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

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

1

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?

If any of the above apply to your business, you’ll need to get GDPR compliant.
2

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

racial or ethnic origins
genetic data
political opinions
biometric data that can uniquely identifying someone
religious or philosophical beliefs
health, sex life or sexual orientation data
trade union membership

Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)

the name and contact details of the controller
the purpose behind the processing of data
a description of the categories of data that will be processed
who will receive the data including data
documentation of suitable safeguards for data transfers to a third country or an international organization
the retention period of the different categories of data
a general description of the technical and organizational security measures

Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf

the name and contact details of the processor or processors and of each controller on behalf of which the processor is acting, and, where applicable, of the controller’s or the processor’s representative, and the data protection officer
the categories of processing carried out on behalf of each controller
documentation of suitable safeguards for data transfers to a third country or an international organization
a general description of the technical and organizational security measures
3

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?

consent of the data subject
contract with the data subject
necessary for compliance with a legal obligation
necessary in order to protect the vital interests of the data subject or a third party
necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller
necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the rights of data subject
4

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)

Do your agreements cover the following items?
vendor shall process the personal data only on documented instructions (including when making an international transfer of personal data) unless it is required to do otherwise by EU or member state law
vendor ensures that persons authorized to process the personal data are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.
vendor have adequate information security in place, technical and organizational measures to be met to support data subject requests or breaches
vendor shall not appoint or disclose any personal data to any sub-processor unless required or authorized
vendor shall delete or return all the personal data after the end of the provision of services relating to processing, and deletes existing copies unless Union or Member State law requires storage of the personal data;
vendor makes available all information necessary to demonstrate compliance and allow for and contribute to audits, including inspections

Have you performed a risk assessment on vendors who are processing your PII?

5

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?

Does your processing involve any of the following?
automated processing, including profiling, and on which decisions are based that produce legal effects
special categories of data or data related to criminal convictions and offenses
monitor publicly accessible area on a large scale.
If any of the above are true, you may need to conduct a Data Protection Impact Assessment for existing and new data projects.
6

Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated

Do you have a public-facing Privacy Policy which covers the use of all your products,  services and websites?

Does the notice to the data subject include the following items?

the identity and the contact details of the organization and its representative
the contact details of the data protection officer, if applicable
the purposes to process personal data and its legal basis for the processing
the recipients or categories of recipients of the personal data, if any
the details regarding any transfer of personal data to a third country and the safeguards taken applicable

Does the notice also include the following items?

the retention period, or if that is not possible, the criteria used to determine that period
the existence of the data subject rights (i.e. requests for information, modification or deletion of PII)
the right to withdraw consent at any time
the right to lodge a complaint with a supervisory authority
whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data
the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the consequences

Do you have a mechanism for persons to change or withdraw consent?

7

Update internal privacy policies to comply with notification obligations

Update internal privacy notices for EU employees

Do you have an Employee Privacy Policy governing the collection and use of EU and UK employee data?

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)?

the data processing is carried out by a public authority
the core activities of the controller or processor require regular and systematic monitoring of data subjects on a large scale
8

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)?

9

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?

10

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?

data processing is occasional
data processing is not on a large scale
data processing doesn’t include special categories or data related to criminal convictions and offenses
doesn’t risk to the rights and freedoms of data subjects
a public authority or body
11

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?

12

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?

13

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?

14

Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk

This includes pseudonymization/ encryption, maintaining confidentiality, restoration of access following physical/technical incidents and regular testing of measures

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?

15

Consider streamlining GDPR compliance with automation

Transform manual data collection and observation processes into continuous monitoring

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1

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

2

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

3

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

4

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

5

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

6

Develop a risk register

Record and manage your organization’s risks

Summarize each identified risk

Indicate the impact and likelihood of each risk

7

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

8

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

9

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
  • Communication
  • Internal Audit
  • Management Review
  • Corrective Action and Continual Improvement
  • Policy Violations
10

Assemble required documents and records

Review ISO 27001 Required Documents and Records list

Customize policy templates with organization-specific policies, process, and language

11

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

12

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

13

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

14

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

15

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

16

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

17

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

18

Learn more about achieving ISO 27001 certification with Vanta

Book an ISO 27001 demo with Vanta

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1

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

2

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

3

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

4

Appoint a security and compliance point person in your company

Designate an employee as your HIPAA Compliance Officer

5

Schedule annual HIPAA training for all employees

Distribute HIPAA policies and procedures and ensure staff read and attest to their review

6

Document employee trainings and other compliance activities

Thoroughly document employee training processes, activities, and attestations

7

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

8

Institute an annual review process

Annually assess compliance activities against theHIPAA Rules and updates to HIPAA

9

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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