NQA ISO 27001 Implementation Guide

ISO 27001:2013INFORMATION SECURITY IMPLEMENTATION GUIDE
9043,000 *

ISO 27001:2013 IMPLEMENTATION GUIDE2
> ISO 27001:2013
IMPLEMENTATION GUIDE
*UK and Ireland only

ISO 27001:2013 IMPLEMENTATION GUIDE 3ISO 27001:2013 IMPLEMENTATION GUIDE 3
Contents
Introduction to the standard P04
Benefits of implementation P05
Key principles and terminology P06
PDCA cycle P07
Risk based thinking / audits P08
Process based thinking / audit P09
Annex SL P10
CLAUSE 1: Scope P11
CLAUSE 2: Normative references P12
CLAUSE 3: Terms and definitions P13
CLAUSE 4: Context of the organization P14
CLAUSE 5: Leadership P16
CLAUSE 6: Planning P18
CLAUSE 7: Support P20
CLAUSE 8: Operation P22
CLAUSE 9: Performance evaluation P24
CLAUSE 10: Improvement P26
Get the most from your management P28
Stor-a-file and ISO 27001:2013 case study P29
Next steps once implemented P30
Useful links P32

INTRODUCTION
TO THE STANDARD
The 27000 Family
The 27000 series of standards started life in 1995 as BS
7799 and was written by the UK’s Department of Trade and
Industry (DTI). The standards correctly go by the title “ISO/
IEC” because they are developed and maintained jointly by
two international standards bodies: ISO (the International
Organization for Standardization) and the IEC (the International
Electrotechnical Commission). However, for simplicity, in
everyday usage the “IEC” part is often dropped.
There are currently 45 published standards in the ISO 27000
series. Of these, ISO 27001 is the only standard intended for
certification. The other standards all provide guidance on best
practice implementation. Some provide guidance on how to
develop ISMS for particular industries; others give guidance on
how to implement key information security risk management
processes and controls.
Regular reviews and updates
ISO standards are subject to review every five years
to assess whether an update is required.
The most recent update to the ISO 27001 standard in 2013
brought about a significant change through the adoption
of the “Annex SL” structure. While there were some very
minor changes made to the wording in 2017 to clarify the
requirement to maintain an information asset inventory, ISO
27001:2013 remains the current standard that organizations
can achieve certification to.
Most businesses hold or have access to valuable or sensitive information. Failure to provide
appropriate protection to such information can have serious operational, financial and legal
consequences. In some instances, these can lead to a total business failure.
The challenge that most businesses struggle with is how to provide appropriate protection. In particular, how
do they ensure that they have identified all the risks they are exposed to and how can they manage them in a
way that is proportionate, sustainable and cost effective?
ISO 27001 is the internationally-recognised standard for Information Security Management Systems (ISMS). It
provides a robust framework to protect information that can be adapted to all types and sizes of organization.
Organizations that have significant exposure to information-security related risks are increasingly choosing to
implement an ISMS that complies with ISO 27001.
Three of the standards are particularly helpful to
all types of organizations when implementing an
ISMS. These are:
• ISO 27000 Information Technology – Overview
and vocabulary
• ISO 27002 Information technology – Security
techniques – Code of practice for information
security controls. This is the most commonly
referenced, relating to the design and
implementation of the 114 controls specified in
Annex A of ISO 27001.
• ISO 27005 Information Technology – Security
techniques – Information security management.

ISO 27001:2013 IMPLEMENTATION GUIDE 5
BENEFITS OF
IMPLEMENTATION
COMMERCIAL
Having independent third-party endorsement
of an ISMS can provide an organization with a
competitive advantage, or enable it to ‘catch up’
with its competitors. Customers that are exposed
to significant information security risks are
increasingly making certification to ISO 27001
a requirement in tender submissions. Where
the customer is also certified to ISO 27001
they will, in the medium term, choose to work
only with suppliers whose information security
controls they have confidence in and that have
the capability to comply with their contractual
requirements.
For organizations that want to work with this
type of customer, having an ISO 27001 certified
ISMS is a key requirement for sustaining and
increasing their commercial revenues.
OPERATIONAL
The holistic approach of ISO 27001 supports
the development of an internal culture that is
alert to information security risks and has a
consistent approach to dealing with them. This
consistency of approach leads to controls that
are more robust in dealing with threats. The
cost of implementing and maintaining them is
also minimised, and in the event of them failing
the consequences will be minimised and more
effectively mitigated.
PEACE OF MIND
Many organizations have information that
is mission-critical to their operations, vital
to sustaining their competitive advantage
or an inherent part of their financial value.
Having a robust and effective ISMS in place
enables business owners and managers with
responsibility for managing risks to sleep easier
at night knowing that they are not exposed to a
risk of heavy fines, major business disruption or
a significant hit to their reputation.
In today’s knowledge-based economy, almost
all organizations are reliant on the security of key
information. Implementation of a formal ISMS is
a proven method of providing such security.
ISO 27001 is an internationally recognised
framework for a best practice ISMS and
compliance with it can be independently verified
to both enhance an organization’s image and
give confidence to its customers.
Information security is becoming increasingly important to organizations, and the adoption
of ISO 27001 therefore more and more common. Most organizations now recognise that it is
not a question of if they will be affected by a security breach; it is a question of when.
Implementing an ISMS and achieving certification to ISO 27001 is a significant undertaking for most organizations.
However, if done effectively, there are significant benefits for those organizations that are reliant on the protection of
valuable or sensitive information. These benefits typically fall into three areas:

KEY PRINCIPLES
AND TERMINOLOGY
The core purpose of an ISMS is to provide protection for sensitive or valuable information.
Sensitive information typically includes information about employees, customers and suppliers.
Valuable information may include intellectual property, financial data, legal records, commercial
data and operational data.
These information security risk types are commonly referred to
as “CIA”.
Risks in information security typically arise due to the
presence of threats and vulnerabilities to assets that
process, store, hold, protect or control access to information
which gives rise to incidents.
Assets in this context are typically people, equipment, systems
or infrastructure.
Information is the data set(s) that an organization wants to
protect such as employee records, customer records, financial
records, design data, test data etc.
Incidents are unwanted events that result in a loss of
confidentiality (e.g. a data breach), integrity (e.g. corruption
of data) or availability (e.g. system failure).
Threats are what cause incidents to occur and may be
malicious (e.g. a burglar), accidental (e.g. a key stroke error) or
an act of God (e.g. a flood).
Vulnerabilities such as open office windows, source code
errors, or the location of buildings next to rivers, increase
the likelihood that the presence of a threat will result in an
unwanted and costly incident.
In information security, risk is managed through the design,
implementation and maintenance of controls such as locked
windows, software testing or the siting of vulnerable equipment
above ground floor levels.
An ISMS that complies with ISO 27001 has an interrelated
set of best practice processes that facilitate and support the
appropriate design, implementation and maintenance of
controls. The processes that form part of an ISMS are usually
a combination of existing core business processes (e.g.
recruitment, induction, training, purchasing, product design,
equipment maintenance, service delivery) and those specific
to maintaining and improving information security (e.g. change
management, information back-up, access control, incident
management, information classification).
Confidentiality
where one or
more persons gain
unauthorised access
to information.
Integrity
where the content of the
information is changed
so that it is no longer
accurate or complete.
Availability
where access to the
information is lost
or hampered.
The types of risks
that sensitive and
valuable information
are subject to
can generally be
grouped into three
categories:
THE TYPES OF
RISKS THAT
SENSITIVE
AND VALUABLE
INFORMATION
ARE SUBJECT TO
CAN GENERALLY
BE GROUPED
INTO THREE
CATEGORIES:

PDCA CYCLE
Plan-Do-Check-Act is an example of a closed-loop system. This ensures the learning from the ‘do’ and ‘check’ stages are
used to inform the ‘act’ and subsequent ‘plan’ stages. In theory this is cyclical, however it’s more of an upward spiral as the
learning moves you on each time you go through the process.
PDCA model ISO 27001
Plan:
Establish objectives,
resources required,
customer and
stakeholder
requirements,
organizational policies
and identify risks and
opportunities.
Do:
Implement what
was planned.
Check:
Monitor and measure
processes to establish
performance against
policies, objectives,
requirements and
planned activities and
report the results.
Act:
Take action to improve
performance, as
necessary.
ISO 27001 is based on the Plan-Do-Check-Act (PDCA) cycle, also known as the Deming
wheel or Shewhart cycle. The PDCA cycle can be applied not only to the management
system as a whole, but also to each individual element to provide an ongoing focus on
continuous improvement.
ESTABLISH
ISMS
MONITOR
AND REVIEW
THE ISMS
MAINTAIN
AND IMPROVE
THE ISMS
IMPLEMENT
AND OPERATE
THE ISMS
Plan Do
Act Check
INFORMATION SECURITY MANAGEMENT SYSTEM (4)
INTERESTED
PARTIES
INFORMATION
SECURITY
REQUIREMENTS
AND
EXPECTATIONS
In brief:
INTERESTED
PARTIES
MANAGED
INFORMATION
SECURITY

RISK BASED
THINKING/AUDITS
1st Party Audits
– Internal Audits
Internal audits are a great opportunity for learning within
your organization. They provide time to focus on a particular
process or department in order to truly assess its performance.
The purpose of an internal audit is to ensure adherence to
policies, procedures and processes as determined by you, the
organization, and to confirm compliance with the requirements
of ISO 27001.
Audit Planning
Devising an audit schedule can sound like a complicated
exercise. Depending on the scale and complexity of your
operations, you may schedule internal audits anywhere from
every month to once a year. There’s more detail on this in
section 9 – performance evaluation.
Risk-based Thinking
The best way to consider frequency of audits is to look at the
risks involved in the process or business area to be audited.
Any process which is high risk, either because it has a high
potential to go wrong or because the consequences would be
severe if it did go wrong, should be audited more frequently
than a low risk process.
How you assess risk is entirely up to you. ISO 27001 doesn’t
dictate any particular method of risk assessment or risk
management.
2nd Party – External Audits
Second party audits are usually carried out by customers or
by others on their behalf, or you may carry them out on your
external providers. 2nd party audits can also be carried out by
regulators or any other external party that has a formal interest
in an organization.
You may have little control over the timing and frequency of
these audits, however establishing your own ISMS will ensure
you are well prepared for their arrival.
3rd Party – Certification Audits
Third party audits are carried out by external bodies, usually
UKAS accredited certification bodies such as NQA.
The certification body will assess conformance to the ISO
27001:2013 standard. This involves a representative of the
certification body visiting the organization and assessing the
relevant system and its processes. Maintaining certification
also involves periodic reassessments.
Certification demonstrates to customers that you have a
commitment to quality.
Audits are a systematic, evidence-based, process approach to evaluation of your
Information Security Management System. They are undertaken internally and externally
to verify the effectiveness of the ISMS. Audits are a brilliant example of how risk-based
thinking is adopted within Information Security Management.
CERTIFICATION ASSURES:
• regular assessment to continually monitor
and improve processes.
• credibility that the system can achieve
its intended outcomes.
• reduced risk and uncertainty and increase
market opportunities.
• consistency in the outputs designed to meet
stakeholder expectations.

PROCESS BASED
THINKING/AUDIT
Even an audit has a process approach. It begins with
identifying the scope and criteria, establishes a clear course
of action to achieve the outcome and has a defined output
(the audit report). Using the process approach to auditing also
ensures the correct time and skills are allocated to the audit.
This makes it an effective evaluation of the performance of the
ISMS.
“Consistent and predictable results are achieved more
effectively and efficiently when activities are understood and
managed as interrelated processes that function as a
coherent system.”
ISO 27001:2013 Fundamentals
and Vocabulary
Understanding how processes interrelate and produce
results can help you to identify opportunities for improvement
and thus optimise overall performance. This also applies
where processes, or parts of processes, are outsourced.
Understanding exactly how this affects or could affect the
outcome and communicating this clearly to the business
partner (providing the outsourced product or service) ensures
clarity and accountability in the process.
The final process step is to review the outcome of the audit
and ensure the information obtained is put to good use. A
formal Management Review is the opportunity to reflect on
the performance of the ISMS and to make decisions on how
and where to improve. The Management Review process is
covered in more depth in Section 9 – performance evaluation.
A process is the transformation of inputs to outputs, which takes place as a series of
steps or activities which result in the planned objective(s). Often the output of one process
becomes an input to another subsequent process. Very few processes operate in isolation
from any other.
“Process: set of interrelated or interacting
activities that use inputs to deliver an
intended result.”
ISO 27001:2013 Fundamentals and Vocabulary
£
£

ANNEX SL
ISO 27001 (Information Security Management System
Standard) adopted this structure during its 2013 revision. ISO
14001 (Environmental Management System Standard) also
adopted this structure during its 2015 revision. The newly
published ISO 45001 (Health and Safety Management System
Standard) also follows this same common structure.
Prior to the adoption of Annex SL there were many differences
between the clause structures, requirements and terms and
definitions used across the various management system
standards. This made it difficult for organizations to integrate
the implementation and management of multiple standards;
Environment, Quality, Health and Safety and Information
Security being among the most common.
One of the major changes introduced into the 2013 revision of ISO 27001 was the adoption
of Annex SL for the clause structure of the revised standard. Annex SL (previously known
as ISO Guide 83) was used within ISO by standards writers to provide a common core
structure for management system standards.
High Level Structure
Annex SL consists of 10 core clauses:
1. Scope
2. Normative references
3. Terms and definitions
4. Context of the organization
5. Leadership
6. Planning
7. Support
8. Operation
9. Performance evaluation
10. Improvement
Of these clauses, the common terms and core
definitions cannot be changed. Requirements may
not be removed or altered, however discipline-specific
requirements and recommendations may be added.
All management systems require a consideration of
the context of the organization (more on this in section
4); a set of objectives relevant to the discipline, in this
case quality, and aligned with the strategic direction
of the organization; a documented policy to support
the management system and its aims; internal audits
and management review. Where multiple management
systems are in place, many of these elements can be
combined to address more than one standard.

CLAUSE 1:
SCOPE
The Scope section of ISO 27001 sets out
• the purpose of the standard;
• the types of organizations it is designed to apply to; and
• the sections of the standard (called Clauses) that contain
requirements that an organization needs to comply with in
order for the organization to be certified as “conforming” to
it (i.e. being compliant).
ISO 27001 is designed to be applicable to any type of
organization. Regardless of size, complexity, industry sector,
purpose or maturity, your organization can implement and
maintain an ISMS that complies with ISO 27001.
ISO 27001 is made of up 10 sections
known as Clauses.
As with most other ISO management
system standards, the requirements of
ISO 27001 that need to be satisfied are
specified in Clauses 4.0 – 10.0. Unlike
most other ISO management system
standards, an organization must comply
with all of the requirements in Clauses 4.0
– 10.0; they cannot declare one or more
clauses as being not applicable to them.
In ISO 27001, in addition to Clauses 4.0-
10.0 there is a further set of requirements
detailed in a section called Annex A,
which is referenced in Clause 6.0. Annex
A contains 114 best practice information
security controls. Each of these 114
controls needs to be considered. To be
compliant with ISO 27001 the organization
must implement these controls, or an
acceptable justification must be given for
not implementing a particular control. The
following parts of this guide provide an
overview explanation of the purpose of
each clause, highlight the type of evidence
an auditor would expect to see to confirm
that you comply, and give tips on effective
ways to comply with the requirements.
THE 10 CLAUSES OF ISO 27001:2013
CONTROLS
CONTINUAL
IMPROVEMENT
MONITOR
INTERESTED PARTIES
THREATS
CONTROL
ACCESS
ASSETS
VULNERABILITIES
RISKSINFORMATION
CONFIDENTIALITY
INTEGRITY
AVAILABILITY
USE
REGULATE
VALUE

CLAUSE 2:
NORMATIVE
REFERENCES
Some of the terms used or requirements detailed in ISO 27001
are explained further in ISO 27000. Reference to ISO 27000 is
very useful in helping you to understand a requirement better
or identify the best way to comply with it.
TIP – External auditors will expect you to have taken the
information contained in ISO 27000 into account in the
development and implementation of your ISMS.
In ISO standards, the Normative References section lists any other standards that contain
additional information that is relevant to determining whether or not an organization
complies with the standard in question. In ISO 27001 only one document is listed – ISO
27000 Information Technology - Overview and vocabulary.

In addition to the terms explained in the “Key
Principles and Terminology” section above, the
most important terms used in ISO 27001 are:
‘Access Controls’
– processes that ensure that only the people that need to have
access to a certain asset have that access and the “need”
is determined with reference to both business and security
requirements.
‘Effectiveness’
– the extent to which planned activities (e.g. processes,
procedures) are executed as planned or specified and
achieve the planned results or outputs.
‘Risk’
– a combination of the likelihood of an information security
event occurring and the resulting consequences.
‘Risk Assessment’
– the process of identifying risks, analysing the level of risk
posed by each risk and evaluating whether additional
action is needed to reduce each risk to a more tolerable or
acceptable level.
‘Risk Treatment’
– processes or actions that reduce identified risks to a tolerable
or acceptable level.
‘Top Management’
– the group of individuals who are the most senior decision
makers in an organization. They are likely to be accountable
for setting its strategic direction and for determining and
achieving stakeholder objectives.
When you write your Information
Security Management System
documentation, you don’t have to
use these exact terms. However, it
does help to clarify the meaning and
intention if you can define the terms
you have used. Providing a glossary
within your system documentation may
be useful.
CLAUSE 3:
TERMS AND
DEFINITIONS
There are no terms and definitions given in ISO 27001. Instead, reference is made to the
most current version of ISO 27000 Information Security Management Systems – Overview
and vocabulary. The current version of this document contains 81 definitions of terms that
are used in ISO 27001.

CLAUSE 4:
CONTEXT OF THE
ORGANIZATION
Internal Context
The following are examples of the areas that can be
considered when assessing the internal issues that may have a
bearing on the ISMS risks:
• Maturity: are you an agile start-up with a blank canvas to
work on, or a 30+ year old institution with well-established
processes and security controls?
• Organization culture: is your organization relaxed
about how, when and where people work, or extremely
regimented? Might the culture resist the implementation of
Information Security controls?
• Management: are there clear communication channels
and processes from the organization’s key decision makers
through to the rest of the organization?
• Resource size: are you working with an Information Security
Team, or is one person doing it all?
• Resource maturity: are the available resources (employees/
contractors) knowledgeable, fully trained, dependable and
consistent, or are personnel inexperienced and constantly
changing?
• Information asset formats: are your information assets
mainly stored in hard-copy (paper) format, or are they stored
electronically on a server on-site, or in remote cloud-based
systems?
• Information asset sensitivity/value: does your organization
have to manage highly valuable or particularly sensitive
information assets?
• Consistency: do you have uniform processes in place
across the organization, or a multitude of different operating
practices with little consistency?
• Systems: does your organization have many legacy systems
running on software versions that are no longer supported
by the manufacturer, or do you maintain the most up to date
and best available technology?
• System complexity: do you operate one main system that
does all the heavy lifting, or multiple departmental systems
with limited information transfer between them?
• Physical space: do you have a dedicated secure office
facility, or do you operate in a space shared with other
organizations?
External Context
The following are examples of the areas that can be
considered when assessing the external issues that may have
a bearing on the ISMS risks:
• Competition: do you operate in a rapidly changing and
innovative market, requiring many system upgrades to
stay competitive, or in a mature, stable market with little
innovation year-to-year?
• Landlord: do you need approval to upgrade physical
security?
• Regulators / enforcement bodies: is there a requirement
in your sector to make regular statutory changes, or is there
little oversight from regulators in your market sector?
• Economic/political: do currency fluctuations impact your
organization; will Brexit in the UK have an impact?
• Environmental considerations: is your site on a flood plain
with the server(s) located in a basement? Are there factors
making your site(s) a possible target for a break-in or a
terrorist attack (e.g. in a prominent city centre location; next
to a possible target)?
• Prevalence of information security attacks: does your
organization operate in a sector which regularly attracts
interest from hackers (criminals, hacktivists)?
• Shareholders: are they very concerned about the
vulnerability of the organization to data breaches? How
concerned are they about the cost of the organization’s
efforts to improve its information security?
The purpose of your ISMS is to protect your organization’s Information Assets, so that the
organization can achieve its goals.
How you go about this and the specific areas of priority
will be driven by the context your organization operates in,
both:
• internal – the things over which the organization has
some control; and
• external – the things over which the organization has no
direct control.
A careful analysis of the environment your organization
operates in is fundamental to identifying the inherent
risks posed to the security of your Information Assets.
The analysis is the foundation that will enable you to
assess what processes you need to consider adding or
strengthening to build an effective ISMS.

Interested Parties
An interested party is anyone who is, can be, or perceives
themselves to be affected by an action or omission of your
organization. Your interested parties will become clear through
the process of carrying out a thorough analysis of internal
and external issues. They will probably include shareholders,
landlords, regulators, customers, employees and competitors
and may extend to the general public and the environment,
depending on the nature of your business. You don’t have
to try to understand or satisfy their every whim, but you do
have to determine which of their needs and expectations are
relevant to your ISMS.
Scope of the
Management System
To comply with ISO 27001, you must document the scope of
your ISMS. Documented scopes typically describe:
• the boundaries of the physical site or sites included (or not
included);
• the boundaries of the physical and logical networks included
(or not included);
• the internal and external employee groups included (or not
included);
• the internal and external processes, activities or services
included (or not included); and
• key interfaces at the boundaries of the scope.
If you want to prioritise resources by building an ISMS that
doesn’t cover all of your organization, selecting a scope that
is limited to managing key stakeholder interests is a pragmatic
approach. This can be done by including only specific sites,
assets, processes and business units or departments. Some
examples of scope statements:
• “All operations carried out by the IT Department”
• “Support and management of email”
• “All equipment, systems, data and infrastructure in the
organization’s Data Centre based at the Basingstoke site”
TIP – Document or maintain a file of all of the information
collated in your analysis of your organization’s context and
interested parties such as:
• Discussions with a senior representative of the organization,
e.g. an MD, CEO or CTO.
• Minutes of meetings or business plans.
• A specific document that identifies internal/external issues
and interested parties and their needs and expectations e.g.
a SWOT analysis, PESTLE study, or high-level business risk
assessment.

CLAUSE 5:
LEADERSHIP
Information Security Policy
A vital responsibility of the leadership is to establish and
document an Information Security Policy that is aligned with
the key aims of the organization. At the top level it must either
include objectives, or a framework (guidelines) for setting
them. To demonstrate that it is aligned with your organization’s
context and the requirements of key stakeholders, it is
recommended that it makes reference to, or contains a
summary of, the principal issues and requirements it is
designed to manage. It must also include a commitment to:
• satisfying applicable requirements relating to Information
Security, such as legal requirements, customer expectations
and contractual commitments; and
• the continual improvement of your ISMS.
The Information Security Policy may refer to, or include
sub-policies that cover, the key controls of the organization’s
ISMS. Examples include: the selection of suppliers critical
to Information Security, the recruitment and training of
employees, clear desk and clear screen, cryptographic
controls, access controls etc. To demonstrate the importance
of the Information Security Policy, it is advisable that it
is authorised by the most senior member of your Top
Management or each member of the Top Management team.
TIP - To ensure your Information Security Policy is well
communicated and available to interested parties, it is a good
idea to:
• include it in induction packs and presentations for new
employees and contractors;
• post the key statement on internal noticeboards, intranets
and your organization’s website; and
• make compliance with it and/or support for it a contractual
requirement for employees, contractors and information
security-critical suppliers.
Roles and Responsibilities
For Information Security activities to form part of the day-to-
day activities for most people within the organization, the
responsibilities and accountabilities they have must be defined
and clearly communicated. Although there is no requirement
in the standard for a nominated Information Security
representative, it may be helpful for some organizations to
appoint one to lead an information security team to coordinate
training, monitoring controls and reporting on the performance
of the ISMS to the Top Management. This individual may
already hold responsibility for data protection or IT services.
However, to carry out their role effectively they will ideally be a
member of the Top Management team and either have a strong
technical knowledge of information security management or
access to individuals who do.
Evidencing Leadership to
an Auditor
The Top Management will be the group of individuals who
set the strategic direction and approve resource allocation
for the organization or business area with your ISMS scope.
Depending on how your organization is structured, these
individuals may or not be the day-to-day management team.
An auditor will typically test leadership by interviewing one or
more members of your Top Management and assessing their
level of involvement and participation in the:
• evaluation of risks and opportunities;
• establishment and communication of policies;
• setting and communication of objectives;
• review and communication of system performance; and
• allocation of appropriate resources, accountabilities and
responsibilities.
TIP – Before your external audit, identify who from your Top
Management will meet with the external auditor and prepare
them for the interview with a dry run-through of the likely
questions they will be asked.
Leadership in this context means active
involvement in setting the direction of
the ISMS, promoting its implementation
and ensuring appropriate resources are
made available. This includes:
• ensuring that the ISMS objectives
are clear and aligned with overall
strategy;
• that there is clarity on responsibilities
and accountabilities;
• that risk-based thinking is at the heart
of all decision making; and
• that there is clear communication
of this information to all individuals
within your ISMS scope.
ISO 27001 places great importance
on active engagement by Top
Management in the ISMS, based on
the assumption that the engagement of
Top Management is crucial in ensuring
the effective implementation and
maintenance of an effective ISMS by
the wider employee group.
The Importance of Leadership

CLAUSE 6:
PLANNING
ISO 27001 is at heart a risk management tool that steers an organization to identify the drivers of its information
security risks from the full range of sources. As such, the underlying purpose of an ISMS is to:
• identify the strategically important, blatantly obvious, and hidden but dangerous risks;
• ensure that an organization’s day-to-day activities and operating processes are designed, directed
and resourced to inherently manage those risks; and
• automatically respond and adapt to changes to cope with new risks and continually reduce the
organization’s risk exposure.
Having a detailed action plan that is aligned, updated and supported by regular reviews and monitoring is crucial,
and provides the best evidence to the auditor of clearly defined system planning.
ISO 27005 – Information security risk
management offers guidance on developing
a risk assessment technique for your
organization. Whichever technique you select
or develop, it should include the following
key elements:
1 Provide a prompt for systematic identification of
risks (e.g. reviewing assets, groups of assets,
processes, types of information) one at a time,
checking each for the presence of common
threats and vulnerabilities, and recording the
controls you currently have in place to
manage them.
2 Provide a framework for assessing the likelihood
of each risk occurring on a consistent basis
(e.g. once a month, once a year).
3 Provide a framework for assessing the
consequences of each risk occurring on
a consistent basis (e.g. £1,000 loss,
£100,000 loss).
4 Provide a framework for scoring or categorizing
each risk identified on a consistent basis (e.g.
1-10, high/medium/low), taking into account your
assessment of the likelihood and consequences.
5 Set out documented criteria which specifies,
for each risk score or category, what type of
action needs to be taken and the level or priority
assigned to it.
Risk Assessment
Risk assessment is at the core of any effective ISMS.
Even the most well-resourced organization cannot
completely eliminate the possibility of an information
security incident occurring. For all organizations, risk
assessment is essential to:
• increase the likelihood of identifying all potential risks
through the involvement of key individuals using
systematic assessment techniques;
• allocate resources to tackle the highest priority areas;
and
• make strategic decisions on how to manage significant
information security risks that will more likely realize their
objectives.
Most risk assessment frameworks consist of a
table containing the results of elements 1-4 with a
supplementary table or matrix covering point 5.
An external auditor will expect to see a record of your risk
assessment, an assigned owner for each risk identified
and the criteria you have used.
TIP – Annex A (8.1.1) contains a requirement to maintain
a list of information assets, assets associated with
information (e.g. buildings, filing cabinets, laptops) and
information processing facilities. If you complete your risk
assessment by systematically assessing the risks posed
to every item on this list, then you will have satisfied two
requirements within the same exercise. Furthermore, for
each item on the list, if you assign an owner you will also
have satisfied another requirement in Annex A (8.1.2).
As the asset owner is also likely to be the risk owner, this
helps prevent duplication and potential confusion.

Risk Treatment
For each risk identified in your risk assessment, you must apply
consistent criteria to determine whether you should:
• accept the risk; or
• treat the risk (called “Risk Treatment”)
The Risk Treatment options available are normally one of the
following:
• Avoidance – stop undertaking the activity or processing the
information that is exposed to the risk.
• Removal – eliminate the source of the risk.
• Change the likelihood – implement a control that makes it less
likely that an information security incident will occur.
• Change the consequences – implement a control that will
lessen the impact if an incident occurs.
• Transfer the risk – outsource the activity or process to a third
party that has greater capability to manage the risk.
• Accept the risk – if there is no practical risk treatment available
to the organization, or the cost of the risk treatment is judged
to be greater than the cost of the impact, you may make an
informed decision to accept the risk. This would need to be
approved by Top Management.
An external auditor will expect to see a Risk Treatment Plan
(e.g. an action list) that details the risk treatment actions you
have implemented or plan to implement. The plan must be
sufficiently detailed to enable the implementation status of each
action to be verified. There will also need to be evidence that this
plan has been approved by the assigned risk owners and Top
Management.
Annex A and the Statement of
Applicability
All Risk Treatment options (with the exception of acceptance)
involve the implementation of one or more controls. Annex A to
ISO 27001 contains a list of 114 best practice information security
controls. You will need to consider whether to implement each
of these controls when formulating your Risk Treatment Plan.
The description of most of the 114 controls is fairly vague, so it is
strongly recommended that you review ISO 27002 which contains
more information on best practice ways of implementing them.
As evidence of you having completed this assessment, an
external auditor will expect you to produce a document called
a Statement of Applicability. Within this, for each of the 114
controls you must record:
• whether it is applicable to your activities, processes and
information security risks;
• whether you have implemented it or not; and
• if you have deemed it not applicable, your justification for
doing so.
For most organizations, the majority of the 114 controls will be
applicable, and they are likely to have already implemented a
number of them to some degree.
TIP - Your Statement of Applicability does not need to an overly
complex document. A simple table with column headings Control,
Applicable?, Implemented?, and Justification will suffice. It is also
advisable to record some information on how the control has been
applied (e.g. reference a procedure or policy) to help you more
readily answer any questioning from your external auditor.
Information Security
Objectives and Planning
to Achieve Them
At relevant levels within your organization you need
to have a documented set of information security-
related objectives. These can be at a top level and
apply organization-wide (e.g. “achieve ISO 27001
certification”) or departmental (e.g. “complete
Information Security Briefings for all new starters
within 1 week of their start date”).
Each objective you set must:
• be measurable;
• be aligned with your Information Security Policy;
• take account of the organization’s information
security requirements; and
• take account of the output from the risk
assessment and risk treatment process.
Typical objectives that are relevant to
information security include:
• Not exceeding a defined frequency of certain types
of information security incidents.
• Achieving a measurable level of compliance with
information security controls.
• Providing a defined availability of information
services.
• Not exceeding a measurable number of data
errors.
• Making improvements to available resources
through recruitment, training or acquisition.
• Implementation of new controls.
• Achieving compliance with information security-
related standards.
Each objective must be communicated to relevant
persons. The objectives must be updated when
necessary to keep them relevant and to assess
performance against them.
For each of the objectives you need to
plan how you are going to achieve them.
This includes determining:
• what needs to be achieved;
• what resources are assigned;
• who has ownership or primary responsibility for
delivering against the objective;
• whether there is a target date for completion or just
an ongoing requirement; and
• the method of assessing performance against the
objective (i.e. what is your measure).
TIP - Effective ways to communicate Information
Security Objectives include covering them in
induction training, setting them as employee
objectives or including them in employee appraisals,
establishing them in SLAs with suppliers, or
evaluating performance against them in supplier
performance reviews.

CLAUSE 7:
SUPPORT
Competence
The implementation of effective information security controls
relies heavily on the knowledge and skills of your employees,
suppliers and contractors. To be certain of an appropriate
knowledge and skills base you need to:
• define what knowledge and skills are required;
• determine who needs to have the knowledge and skills; and
• set out how you can assess or verify that the right people
have the right knowledge and skills.
Your auditor will expect you to have documents detailing
your knowledge and skills requirements. Where you believe
the requirements are satisfied this will need to be supported
with records such as training certificates, course attendance
records or internal competency assessments.
TIP – Most organizations that already use tools such as
training/skills matrices, appraisals or supplier assessments can
satisfy the requirement for competence records by expanding
the areas covered to include information security.
Awareness
In addition to ensuring specific competence of key personnel
in relation to information security, the wider group of
employees, suppliers and contractors will need to be aware of
the basic elements of your ISMS. This is central to establishing
a supportive culture within the organization.
All staff, suppliers and contractors should be aware of the
following:
• That you have an ISMS and why you have one.
• That you have an Information Security Policy and which
particular elements of it are relevant to them.
• How they can contribute to your organization protecting its
valuable information and what they need to do to help the
organization achieve its information security objectives.
• Which policies, procedures and controls are relevant to them
and what the consequences are of not complying with them.
TIP – The communication of this information can normally
be done through existing processes and documents such
as inductions, employment contracts, toolbox talks, supplier
agreements, employee briefings or updates.
Communication
To enable the processes in your ISMS to work effectively you
will need to ensure you have communication activities that are
well planned and managed. ISO 27001 details these concisely
by requiring you to determine:
• what needs to be communicated;
• when it needs to be communicated;
• to whom it needs be communicated;
• who is responsible for communication; and
• what is the processes for communication.
TIP – If your communication requirements are well defined in
your processes, policies and procedures then you do not need
to do any more to satisfy this requirement. If they aren’t then
you should consider documenting your key communication
activities in the form of a table or procedure that includes the
headings detailed above. Remember, the content of these
documents also needs to be communicated!
Clause 7 concerns itself with resources. This applies to people, infrastructure and
environment as much as physical resources, materials, tools etc. There is also a renewed
focus on knowledge as a significant resource within your organization. When planning your
quality objectives, a major consideration will be the current capacity and capability of your
resources as well as those you may need to source from external suppliers / partners.
To implement and maintain an
effective ISMS you need to have
supporting resources in place. These
resources will need to be sufficiently:
• capable – if they are equipment or
infrastructure; and
• competent – if they are people.
• at Management Review meetings.

Documented Information
To be of use, the documented information you use to
implement and maintain your ISMS needs to:
• be accurate;
• be understandable to the individuals who use it regularly or
occasionally; and
• support you to comply with legal requirements, manage
information security risks and achieve your objectives.
So that your documented information always satisfies these
requirements you will need to have processes in place to
ensure that:
• documented information is reviewed where required by
appropriate individuals before it is released into general
circulation;
• access to documented information is controlled so that
it cannot be changed accidentally, corrupted, deleted or
accessed by individuals to whom it is not appropriate;
• information is deleted securely or returned to its owner when
there this a requirement to do this; and
• you can track changes to information to guarantee that the
process is in control.
The source of your documented information may be either
internal or external, so your control processes need to manage
documented information from both sources.
TIP – Organizations that have good document control typically
have one or more of the following in place:
• A single person or small team responsible for ensuring
that new/modified documents are reviewed before they are
issued, are stored in the right location, are withdrawn from
circulation when superseded and that a register of changes
is maintained.
• An electronic document management system that contains
automatic workflows and controls.
• Robust electronic data back-up and hard-copy file archiving/
storage processes.
• Strong employee awareness of document control, record
keeping and information access/retention requirements.

CLAUSE 8:
OPERATION
Managing your information security risks and achieving your
objectives requires the formalisation of your activities into a set
of clear and coherent processes.
Many of these processes are likely to exist already (e.g.
induction, training) and will simply need modifying to include
elements relevant to information security. Other processes may
happen in an ad-hoc fashion (e.g. supplier approvals), while
some may not currently exist at all (e.g. internal audit).
To implement effective processes the following
practices are crucial:
1 Processes are created by adapting or formalising an
organization’s “business as usual” activities.
2 Systematic identification of the information security risks
relevant to each process.
3 Clear definition and communication of the set of activities
required to manage the associated information security
risks when an event occurs (e.g. a new employee joining
the company).
4 Clear assignment of the responsibilities for carrying out
related activities.
5 Adequate allocation of resources to ensure that related
activities can take place as and when required.
6 Routine assessment of the consistency with which each
process is followed and its effectiveness in managing
relevant information security risks.
TIP – For each process, designate an individual as
accountable for ensuring that steps 2-6 happen. This individual
is often referred to as the Process Owner.
Information Security Risk
Assessment
The risk assessment methods and techniques described in
Clause 6 must be applied to all processes, assets, information
and activities within the organization’s ISMS scope.
Since risks are not static, the results of these assessments
must be reviewed at appropriate frequencies. This is usually at
least annually, or more frequently if the assessment identifies
the presence of one or more significant risks. Risks should also
be reviewed whenever:
• any Risk Treatment actions are completed (see below);
• there are changes to the organization’s assets, information or
processes;
• new risks are identified; or
• experience or new information indicates that the likelihood
and consequence of any identified risk has changed.
TIP – To ensure your risk assessment process covers the types
of events that would require a review, you should also take into
consideration the Annex A controls for Technical Vulnerability
Management (A.12.6), Security in Development and Support
Processes (A.14.2) and Supplier Service Delivery Management
(A.15.2).
Information Security Risk
Treatment
The risk treatment plan you develop cannot simply remain as
a statement of intent; it must be implemented. Where changes
are needed to take into account new information about risks
and changes to your risk assessment criteria, the plan needs
to be updated and re-authorised.
The impact of the plan must also be assessed and the results
of this assessment recorded. This may be done as part of your
Management Review or Internal Audit Processes or by using
technical assessments such as network penetration tests,
supplier audits or unannounced third part audits.
So, after all the planning and risk assessment, we’re ready to move on to the “do” stage.
Clause 8 is all about having appropriate control over the creation and delivery your
product or service.

CLAUSE 9:
PERFORMANCE
EVALUATION
Monitoring, Measurement,
Analysis and Evaluation
Your organization will need to decide what needs to be
monitored to be assured that your ISMS process and
information security controls are operating as intended. It is
impractical for an organization to monitor everything all the
time; if you attempt to do so, it is likely that the volume of
data would be so great that it would be virtually impossible to
use it effectively. Therefore, in practice, you will need to take
an informed decision about what to monitor. The following
considerations will be important:
• Which processes and activities are subject to the most
frequent and significant threats?
• Which processes and activities have the most significantly
inherent vulnerabilities?
• What is practical to monitor and generate meaningful and
timely information from?
• With each monitoring process you put in place, for it to be
effective you must clearly define:
• how the monitoring is undertaken (e.g. is this defined in a
procedure);
• when it is undertaken;
• who is responsible for undertaking it;
• how are the results reported, when, to whom and what do they
do with them; and
• if the monitoring results identify unacceptable performance,
what is the escalation process or procedure to deal with this
situation.
To demonstrate to an auditor that you have appropriate
monitoring processing in place, you will need to retain records
of monitoring results, analysis, evaluation reviews and any
escalation activities.
Internal Audits
The purpose of internal audits is to test your ISMS processes
for weaknesses and identify opportunities for improvement.
They are also an opportunity to provide a reality check to Top
Management on how strongly the ISMS is performing. When
done well, internal audits can ensure that there are no surprises
at your external audits.
The internal audits you perform should check:
• how consistently processes, procedures and controls are
followed and applied;
• how successful your processes, procedures and controls are
at generating the intended results; and
• whether your ISMS remains compliant with ISO 27001 and the
requirements of interested parties.
To ensure that audits are undertaken to a high standard
and in a way that is seen to add value, they need to be
undertaken by individuals who:
• are respected;
• competent
• understand the requirements of ISO 27001; and
• can quickly interpret your documentation and are well-
practiced in sound auditing techniques and behaviours.
Most importantly of all, they need to be allocated sufficient
time to do the audit and be assured of cooperation from
relevant employees. You must maintain a plan for carrying
out your internal audits. An external auditor will expect this
plan to ensure that all of your ISMS processes are audited
over a three-year cycle and that processes which:
• have shown evidence of poor performance (i.e. through
previous audits, or monitoring results or information security
incidents); and/or
• manage the most significant information security risks
• are audited at a higher frequency.
The external auditor will also expect that any actions identified
from audits are recorded, reviewed by appropriate employees
and actions implemented in a timely manner to rectify any
significant issues. They should make an allowance in the
close-out time for any improvement opportunities identified that
require significant investment in resources.
There are three main ways in which the
performance of an ISMS is evaluated.
These are:
• monitoring the effectiveness of the
ISMS controls;
• through internal audits; and
• at Management Review meetings.

Management Review
Management Review is an essential element of an ISMS. It is the
formal point at which Top Management reviews the effectiveness
of the ISMS and ensures its alignment to the organization’s
strategic direction. Management Reviews must take place at
planned intervals and the overall review programme (i.e. one
meeting or several meetings) must at a minimum cover a list of
core areas specified within clause 9.3 of the standard.
It is not essential for one single Management Review meeting to
take place covering the full agenda. If you currently hold a range
of meetings that cover the inputs between them, there is no
specific need to duplicate them.
You will need to retain documented information on your
Management Reviews. These would normally be minutes of
meetings or perhaps call recordings if you carry out conference
calls. These do not need to be extensive notes, but they must
contain a record of any decisions made and actions agreed,
ideally with responsibilities and timescales.
TIP – If you decide to adapt your existing schedule of
management meetings and these meetings cover a number of
areas, you may want to consider summarising the areas that
these meetings cover in the form of a table or procedure so that
it is clear to you and an auditor which meetings cover each of
the required review areas.

CLAUSE 10:
IMPROVEMENT
Nonconformity and
Corrective Action
One of the main drivers of improvement is to learn from security
incidents, issues identified in audits, performance issues
identified from monitoring, complaints from interested parties and
ideas generated at management reviews.
For each learning opportunity identified you must maintain a
record of:
• what occurred;
• if the event had undesirable consequences, what action was
taken to contain and mitigate those;
• the root cause of the event (if determined);
• the action taken to eliminate the root cause (if needed); and
• an assessment of the effectiveness of any action taken.
The key aim of implementing an ISMS should be to reduce the likelihood of information
security events occurring and their impact. No ISMS is likely to be perfect. However,
a successful ISMS will improve over time and increase the organization’s resilience to
information security attacks.
Root cause analysis
To identify effective corrective action, it is strongly
advisable to complete a root cause analysis of the issue
that occurred. If you don’t get to the bottom of why or
how it happened, then it is likely that whatever fix you
implement will not be fully effective. A simple approach
such as “5 Whys” is a good root cause analysis tool:
start with the issue, then ask “Why” enough times
to reach the root cause. Usually 5 times of asking is
enough, but for more complex problems you may need
to dig deeper.
For example:
Problem statement:
The organization was infected by the Wannacry
virus
Why?
Someone clicked on a link in an email and it
downloaded the virus and infected their PC
Why?
They had not received any training in clicking on
links in emails they are not expecting to receive
Why?
The training manager is on maternity leave and the
organization has not implemented cover for them
Why?
The maternity leave process is not covered in the
Change Management Procedure and so a risk
assessment was not completed to identify any
information security risks.
TIP – You may not have sufficient resources to
undertake root cause analysis for every event. To
prioritise your efforts, you should consider first
completing a simple risk assessment of an event and
then undertake root cause analysis only for those that
are medium or high risk.

GET THE MOST
FROM YOUR
MANAGEMENT
SYSTEMS
Top Tips for the successful implementation of an ISMS
1. Start with “Why?”. Make sure the
reasons for implementing an ISMS are
clear and aligned with your strategic
direction, otherwise you risk not
getting the critical buy-in from Top
Management.
2. Next consider “What for?”.
Implementing and maintaining an ISMS
requires significant commitment, so
make sure your scope is broad enough
to cover the critical information that
needs protecting, but is not so broad
that you do not have sufficient resources
to implement and maintain it.
3. Get all of your key stakeholders
involved at the appropriate times. Top
Management for context, requirements,
policy and objectives setting; managers
and employees with valuable knowledge
for risk assessments, process design
and procedure writing.
4. Communicate extensively throughout
the process to all of your stakeholders.
Let them know what you are doing, why
you’re are doing it, how you plan to do
it and what their involvement will be.
Provide regular progress updates.
5. Get external help where you need it.
Do not fail for lack of in-house technical
skills or knowledge. Management of
information security risks often requires
specialist knowledge. However, be sure
to check the credentials of a third party
before engaging them.
6. Keep your processes and supporting
documentation simple. It can develop
to become more extensive over time if
needed.
7. Design and implement rules you
can follow in practice. Don’t make
the mistake of documenting an over-
elaborate rule that no-one can follow. It
is better to accept a risk and to continue
to look for ways to manage it.
8. Remember your suppliers. Some
suppliers will help you enhance your
ISMS, some will increase your risk. You
need to ensure any high-risk suppliers
have controls in place that are at least
as good as yours. If they don’t then look
for alternatives.
9. Train, train and train again. Information
Security is likely to be a new concept
for many or most of your employees.
People may need to change habits
ingrained over many years. A single
awareness briefing is unlikely to be
sufficient.
10. Remember to allocate sufficient
resources to routinely test your controls.
The threats your organization faces will
constantly change and you need to test
whether you are able to respond
to those threats.

STOR-A-FILE AND
ISO 27001:2013
CASE STUDY
Stor-a-File set on a path to certification by ensuring they
increased their knowledge into ISO 14001, a standard that
targets environmental management, and ISO 27001, a
standard that focuses on cybersecurity strategies, customer
confidence, asset protection and more. NQA offered resources
in the form of blogs, webinars and videos for the team to
review before the company underwent two successful audits
by experienced assessors.
As a part of its commitment to drive internal growth, Stor-
a-File also started refresher team meetings, plus hung staff
communications for ISO certification in communal areas.
ACHIEVING CERTIFICATION
WITH NQA
Following its successful audits for ISO 27001 and ISO 14001,
Stor-a-File attained its goal not only to receive certification
for those standards but also to consolidate them with a
single provider. It was a smooth, streamlined experience that
prompted Stor-a-File to schedule a transition audit for June
2018 for its ISO 9001 certification.
Looking back on the recent experience with our
certification body, Gavin Prior, the operations director of
Stor-a-File, remarked:
“Consolidating our key management systems with NQA
has allowed our SME business to reinforce our foundations,
ensuring we strive to improve our multisite operational
effectiveness and build a reputation that services our clients’
requirements, whilst maintaining a flexible and adaptive
approach.”
Nick Wright, managing director at NQA, commented:
“We’re proud of the longstanding relationship we’ve built with
Stor-a-File. It’s a testament to what we bring to the table as a
partner, and we’re excited about what we could do for Stor-a-
File recently, from cutting down on the inefficiencies of multiple
audits to improving team communication and learning. We’re
looking forward to seeing what standards they focus on next
and how they no doubt continuously improve the systems they
have in place.”
With more than 40 years’ of experience, Stor-a-File has established a reputation for secure
and confidential document storage, scanning, shredding and microfiche conversion at
locations throughout the UK, including London, Merseyside, and across the Midlands. Its
dedication to safety and security prompted the family-owned company to take the steps
to gain certification to particular ISO standards: ISO 27001 (information security) and ISO
14001 (environmental), to complement its ISO 9001 certification for quality management.
Gaining the various ISO certifications,
whilst being a challenge, has been
very rewarding. It allows you to look
at how your business operates and
how the standards work within it.
This has meant being able to adopt
an impartial approach to the work
required and address it accordingly.
It has been an energised team effort,
which we will be building upon to
ensure that we enhance all areas.

ISO 27001:2013 IMPLEMENTATION GUIDE30 ISO 27001:2013 IMPLEMENTATION GUIDE30
NEXT STEPS ONCE
IMPLEMENTED
AWARENESS TRAINING
• Your organization should raise awareness about
various standards covered under IMS.
• You should hold separate training meetings for top
management, middle management and junior level
management, which will help to create a motivating
environment, ready for implementation.
POLICY AND OBJECTIVES
• Your organization should develop an Integrated
Quality Policy/Environment Policy/Health & Safety
Policy/Information Security Policy and relevant
objectives to help meet the requirements.
• By working with top level management your company
should hold workshops with all levels of management
staff to outline the integrated objectives.
INTERNAL GAP ANALYSIS
• Your organization should identify and compare the
level of compliance of existing systems against
requirements of the standards under your new IMS.
• Relevant staff should all understand the operations of
the organization and develop a process map for the
activities within the business.
DOCUMENTATION / PROCESS DESIGN
• The organization should create documentation
of the processes as per requirements of relevant
standard(s).
• You should write and implement a manual, functional
procedures booklet, work instructions, system
procedures and provide associated terms.
DOCUMENTATION / PROCESS
IMPLEMENTATION
• Processes / Documents developed in step 4, should
be implemented across the organization covering all
the departments and activities.
• The organization should hold a workshop on the
implementation as per applicable for the ISO
standard requirements.
5
4
3
2
1
INTERNAL AUDIT
• A robust internal audit system for the organization is
essential. Internal Auditor Training is recommended
and NQA can provide Internal Auditor Training for the
standard(s) that you are implementing.
• It is important to implement corrective actions for
improvements, in each of the audited documents, in
order to bridge gaps and ensure effectiveness of IMS.
ORGANISE A MANAGEMENT ‘SYSTEM’
REVIEW MEETING
• Top level management must review various official
business aspects of the organization, which are
relevant to the standards being implemented.
• Review the policy, objectives, results of internal
audit, results of process performance, results of
complaints/feedback/legal compliance, results of risk
assessment/incidents and develop an action plan
following the meeting - which must be minuted.
THOROUGH GAP ANALYSIS OF
IMPLEMENTED SYSTEMS
• A formal pre-certification gap analysis should be
conducted to assess effectiveness and compliance of
system implementation in the organization.
• This final gap analysis will prepare your organization
for the final certification audit.
CORRECTIVE ACTIONS
• The organization should be ready for final
certification audit, providing that the gap analysis
audit conducted in the last step and all the non-
conformities (NC) have been assigned corrective
actions.
• Check that all the significant NCs are closed and the
organization is ready for the final certification audit.
FINAL CERTIFICATION AUDIT
• Once completed, your organization is hopefully
recommended for registration to the required
standard.
• CONGRATULATIONS!10
9
8
7
6

NOTES

www.nqa.com
USEFUL LINKS
Information Security Management Training
https://www.nqa.com/training/information-security
Information Commissioners Office
https://ico.org.uk/
ISO - International Organization for Standardization
https://www.iso.org/home.html
Authored on behalf of NQA by: Julian Russell

NQA ISO 27001 Implementation Guide

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