements
You must find a list of laws and regulations in your country that can potentially be relevant for your ISMS - you can find an unofficial list here: https://www.infosecpedia.info/laws-regulatio******************************************** For contractual obligations, you have to find all the contracts your company has made.
The only way to find out if they are relevant to your company is to read them, or ask someone else to read them for you.
This article can also help you: How to identify interested parties according to ISO 27001 and ISO 22301 https://advisera.com/27001academy/knowledgebase/how-to-identify-interested-parties-according-to-iso-27001-and-iso-22301// -
ISMS scope for data center
If the data center facility is not part of your company, then you can describe that only the server + the database is part of your ISMS scope (or only the database if the server is not under your control). See also this article: Problems with defining the scope in ISO 27001 https://advisera.com/27001academy/blog/2010/06/29/problems-with-defining-the-scope-in-iso-27001/
The ISMS needs to be implemented by all the employees involved, not only by one person who is coordinating the ISMS implementation. Therefore, this coordinator does not need to travel to all your locations if he/she feels comfortable that local employees are doing their job properly. See also this article: ISO 27001 project How to make it work https://advisera.com/27001academy/blog/2013/04/22/iso-27001-project-how-to-make-it-work/