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How to maintain ISO compliance
When your organization has gone through the process of achieving ISO 27001 compliance, and you receive that coveted certification, you feel like you’ve crossed a long-awaited finish line. That’s only the beginning.
Maintaining your ISO 27001 compliance requires ongoing effort and monitoring. Let’s take a look at what it takes to maintain your certification and the best ways to remain compliant, even between recertifications.
The mechanics: The ISO certification maintenance process
Your ISO 27001 certification won’t stay valid forever. ISO compliance is an ongoing process. When you receive your certification, it’s technically valid for three years. However, each year, your auditor will conduct a preliminary audit to check select aspects of your ISMS and see if they are in compliance.
If these aspects aren’t up to snuff, you’ll need to go through another full audit, just like you did in the first year, to keep your certification.
In other words, here’s a typical timeline:
Year 0: You successfully complete a full audit and receive your ISO 27001 certification
Year 1: Preliminary audit
Year 2: Preliminary audit
Year 3: New full audit
How to maintain your ISMS compliance: Top strategies
It’s easy for aspects of your ISMS to change and leave you falling short of ISO 27001 compliance. It may be due to integrated software updates, lack of follow-through with your security policies, or a host of other possibilities. Follow these essential tips to stay in compliance throughout your entire three-year audit cycle and beyond.
Use continuous monitoring with an automated compliance platform
The tools and platforms you integrate with, including cloud providers and other key aspects of your ISMS, will have an impact on ISO 27001 compliance. It’s important to monitor your integrated products as well as the rest of your ISMS for breaches and compliance-breaking issues. To do this thoroughly, you’ll need a continuous monitoring strategy.
An automated platform will instantly alert you when something falls out of place. This gives you immediate action items, so when it comes time for your next preliminary audit, you won’t get caught off guard. Instead of manually monitoring your system, an automated compliance tool can scan your system, gathers evidence of your compliance, and indicate any requirements you’re missing, all without hands-on engineering time.
Establish and enforce a clear onboarding and offboarding process
Much of ISO 27001 compliance centers on limiting access to sensitive data so it’s only visible to necessary personnel. Staying compliant hinges on your ability to quickly and thoroughly remove access when employees and contractors leave or change positions.
It’s critical to establish a clear and consistent onboarding and offboarding process so those changes happen swiftly and correctly. Make sure this process is also well documented so it isn’t compromised when you have turnover in the employees who make those changes.
Update risk management policies as new threats arise
Hackers and seedy organizations are busy finding new ways to get around security blocks. There will always be new hacking techniques, new trends, and new vulnerabilities that arise. Assign a team member to stay aware of the latest developments and to bring up discussions and changes to be made when new risks arise.
Maintain a unified storage location for all ISO 27001 documentation
One of the most challenging aspects of ISO 27001 certification is gathering all the documentation your auditor will need to see. This includes policies and procedures, vulnerability reports, and more. To make documentation easier, set up a unified storage location that will house all of this documentation. Make sure you can easily see when documents were last updated so you know what may need an update before your next audit.
Clearly identify responsible professionals
Depending on the size and complexity of your organization and your ISMS, it’s easy for aspects of your security and your ISO compliance to slip through the cracks because each person thinks it’s someone else’s responsibility. To avoid these misunderstandings, establish clear definitions of which team members are responsible for which aspects of your ISMS and your ISO 27001 compliance.
Set up a clear succession plan
While compliance and security issues can fall through the cracks at any point because of misunderstandings, your business is especially at risk when you have turnover on your security team. You never know when a fireable offense will happen, and if a security employee resigns, you want to have the flexibility to waive their last two weeks for your organization’s safety.
This requires a clear succession plan for each person on the team, documenting who will cover which aspects of their responsibilities if they leave unexpectedly. You also need detailed documentation that will allow your new team members to pick up on their responsibilities quickly and smoothly.
Maintaining your ISO 27001 compliance
Keeping your ISO 27001 compliance up to date is a critical way to protect your clients’ data, your revenue, and your reputation. The tips above can help you maintain your compliance more reliably and easily. The first step is getting a trustworthy compliance tool on your side. Learn more about Vanta’s automated compliance platform and how it can help you maintain your compliance year after year.
Determine whether the GDPR applies to you and if so, if you are a processor or controller (or both)
Do you sell goods or service in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Create a Data Map by taking the following actions
Identify and document every system (i.e. database, application, or vendor) which stores or processes EU or UK based personally identifiable information (PII)
Document the retention periods for PII in each system
Determine whether you collect, store, or process “special categories” of data
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
Determine your grounds for processing data
For each category of data and system/application have you determined the lawful basis for processing based on one of the following conditions?
Take inventory of current customer and vendor contracts to confirm new GDPR-required flow-down provisions are included
Review all customer contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Review all in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Have you performed a risk assessment on vendors who are processing your PII?
Determine if you need to do a Data Protection Impact Assessment
Is your data processing taking into account the nature, scope, context, and purposes of the processing, likely to result in a high risk to the rights and freedoms of natural persons?
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Does the notice to the data subject include the following items?
Does the notice also include the following items?
Do you have a mechanism for persons to change or withdraw consent?
Update internal privacy policies to comply with notification obligations
Update internal privacy notices for EU employees
Determine if you need to appoint a Data Protection Officer, and appoint one if needed
Have you determined whether or not you must designate a Data Protection Officer (DPO) based on one of the following conditions (Art. 37)?
If you export data from the EU, consider if you need a compliance mechanism to cover the data transfer, such as model clauses
If you transfer, store, or process data outside the EU or UK, have you identified your legal basis for the data transfer (note: most likely covered by the Standard Contractual Clauses)
Have you performed and documented a Transfer Impact Assessment (TIA)?
Confirm you are complying with other data subject rights (i.e. aside from notification)
Do you have a defined process for timely response to Data Subject Access Requests (DSAR) (i.e. requests for information, modification or deletion of PII)?
Are you able to provide the subject information in a concise, transparent, intelligible and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need to appoint an EU-based representative, and appoint one if needed
Have you appointed an EU Representative or determined that an EU Representative is not needed based on one of the following conditions?
If operating in more than one EU state, identify a lead Data Protection Authority (DPA)
Do you operate in more than one EU state?
If so, have you designated the Supervisory Authority of the main establishment to act as your Lead Supervisory Authority?
Implement Employee Trainings to Demonstrate Compliance with GDPR Principles and Data Subject Rights
Have you provided appropriate Security Awareness and Privacy training to your staff?
Update internal procedures and policies to ensure you can comply with data breach response requirements
Have you created and implemented an Incident Response Plan which included procedures for reporting a breach to EU and UK Data Subjects as well as appropriate Data Authorities?
Do breach reporting policies comply with all prescribed timelines and include all recipients i.e. authorities, controllers, and data subjects?
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measure ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed?
Develop a roadmap for successful implementation of an ISMS and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider ISO 27001 certification costs relative to org size and number of employees
Clearly define scope of work to plan certification time to completion
Select an ISO 27001 auditor
Set the scope of your organization’s ISMS
Decide which business areas are covered by the ISMS and which are out of scope
Consider additional security controls for business processes that are required to pass ISMS-protected information across the trust boundary
Inform stakeholders regarding scope of the ISMS
Establish an ISMS governing body
Build a governance team with management oversight
Incorporate key members of top management, e.g. senior leadership and executive management with responsibility for strategy and resource allocation
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Execute a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks
Summarize each identified risk
Indicate the impact and likelihood of each risk
Document a risk treatment plan
Design a response for each risk (Risk Treatment)
Assign an accountable owner to each identified risk
Assign risk mitigation activity owners
Establish target dates for completion of risk treatment activities
Complete the Statement of Applicability worksheet
Review 114 controls of Annex A of ISO 27001 standard
Select controls to address identified risks
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in the ISMS implementation
Continuously assess and manage risk
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
Assemble required documents and records
Review ISO 27001 Required Documents and Records list
Customize policy templates with organization-specific policies, process, and language
Establish employee training and awareness programs
Conduct regular trainings to ensure awareness of new policies and procedures
Define expectations for personnel regarding their role in ISMS maintenance
Train personnel on common threats facing your organization and how to respond
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements
Perform an internal audit
Allocate internal resources with necessary competencies who are independent of ISMS development and maintenance, or engage an independent third party
Verify conformance with requirements from Annex A deemed applicable in your ISMS's Statement of Applicability
Share internal audit results, including nonconformities, with the ISMS governing body and senior management
Address identified issues before proceeding with the external audit
Undergo external audit of ISMS to obtain ISO 27001 certification
Engage an independent ISO 27001 auditor
Conduct Stage 1 Audit consisting of an extensive documentation review; obtain feedback regarding readiness to move to Stage 2 Audit
Conduct Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls
Address any nonconformities
Ensure that all requirements of the ISO 27001 standard are being addressed
Ensure org is following processes that it has specified and documented
Ensure org is upholding contractual requirements with third parties
Address specific nonconformities identified by the ISO 27001 auditor
Receive auditor’s formal validation following resolution of nonconformities
Conduct regular management reviews
Plan reviews at least once per year; consider a quarterly review cycle
Ensure the ISMS and its objectives continue to remain appropriate and effective
Ensure that senior management remains informed
Ensure adjustments to address risks or deficiencies can be promptly implemented
Calendar ISO 27001 audit schedule and surveillance audit schedules
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
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Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
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