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ISO 27001: 2022 updates and what they mean for your organization

July 25, 2022

2022 is a big year for changes to the ISO 27001 and 27002 standards. As a result, we’re getting lots of questions. How will the new changes affect organizations that are already ISO 27001 certified? What about organizations that are preparing for certification? This article will highlight some of the key changes and their potential impacts.

 

Formal publication

First, the 2022 revision of ISO 27001 has not been formally published yet (as of July 2022). Regardless, we still have a good idea of what it will look like as the Annex A controls are aligned with the implementation guidance found in ISO 27002, which was published in February and is available here.

 

Implementation timeline

 

The formal timeline for adopting the new version has not been determined but most market watchers are anticipating at least 18 to 24 months.

 

Required management clauses are not changing

 

Organizations that have already implemented ISO 27001 understand that the framework is a management standard first and foremost. The management requirements for implementing and maintaining an Information Security Management System (ISMS) are contained in the ISO Clauses 4 through 10. Those clauses are not materially changing.

 

Changes to the Annex A controls

 

The major changes to the standard will be in the Annex A controls. For those who aren’t familiar, the Annex A controls are the normative control set that organizations apply to mitigate and manage information security risk. 

While they are not strictly required, most organizations implement the majority of Annex A controls, as they are broadly applicable to the information security risks that most organizations face. Let’s dig into these changes.

Organization of the controls

 

In the current framework, there are 114 controls organized into 14 categories (A.5-A.18). In the 2022 version, there are 93 controls organized into four categories (A.5-A.8). Although the organization of controls is substantially different, the content is more consistent. 

There are 12 net new controls which I list in this blog post. The remaining 81 controls are largely the same as existing controls—in some cases, the wording has been altered slightly or controls have been combined.

 

Control attributes

 

Another significant change to the look and feel of the new Annex A controls is the addition of an “Attribute Table” for each control. The Attributes are five pieces of metadata that give the user more insight into the function and intent of each control. The categories of Attributes are:

  • Control type
  • Information security properties
  • Cybersecurity concepts
  • Operational capabilities
  • Security domains

 

The Control types indicate “when and how the control modifies the risk.” The meaning of the three types is fairly self-evident:

  • Preventative
  • Detective
  • Corrective

 

A preventative control should be implemented to prevent an information security event or incident. A detective control detects the possible occurrence of an event or incident, and a corrective control is used to respond to an incident and restore a safe, secure operating environment. The Information security properties describe the aspect of information security protection the control contributes to. The properties are related to the familiar “CIA Triad”:

  • Confidentiality
  • Integrity
  • Availability

 

The Cybersecurity concepts are a logical grouping related to the association of controls in ISO 27110. The concepts are similar to the logical grouping used by the NIST Cybersecurity Framework. The concepts are:

  • Identify
  • Protect
  • Detect
  • Respond
  • Recover

 

The Operational capabilities describe 15 practitioner capabilities that these controls support. Most controls are related to a single capability, but a few controls relate to multiple. The capabilities are:

  • Governance
  • Asset management
  • Information protection
  • Human resource security
  • Physical security
  • System and network security
  • Application security
  • Secure configuration
  • Identity and access management
  • Threat and vulnerability management
  • Continuity
  • Supplier relationships security
  • Legal and compliance
  • Information security event management
  • Information security assurance

 

Finally, the controls are grouped into four high-level Security domains:

  • Governance and ecosystem
  • Protection
  • Defense
  • Resilience

 

The attributes are not requirements and are only to be used to the extent that an organization finds them helpful or useful. An organization is free to disregard, modify, or add to the attributes in accordance with its own ISMS and management preferences.

 

The current control “objectives” have been changed to “purpose” statements, and these purposes/objectives are listed for every control, not just at the control category level as they are in the current version. I’d argue that this makes the control purpose a bit clearer and more granular, and I expect most users will find this change helpful.

 

Content of control changes

 

ISO 27002 provides significant guidance with respect to each control. This is extremely useful as it gives a complete picture of the intent of the control, as well as practical examples regarding what implementation might look like. This guidance is also excellent for organizations that have achieved compliance and are now looking to understand or deepen their control maturity. While a complete article could be written about each net-new control, I’ll provide some highlights here.

 

5.7 Threat Intelligence: This is an extension of the previous control regarding subscribing to alerts. Assuming an organization is receiving alerts about threats and vulnerabilities, the next step is to develop the capability and associated processes for analyzing and assessing that information to create relevant and actionable intelligence.

 

5.16 Identity Management: The access management controls require the unique identification of individuals. The guidance states that non-human identities shall be managed, and shared accounts [shall be] limited and tightly controlled.

 

5.23 Security for Cloud Services: The guidance states that organizations shall implement processes, procedures, and policies for managing cloud services; ISO recognizes that the use of cloud services introduces certain risks for organizations that need to be proactively managed.

 

5.30 ICT Readiness for Business Continuity: This control requires planning and testing continuity plans for the organization’s technology. Many people think this is part of the current ISO standard, but the current Annex A technically only has controls addressing maintenance of information security continuity processes (but no explicit control to perform business continuity planning).

 

7.4 Physical Security Monitoring: A new control to continuously monitor protected physical spaces with technologies like cameras and/or physical intrusion detection systems.

 

8.1 User Endpoint Devices: The new guidance states that controls shall be implemented to protect information on endpoints (i.e. laptops).

 

8.9 Configuration Management: The new guidance states that secure configurations shall be defined and managed for hardware, software, and services.

 

8.10 Information Deletion: The new guidance states that data retention policies and processes shall ensure that data is deleted when no longer needed by the organization.

 

8.11 Data Masking: The new guidance states that controls shall be implemented to limit the exposure of sensitive data. The control language says “masking” but should be thought of more as “de-identification”, as the guidance includes pseudonymization and anonymization.

 

8.12 Data Leakage Prevention: This is a data loss prevention (DPL) control. The new guidance states that automated tools should prevent sensitive data from being sent to unauthorized recipients.

 

8.22 Web Filtering: The new guidance states that outbound web traffic should be filtered to prevent malware from connecting to command and control servers, as well as to prevent traffic to other malicious websites.

 

8.28 Secure Coding: The new guidance states that secure coding principles shall be applied to minimize vulnerabilities in code. The current control set requires rules for the secure development of software and systems, while the new control language is focused on the application and implementation of code security practices.

Looking forward

 

While the core ISMS management processes are not really changing, the Annex A control set has been updated to reflect more modern risks and their associated mitigating controls. Most of these new controls will already be familiar to information security practitioners. 

As ISO 27001 remains a risk-based management system, each organization will need to determine for themselves which controls are needed to mitigate their specific risks and at which level they will apply them.

Matt Cooper, Principal, Cybersecurity and Data Privacy

About the author: Matt leads the Privacy and Compliance team at Vanta. He has spent his 20+ year career in security and information technology. Prior to joining Vanta, Matt was the U.S. Director for the Cyber, Risk & Advisory practice at BSI where he led an information security consultancy providing risk management and readiness consulting for common industry frameworks such as ISO 27001, SOC2, HIPAA, and PCI. At Vanta, Matt works closely with audit partners, advises customers on security and compliance, and provides input to the product team.

Learn more about ISO 27001 

Who needs ISO 27001 certification?

The ISO 27001 Compliance Checklist

How to maintain ISO compliance