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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/ -
3rd party security policy vs. Information security policy for supplier relations
Answer: ISO 27001 does not mention "3rd party security policy", so the point is:
1) ISO 27001 requires you to make only one policy to deal with suppliers
2) The difference between 3rd parties and suppliers is that 3rd parties could also include customers
3) Even if you want to cover the security requirements for customers and suppliers, you can do it in one policy, you do not have to separate them. -
Is it an NC
I'm not sure if I understood your question well, but if the provider of training services has signed a contract with the customer where it has obliged to comply with certain requirement, then it must comply with it - otherwise this is a nonconformity.
The point is, a company must comply with all of these: ISO 27001 + laws & regulations + contractual obligations + its own policies and procedures.
This article can also help you: Major vs. minor nonconformities in the certification audit https://advisera.com/27001academy/blog/2014/06/02/major-vs-minor-nonconformities-in-the-certification-audit/ -
27001 Scope
There might be a serious problem with this reduced scope for the ISMS. Due to the need for connexion with the two other sites, the reduced ISMS scope might be not feasible. This decision should be reviewed and justified.
You may consider the two other sites as external, but the complexity is in the close interactions in/out/in-out that is continuous or at least continual. When describing the scope, you should also clearly describe what is in and what is out.
When there are connections with other entities (be they from the same company or external) you should identify and describe the interfaces with the associated risks of information coming in and going out. Identifying the communic ation channels and the associated risks is also important, depending on the responsibility for protection the ISMS scope has. In your case, you have to use both directions.
In any case, it is easier to have all the 4 locations within the scope.
This post on the blog can also help you: Problems with defining the scope in ISO 27001:
https://advisera.com/27001academy/blog/2010/06/29/problems-with-defining-the-scope-in-iso-27001/ -
ISO 27001 / Planned intervals
Management review must be performed at least once a year.
By the way, if your top management doesn't care at all about your information security, then you have a serious problem - therefore, a management review shouldn't be just another compliance job, but a serious consideration from the management point of view on how your security is performing.
This article can also help you: Why is management review important for ISO 27001 and ISO 22301? https://advisera.com/27001academy/blog/2014/03/03/why-is-management-review-important-for-iso-27001-and-iso-22301/ -
Context and scope of the ISMS / ISO 27001 v 2013
So we would suggest you avoid the risk analysis or any deep consideration of what if at this stage and concentrate on identifying the issues. Personal data, sensitive customer ideas and IPR, financial information, brand, codebases etc? Therefore consider any existing issues of: recruitment e.g. -
On-line transactions
Answer:
1. Transactions (e.g. financial) are one of the types of services, but the standards does not focus on them. One may of course only think about that, but why narrowing the scope of application services and forgetting issues? I dont think any list will be exhaustive.
Other transactions can be any direct exchange of data, such as credentials for requesting access to a distant system, answers to an line o a poll or survey, uploading files to a cloud server, etc.
2. However, ISO27001:2013 (and ISO 27002:2013 that provides the details of Annex A) doesnt speak about this anymore and widens largely the scope of this control. It relates with all kinds of applications and services that pass over the public service.
Please remember that the title of the clause is System acquisition, development and maintenance.
Some examples of application services: Games, Streaming videos, E-learning, On- line registration and acquisitions, Telephony services, Establishing and managing a radio communication between a control tower and an aircraft.
Best regards
Jean-Luc