Answer: There is no specific template for segregation of duties because responsibilities are defined in each template according the required tasks to be performed (for example, in the Back up policy template, you can define different job titles to create and test backup copies). If for a required activity your organization identifies there is need to segregate it, you can adjust the template to that specific situation.
Additionally, in the Information Security Policy template you can define segregated activities related to information security (please see the section 4.5 of the document). This template can be found on folder 04 Information Security Policy.
A path between the ISO 27001 certification and the GDPR toolkit
Answer: In the Article 32, EU GDPR requires the implementation of security controls, so in our EU GDPR Toolkit we have included 11 documents from ISO 27001 that will cover this requirement - here they are:
- IT Security Policy (in the ISO 27001 toolkit this one is called the Acceptable Use Policy)
- Access Control Policy
- Security Procedures for IT Department (in the ISO 27001 toolkit this one is called the Operating Procedures for Information and Communication Technology)
- Bring Your Own Device (BYOD) Policy
- Mobile Device and Teleworking Policy
- Clear Desk and Clear Screen Policy
- Information Classification Policy
- Policy on the Use of Encryption Article 32
- Disaster Recovery Plan Article 32
- Internal Audit Procedure Article 32
- ISO 27001 Internal Audit Checklist
The point is, the implementation of these security controls is ca 50% of the whole GDPR implementation, while the rest of the effort should be focused on privacy and legal issues.
Management Review inputs and monitoring and measurement
Answer:
According to the process approach, your QMS is a set of interrelated processes. Every process has indicators or some other methods of measuring and monitoring performance. The Management Review Meeting (MRM) is a good place to do two things with those methods. First, are they relevant? Do you still consider them to be good choices to monitor and measure performance? Do you see better choices? Second, what about the performance level according to those indicators and other methods? Should your company update the targets for performance? Should your company develop improvement actions?
The following material will provide you information about monitoring and measurement:
Answer: Financial information is only one kind of information that may require the application of control A.14.1.3 (Protecting application services transactions). Other examples of information that may require protection in application service transactions are health information and information the organization classified as sensitive.
So, even if your organization don't have online financial transaction you may have other types of sensitive information processed by your web applications that may require the application of control A.14.1.3. You should consult your inventory of assets, the information classification policy and which information are processed on your web applications to verify if control A.14.1.3 is applicable.
(What is the difference between the asset owner and the risk owner?)
Answer: The asset owner is the person responsible for protecting and managing an asset in your company, while the risk owner is a person designated to solve a risk. Although these are different roles, they can be performed by the same person in a small organizations, but you should note that designating these roles to the same person becomes increasingly complex as the quantity of assets and risks under his responsibility increases.
Answer: This statement is only a recommendation. ISO 27001 control A.8.2.2 (Labeling of information) does not define any form of labeling, only that a labeling procedure must be defined and implemented (if the control is considered applicable). How to label information is an organization's decision. In cases where the implementation of labeling is not feasible, or it will require much effort or resources, an organization can define that labeling will not be applicable.
Answer: To ensure a better alignment between Information security and cyber security practices it is better to consider the Cyber Security Policy as a section of your Information Security Policy. Regarding which points you should consider, a good reference is the ISO 27032 standard, which provides guidelines for cyber security. In terms of policies you should consider the following topics:
- Guidelines to be followed when you are an information providing organization and when you are an information receiving organization
- Classification and categorization of information
- Information minimization
- Limited audience
- Coordination protocol