Alternatively, should the annex a controls and implementation be owned by the Head of IT/information security?
Answer:
You can assign owners to controls applicable to your organization, but for small and mid-size companies this role is normally assumed by the risk owner, the one who is accountable for managing a risk. For small and mid-size companies the number of treated risks normally allows the risk owners also to be control owners, but when the number of risks is too high, or controls are used to treat multiple risks, assigning control owners may be a better approach, since the control owner will have a comprehensive view of how controls are used against multiple risks, while the risks owners can focus on keeping the risks on acceptable levels.
Considering your alternative, since inf ormation security controls can cover much more then IT-related controls, then the best approach would be for the controls to be owned by the Head of information security. Again, if the number of controls is too high, then you can split responsibilities considering people competencies.
The management understanding is correct. Having a single plan to cover multiple types of incidents or assets would be a big and unpractical document, then the best approach would be to have multiple small documents covering specific assets or incidents.
Information Security Policy and Business Continuity Management Policy
1 - Your Information Security Policy relates to the BCMP, (red below), but can you please advise where is this template?
Answer: You do not have to keep section 4.4 of the Information Security Policy if you don't have business continuity management implemented in your company, or you do not have plans to implement it together with ISO 27001. The Business Continuity Management Policy is not mandatory for ISO 27001 certification (even if controls from section A.17 of Annex A are applicable), so to not increase unnecessarily customers effort on managing the ISMS, this template is not included in the toolkit you bought.
2 - During Certification, we are concerned the Business Recovery Plan may be too simplistic even for our small business. We have reviewed your tutorials, but still remain very unclear. We would appreciate your explana tion here to help us move forward please.
Answer: The Disaster Recovery Plan template included in your toolkit includes all requirements a certification auditor will look for during the certification audit, so if you followed all recommendations in the comments included in the template your document will be fine for the certification audit. In any case, included in your toolkit you have the possibility to send us some of your documents so one of our experts can evaluate them and provide guidance on which adjustments you have to make, if any, so your document is fully compliant with the standard.
Mandatory documents and production steps
We are having an internal debate here regarding "Work Station Signage" requirements. That is, are assembly technicians "required" to initial & date when they complete a particular manufacturing sequence step? Currently we have not required technician signoffs in the past as it is "fairly" obvious as to whether or not the prior Sequence Step was completed correctly or not. Typically there are about 20-30 sequence steps to assemble the products we sell. At the very end, all products receive a Final Calibration report which basically indicates the product manufactured satisfies performance specifications.
There are a group of individuals here that feel ISO 9001 requires workstation signage and there is a group of individuals her e that is against it. I don't see the harm in having it the signoffs, but I'm not an ISO expert and I'm not able to determine whether this is specifically required or not by the standard. Could you shed some light on this?”
Answer:
The fast answer is: ISO 9001:2015 does not require workstation signage as long as that signage is just a confirmation of work done. If that workstation signage is used in your organization as a kind of quality control then it is required.
Answer:
You can start by asking if the organization has determined its risks and opportunities. Even if they are not documented, you can check if different people in different places and moments are on the same page about risks and opportunities determination.
Then you can ask how the organization determines which risks and opportunities are relevant and must be treated. Now is the time to request evidence of examples of actions, developed and implemented, to manage relevant risks and opportunities. Were those actions effective?
And how the organization monitors and reviews risks and opportunities?
These are examples of the kind of questions you can ask to audit risks and opportunities.
Answer:
I will only consider ISO 9001:2015 and ISO 14001:2015 in my answer.
ISO 9001:2015
About being mandatory to update external and internal issues – the last phrase of clause 4.1 and clause 9.3.2 b) consider the principle that changes in the context may occur and that the organization must consider them.
About being mandatory to update risk analysis – clause 6.1.1 say that organizations should consider external and internal issues when determining risks and opportunities. So, if external and internal issues are updated it is plausible to conclude that at least some risks and opportunities can appear/disappear or become more or less critical. Also, clauses 9.3.2 e) and 10.2.1 e ) can be seen as doors to consider the need to update risk analysis. Effective actions, for example, can change the priority of risks and opportunities, and nonconformities can make updating the risk register and risk classification necessary.
ISO 14001:2015
About being mandatory to update external and internal issues – clause 9.3 b) 1) consider the principle that changes in the context may occur and that the organization must consider them.
About being mandatory to update risk analysis – clause 6.1.1 say that organizations should consider environmental aspects, compliance obligations and external and internal issues when determining risks and opportunities. So, if external and internal issues are updated, and if environmental aspects and compliance obligations are updated it is plausible to conclude that at least some risks and opportunities can appear/disappear or become more or less critical. Also, clause 9.3 b) 4) can be seen as a door to consider the need to update risk analysis. Effective actions, for example, can change the priority of risks and opportunities.
About being mandatory to update environmental aspects – Clause 9.3 b) 3) considers the possibility of changes among environmental aspects.
Organizations are not separated from their context they are immersed in it. If the context changes, organizations should update their context analysis and evaluation. Management systems are in part tools to manage risks, opportunities and environmental aspects. An effective management system with their effective actions should, as a consequence, generate the need to update the determination and evaluation of risks, opportunities and aspects.
Answer:
Even if your organization is outsourcing the design it will still be responsible for ensuring that a process is followed and that ISO 9001 requirements are met. Outsourced processes are still applicable. But if your organization buys a particular design off the shelf, as finished specifications, non-applicability makes sense.
I was checking ISO/IEC 27017:2015, and wondering if I'm missing something.
Answer:
There is no specific ISO certifications for cloud computing. What you can consider is the implementation of specific controls of ISO 27017 in an ISMS (ISO 27001 already cover the general controls to also protect cloud services), if you have specific requirements (e.g., laws, regulations or contracts) demanding security controls for cloud environments.
Additionally, I suggest you to consider ISO 27018, ISO standard related to protection of Personal Identifiable Information (PII), to fulfill potential requirements you have regarding the protection of customers privacy.
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