Implementing ISO 27001 Annex A 5.7 is the strategic process of gathering, analyzing, and distributing Threat Intelligence to inform risk-based decision-making. It requires organizations to filter global security feeds against their specific asset inventory to identify relevant vulnerabilities, document the business impact, and execute targeted remediation actions to preemptively secure critical systems against evolving attack vectors.
ISO 27001 Annex A Threat Intelligence Implementation Checklist
Use this implementation checklist to achieve compliance with ISO 27001 Annex A 5.7. Compliance with this control requires a manual, analytical process to identify, filter, and act upon security threats relevant to your specific technology stack, not just a passive subscription to a news feed.
1. Audit and Define Critical Assets
Control Requirement: The organization must determine which information relating to information security threats is relevant to its specific environment.
Required Implementation Step: Open your Asset Register (Excel or CSV). Filter for ‘Critical’ assets. List the specific hardware (e.g., Dell PowerEdge), operating systems (e.g., Ubuntu 22.04), and software stacks (e.g., Nginx, PostgreSQL) that support these assets. You cannot gather intelligence if you do not know what you are defending.
Minimum Requirement: A list of the top 5 critical technologies used by the business, saved in /compliance/threat-intel/scope.txt.
2. Configure Vendor-Specific Direct Alerts
Control Requirement: Information regarding threats must be collected from relevant sources.
Required Implementation Step: Log in to the administrative consoles of your critical vendors (e.g., AWS Health Dashboard, Microsoft 365 Admin Center, Adobe Admin Console). Configure email alerts specifically for “Security Advisories” and “Critical Vulnerabilities” to be sent to a dedicated technical distribution list (e.g., sec-ops@company.com), not a generic “info@” address.
Minimum Requirement: Screenshot evidence of notification settings enabled for your primary Cloud Service Provider (CSP).
3. Subscribe to National CERT/CSIRT Feeds
Control Requirement: The organization must monitor specialized interest groups and government advisories.
Required Implementation Step: Manually subscribe to the mailing list of your national Computer Emergency Response Team (e.g., NCSC in the UK, CISA in the US). Select options for “Weekly Threat Reports” and “Critical Alerts” only to avoid alert fatigue. Do not rely on Twitter or RSS feeds that cannot be audited easily.
Minimum Requirement: A confirmation email from the national CERT stored in your evidence folder.
4. Appoint a Threat Intelligence Analyst
Control Requirement: Threat intelligence must be analyzed to be effective.
Required Implementation Step: Update a specific Job Description or define a role in your ISMS Roles & Responsibilities document. Assign a named individual (e.g., the Lead System Administrator) responsibility for reviewing the sec-ops inbox. This role requires technical knowledge, not just compliance oversight.
Minimum Requirement: A signed Roles & Responsibilities document assigning “Threat Intelligence Analysis” to a specific person.
5. Initialize the Threat Intelligence Register
Control Requirement: Evidence of analysis and decision-making must be retained.
Required Implementation Step: Create a simple spreadsheet named threat-intelligence-log.xlsx. Create columns for: Date, Source (e.g., NCSC), Threat Description, Applicability (Yes/No), Impact Analysis, Action Taken, and Owner. Do not use a GRC tool’s complex module; a spreadsheet is faster and easier to audit.
Minimum Requirement: A blank register with the correct headers saved in your ISMS directory.
6. Execute Weekly Triage Process
Control Requirement: Information must be analyzed to produce threat intelligence.
Required Implementation Step: The assigned Analyst must block out 30 minutes every Friday to review the sec-ops inbox. For every alert, ask: “Do we use this software/hardware?” If No, delete. If Yes, log it in the register.
Minimum Requirement: Calendar invite evidence for “Weekly Threat Intel Review”.
7. Perform Applicability & Impact Analysis
Control Requirement: The organization must understand the relevance of the threat.
Required Implementation Step: For relevant threats, document the specific impact in the register. Example: “Log4j vulnerability identified. We run Log4j v2.14 on the payments server. Impact: Critical/RCE.” This converts raw data into *intelligence*.
Minimum Requirement: One completed row in the register showing a “Positive” match and its potential impact.
8. Disseminate Intelligence to Action Owners
Control Requirement: Threat intelligence must be communicated to relevant personnel.
Required Implementation Step: Forward the specific analysis to the person capable of fixing it (e.g., the DevOps Lead or HR Director for phishing campaigns). Use the subject line: ACTION REQUIRED: Threat Intel - [Threat Name]. Do not just forward the original vendor email without context.
Minimum Requirement: An email in the “Sent” folder providing specific instructions based on an alert.
9. Execute Remediation & Close Loop
Control Requirement: Information must be used to mitigate risks.
Required Implementation Step: The action owner must apply the fix (e.g., patch the server, update the firewall rule). Once complete, they must reply to the Analyst. The Analyst then updates the Threat Intelligence Register column “Action Taken” to “Closed/Patched”.
Minimum Requirement: A closed ticket number or git commit hash referenced in the Intelligence Register.
10. Quarterly Review of Intelligence Sources
Control Requirement: The process must be continually improved.
Required Implementation Step: Every quarter, review the threat-intelligence-log.xlsx. Identify if any sources are providing 100% noise (irrelevant data) and unsubscribe. Identify if you missed a threat that hit the news, and find a new source to plug that gap.
Minimum Requirement: Meeting minutes from the Quarterly ISMS Review noting changes to intelligence feeds.
ISO 27001 Annex A 5.7 SaaS / GRC Platform Implementation Failure Checklist
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Relevance of Threats | GRC tools provide a generic “Threat Feed” widget on the dashboard populated with global news. | Failure: The dashboard shows threats for Windows when you run Linux. Auditors fail this because there is no analysis of your specific environment. |
| Collection of Data | The platform integrates an RSS feed from a generic security website. | Failure: Real alerts come from your specific vendor portals (e.g., AWS Health), which GRC tools rarely integrate with deeply enough to be useful. |
| Analysis of Data | The tool offers a “Mark as Read” button next to news items. | Failure: Clicking “Read” is not analysis. You must document why a threat matters (or doesn’t) to your specific assets to satisfy the standard. |
| Dissemination | The tool sends an automated digest email to the admin. | Failure: Automated digests are ignored. Intelligence must be manually triaged and sent to the specific engineer who owns the affected system. |
| Actioning Intelligence | You can link a threat to a generic “Risk”. | Failure: Operational threats require operational tickets (Jira/ServiceNow), not high-level risk register entries. GRC tools disconnect the intel from the fix. |
| Evidence Retention | The tool deletes old feed items after 30 days to save space. | Failure: ISO 27001 requires an audit trail. You need a permanent log (Excel/CSV) proving you reviewed threats over the entire audit period. |
| Cost/Benefit | Paying $10k/year for a tool with a “Threat Module”. | Failure: Free alerts from CISA and your vendors are superior. You are paying for a fancy RSS reader that discourages actual work. |
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