ISO 27001 Continual Improvement Policy Beginner’s Guide

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ISO 27001 Continual Improvement

In this ultimate guide I show you everything you need to know about the ISO 27001 Continual Improvement Policy and exactly what you need to do to satisfy it to gain ISO 27001 certification.

You will learn

  • what continual improvement is
  • understand why organisations need a Continual Improvement Policy
  • how to write an ISO 27001 Continual Improvement Policy

and I let you in on trade secret’s that’ll save you hours of time and effort.

What is an ISO 27001 Continual Improvement Policy?

The Continual Improvement Policy sets out the guidelines and the framework for how you manage when you identify that things are not working as intended.

The policy is about maintaining an effective information security management system so it continues to meet is intended goals.

ISO 27001 acknowledges that things are not always perfect and advocates for continually improving.

It is one of the ISO 27001 policies required by the ISO 27001 standard for ISO 27001 certification.

ISO 27001 Continual Improvement Policy Purpose

The purpose of the ISO 27001 Continual Improvement Policy is the continual improvement of the suitability, adequacy, and effectiveness of the information security policy and information security management system.

ISO 27001 Continual Improvement Principle

The information security management system is continually improved and enhanced through addressing incidents and non-conformities with an effective corrective action and management process.

Why the ISO 27001 Continual Improvement Policy is Important

Things change. When we first build and implement our information security management system things will operate effectively but the standard recognises that things are not perfect. There is always room for improvement.

In addition changes will occur within the organisation. Some of these will be intentional and some of these will be unintentional.

As changes occur then the information security management system will need to adapt.

If the management system does not adapt, then either incidents will occur or the process of audit will identify areas that are not longer working as intended.

All of this is fine and part of the natural process.

This policy is important because it sets out clearly how you identify these non-conformities and then how you manage and address them.

How to write an ISO 27001 Continual Improvement Policy

ISO 27001 is based on the principle of always improving.

It is a tool in our business arsenal and it forms part of the mandatory ISO 27001 documents.

It gets everyone on the same page and gives us a standard approach to we improve the information security management system.

Time needed: 1 hour and 30 minutes

How to write an ISO 27001 Continual Improvement Policy

  1. Write the ISO 27001 Continual Improvement Policy Page

    The contents of the continual improvement Policy should include:
    Document Version Control
    Document Contents Page
    Continual Improvement Policy
    Purpose
    Scope
    Principle
    Audit
    Internal Audits
    External Certification Audits
    Client and Third-Party Audits
    Incidents
    Change Management
    Management Review Team
    Review of Objectives
    Legal, Regulatory and Information Security Standards Change
    Improvement as a result of Non-Conformity
    Management of Improvement
    Policy Compliance
    Compliance Measurement
    Exceptions
    Non-Compliance
    Continual Improvement
    Areas of the ISO27001 Standard Addressed

  2. Write the ISO 27001 Continual Improvement Policy Purpose

    Record the purpose of the policy. An example of the purpose is – the continual improvement of the suitability, adequacy, and effectiveness of the information security policy and information security management system.

  3. Write the ISO 27001 Continual Improvement Policy Scope

    Scope is all employees and third party users and also the information security management system (ISMS).

  4. Write the ISO 27001 Continual Improvement Policy Principle

    The principle is the information security management system is continually improved and enhanced through addressing incidents and non-conformities with an effective corrective action and management process.

  5. Describe how you perform internal audits

    Internal audits are conducted to assess the effectiveness of the information security management system and the controls documented in the Statement of Applicability.
    Internal audits are conducted based on risk and business need.
    Internal audits are conducted by individuals independent of the area being audited.
    Internal audits are planned for the year.
    Internal audit results are reported to and overseen by the Management Review Team.
    Internal audits may result in a nonconformity requiring a corrective action or identifying an opportunity for improvement.

  6. Describe how you perform external audits

    External certification audits are conducted to assess the effectiveness of the information security management system and the controls documented in the Statement of Applicability.
    External certification audits are conducted based on the certification body requirements.
    External certification audits are planned for the year.
    External certification audits results are reported to and overseen by the Management Review Team.
    External certification audits may result in a nonconformity requiring a corrective action or identifying an opportunity for improvement.

  7. Describe how you perform client and third party audits audits

    Client and third-party audits are conducted to assess the effectiveness of the information security management system and the controls documented in the Statement of Applicability.
    Client and third-party audits are conducted based on agreement and subject to a contract and / or non-disclosure agreement being in place.
    Client and third-party audits results are reported to and overseen by the Management Review Team.
    Client and third-party audits may result in a nonconformity requiring a corrective action or identifying an opportunity for improvement.

  8. Explain the role of information security incidents

    Whilst you will have an incident management process and likely an incident management professional who can help here, our continual improvement policy is going to set out the role incidents play for continual improvement. An example:
    Incident management may result in a nonconformity requiring a corrective action or identifying an opportunity for improvement.

  9. Explain the role of change management

    Change management will consider and may identify an opportunity for improvement.

  10. Set out the role of the Management Review Team

    The management review team has an oversight role.
    The management review team as part of the structured management review team agenda consider opportunities for improvement.

  11. Document how the review of objectives contributes

    The review of information security objectives will consider and may identify an opportunity for improvement.

  12. Explain the role Legal, Regulatory and Information Security Standards Changes

    Changes as a result of legal and regulatory requirements or changes to applicable standards for information security will consider and may identify an opportunity for improvement.

  13. Describe Improvement as a result of Non-Conformity

    A non-conformity is a deviation from the norm. This is defined as a deviation from policy and / or process.

    Nonconformity to process or policy is identified by the audit process and the occurrence of incidents.

    When a nonconformity occurs, action is taken to correct it and deal with the consequences.

    Nonconformities are evaluated for the need to eliminate the causes of the non-conformity in order that it does not reoccur or occur elsewhere:
    – Reviewing the non-conformity
    – Determining the cause of the non-conformity
    – Determining if similar nonconformities exist or could potentially occur.

    Nonconformities are reported through the Management Review Team.

    Nonconformities are recorded, documented, and tracked in the incident and corrective action log.

    The effectiveness of corrective actions is reviewed.

  14. Explain the Management of Improvement

    Changes to the information security management system are planned and managed.

    Changes to the information security management are recorded in the incident and corrective action log or in a change log, as appropriate and relevant.

  15. Describe the process for policy compliance

    Set how compliance with the policy will be measured and enforced.

ISO 27001 Continual Improvement Policy Template

The Continual Improvement Policy Template is part of the Ultimate ISO 27001 Toolkit and also exclusively available stand-alone. It is prewritten, fully populated and ready to go and fully complies with ISO27001:2022.

ISO 27001 Continual Improvement Policy Template

ISO 27001 Continual Improvement Policy Example

This is a great example of the Continual Improvement Policy. Taking the first 3 pages being the contents of what it includes.

ISO 27001 Continual Improvement Policy FAQ

What are the benefits of ISO 27001 Continual Improvement Policy?

The following are benefits of having the ISO 27001 Continual Improvement Policy:
Improved security: You will address non-conformities in your information security management operation and keep paces with changes, ensuring that you continue to meet your information security objectives.
Reduced risk: Ensuring that the management system is audited, reviewed and incidents are managed will reduce the risk of attack and exploit
Improved compliance: Standards and regulations require that you monitor the effectiveness of your management system and continual improve.
Reputation Protection: In the event of a breach having effective continual improvement management will reduce the potential for fines and reduce the PR impact of an event

Who is responsible for the ISO 27001 Continual Improvement Policy?

This will depend on the structure and make up of your organisation. If you have a quality manager then it will sit them. Otherwise, responsibility will be assigned the information security manager.

Who is responsible for implementing the ISO 27001 Continual Improvement Policy?

The implementation of continual improvement is the responsibility of the area or function where the non-conformity has occurred.

How do you monitor the effectiveness of the ISO 27001 Continual Improvement Policy?

The approaches to monitoring the effectives of continual improvement include:
Obtaining relevant industry information security certificates
Internal audit of the continual improvement process
External audit of the continual improvement process
Review of incidents and changes

What are examples of a violation of the Continual Improvement Policy?

Examples of where the policy can fail or violations of the ISO 27001 Continual Improvement Policy can include:
Not conducting internal audits
Not recording the results of audits
Not responding to non-conformities that are identified

What are the consequences of violating the ISO 27001 Continual Improvement Policy?

Not managing non-conformities can have severe consequences for information security and the confidentiality, integrity and availability of data and systems. 
The consequences could be legal and regulatory fines and / or enforcement, loss of data, loss of revenue, loss of clients and customers, negative PR.

How often is the Continual Improvement Policy reviewed?

The Continual Improvement Policy is reviewed after any significant change that affects the organisation and at least annually.

Further Reading

The following are ISO 27001 controls relevant to continual improvement to consider for further reading:

ISO 27001 Clause 10.1 Continual Improvement

ISO 27001 Clause 10.2 Nonconformity and Corrective Action

About the author

I am Stuart Barker the ISO 27001 Ninja.

You can connect with me on Linked In, stalk me, check me out and join my network.

I am an information security practitioner of over 30 years. I hold a Software Engineering degree and started my career in software development. In 2010 I started my first cyber security consulting business that I sold in 2018. I worked for over a decade for GE, leading a data governance team across Europe and since then have gone on to deliver hundreds of client engagements and audits.

I regularly mentor and train professionals on information security and run a successful ISO 27001 YouTube channel where I show people how they can do it themselves. I am passionate that knowledge should not be hoarded and brought to market the first of its kind online ISO 27001 store for all the tools and templates people need when they want to do it themselves.

In my personal life I am active and a hobbyist kickboxer.

My specialisms are ISO 27001 and SOC 2 and my niche is start up and early stage business.

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