ISO 27001 Clause 4.1 Understanding The Organisation And Its Context

What is ISO 27001 Clause 4.1?

ISO 27001 Clause 4.1 Understanding The Organisation And Its Context is an ISO 27001 clause that requires us to understand the internal and external issues that could impact your information security management system (ISMS).

What are internal and external issues?

Internal issues and external issues are just another way of saying risks.

So the clause is asking you to consider and record what internal and external risks there are to your information security management system (ISMS). What could stop your information security management system from being able to achieve its outcomes.

Purpose

ISO 27001 Clause 4.1 is an Information Security Management System (ISMS) control to ensure you identify, manage and mitigate risks to the management system achieving its intended outcomes.

Definition

The ISO 27001 standard defines ISO 27001 Clause 4.1 Understanding The Organisation And Its Context as:

The organisation shall determine external issues and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its information security management system.
The organisation shall determine whether climate change is a relevant issue.

ISO27001:2022 Clause 4.1 Understanding The Organisation And Its Context

The standard amended the definition in February 2024. This amendment, referred to as Amendment 1: Climate action changes added climate change to ISO 27001 Clause 4.1. The standard also added the following sentence:

‘ The organisation shall determine whether climate change is a relevant issue.’

ISO 27001 Amendment 1: Climate action changes 

In February 2024 the standard was amended to include climate change. The following sentence was added to the clause

The organisation shall determine whether climate change is a relevant issue.

ISO 27001:2022 Amendment 1: Climate action changes 

For more information on the changes in ISO 27001:2022 Amendment 1, I recommend reading the article ISO27001:2022 Amendment 1: – Absolutely Everything You Need to Know.

Ownership

The Information Security Officer is responsible for collaborating closely with the domain experts to identify and manage internal issues and external issues.

Implementation Guide

When implementing ISO 27001, to comply with ISO 27001 Clause 4.1 Understanding The Organisation And Its Context, you will need to identify and document your internal issues and external issues that could potentially affect your information security management system and document them in a Context of Organisation document.

Implementation Checklist

ISO 27001 Clause 4.1 Understanding The Organisation And Its Context Implementation Checklist

Conduct a Brainstorm Session

Challenge:

Identifying internal issues and external issues can be challenging.

Solution

• Create cross-functional teams: Create teams with members from different departments to encourage knowledge sharing and collaboration.
• Manage stakeholders: With key stakeholders from across the business and organisational units perform a brainstorming session to record the potential issues that you may face.
• Leverage Best Practice: Consider using the example internal issues and external issues later in this article as your starting point.

Compliance and Security Requirements

Challenge:

Maintaining compliance while adapting to constantly evolving regulations presents a significant challenge.

Solution:

• Utilise compliance management tools: Employ specialised tools to track and monitor regulatory changes and ensure compliance adherence.
• Integrate compliance into the ISMS: Incorporate compliance requirements directly into the Information Security Management System (ISMS) framework.
• Provide continuous training: Regularly train security teams on the latest regulatory requirements and best practices for maintaining compliance in test environments.
• Create a legal register: Use an ISO 27001 legal register template to record all relevant laws.

Align with the Organisation

Challenge:

Internal issues and external issues to the management system do not exist in isolation of the organisation and it can be challenging to align with organisation goals.

Solution:

• Understand the organisation: Read and understand the organisation mission and goals and ensure these are referenced when identifying issues.
• Integrate business goals into the ISMS: Incorporate the business goals into the information security management system and align them with the goals of the ISMS.
• Document the organisation: Create a documented overview of the organisation utilising the ISO 27001 Organisation Overview Template.

Assess the organisation’s infrastructure

Challenge:

Having a comprehensive understanding and record of the organisations technical infrastructure and human resources presents a significant challenge.

Solution:

• Create organisation charts: Work with HR to create organisation charts. Using the roles and responsibilities aligned with ISO 27001:2022 Clause 5.3 (Organisational Roles, Responsibilities and Authorities) identify gaps and internal resource issues.
• Map roles and responsibilities: Understand the roles that are required for the information security management system as referenced in ISO 27001:2022 Clause 5.3 (Organisational Roles, Responsibilities and Authorities) and document them in the ISO 27001 Information Security Roles and Responsibilities Template identify gaps and internal resource issues.
• Create technical documentation: Working with the technical teams and domain experts create accurate technical documentation including server and network diagrams and identify and internal technological issues.

Risk Management

Challenge:

Identifying and mitigating all potential risks, especially within complex IT environments, presents a significant challenge.

Solution:

• Comprehensive Risk Assessments: Conduct thorough risk assessments tailored to identifying internal issues and external issues to the ISMS. This process should adhere to ISO 27001:2022 Clause 6.1 (Planning), focusing on identifying and addressing potential vulnerabilities and threats.
• Conduct a Risk Assessment: Determine whether the identified issues and risks require risk management by utlising the ISO 27001 risk register template and ISO 27001 risk management process template.

Document Internal and External Issues

Challenge:

Maintaining a record of internal issues and external issues can be confusing and present a challenge.

Solution:

• Create and ISO 27001 Context of Organisation document: Record the internal issues and external issues using the ISO 27001 Context of Organisation template.

Audit Checklist

ISO 27001 Clause 4.1 Understanding The Organisation And Its Context Audit Checklist

Document Internal and External Issues

• Review the ISO 27001 Context of Organisation documentation.
• Confirm that internal issues are recorded.
• Ensure that external issues are recorded.
• Check that there is a link between issues and the ISMS that shows how the ISMS addresses the issues.

Brainstorm Session

• Check if a brainstorming session was conducted.
• If a brainstorming sessions was conducted check meeting minutes for evidence and attendees.
• Ensure that brainstorming sessions covered full organisation representation.

Compliance and Security Requirements

• Review compliance management tools and how they track and monitor regulatory changes and ensure compliance adherence.
• Ensure that compliance is integrated into the ISMS
• Asses continuous training and that regular training is in place for security teams on the latest regulatory requirements and best practices for maintaining compliance.

Alignment with the Organisation

• Review the organisation mission and goals and ensure these are referenced.
• Check that business goals are referenced into the information security management system and aligned with the goals of the ISMS.
• Assess the documented overview of the organisation and the completion of the ISO 27001 Organisation Overview Template.

Assessment of the organisation’s infrastructure

• Review organisation charts and assess that roles and responsibilities are aligned with ISO 27001:2022 Clause 5.3 (Organisational Roles, Responsibilities and Authorities).
• Check roles and responsibilities required for the information security management system as referenced in ISO 27001:2022 Clause 5.3 (Organisational Roles, Responsibilities and Authorities) are documented and check the ISO 27001 Information Security Roles and Responsibilities Template.
• Walkthrough technical documentation working with the technical teams and domain experts to assess accurate technical documentation including server and network diagrams are in place.

Risk Management

• Check if a thorough risk assessments tailored to internal issues and external issues has been performed and if it considered identifying and addressing potential vulnerabilities and threats.

Documentation and Audit

• Ensure that reviews and internal audits are in place and evidenced
• Assess the documentation framework, inputs and outputs.

Watch the Tutorial

For a visual guide on how to implement ISO 27001 Clause 4.1, I suggest watching the YouTube tutorial titled ‘How to implement ISO 27001 Clause 4.1 Understanding The Organisation And Its Context‘

ISO 27001 Templates

The ISO 27001 Context Of Organisation template fully meets the requirements of ISO 27001 Clause 4.1 and includes pre-written examples of common internal issues and external issues. The template can be purchase as an individual download or as part of the internationally acclaimed and award-winning ISO 27001 Toolkit.

What are ISO 27001 Internal Issues?

Internal issues, relevant to ISO 27001, are threats that could hinder the effective functioning of your information security management system (ISMS). In other words, consider them as risks that could prevent the ISMS from achieving its desired outcomes. Furthermore, these issues originate within your organisation and, to a large extent, are within your control.

When considering internal issues and what could impact information security, the following can be a great guide:

• The organisation’s culture.
• Organisational governance.
• Organisational structure.
• People’s roles and accountabilities.
• Policies.
• Company objectives and the strategies that are in place to achieve them.
• Organisational capabilities in terms of resources and knowledge.
• The relationships, perceptions and values of internal stakeholders.
• Information systems.
• Information flows and decision-making processes.
• Standards, guidelines and models adopted by the organisation.
• Contractual relationships.

Example Internal Issues

ISO 27001 Clause 4.1 internal issues examples include

Time

What could be the issues with time? Time could be that you haven’t got enough time to dedicate to the management system. You know the organisation is working too much on Commercial products. Positive and negative. You do have time you don’t have time. Operation and organisational structures could be an issue for you. It could be that you’re part of a group structure, it could be you are part of an international structure, or it could be more micro than that, but those organisational structures could present you with some challenges around meeting your objectives. Again if they don’t then you should put the positive down and show that you have considered it and it is not an issue for you.

Technologies

Technologies that you use may potentially prevent or introduce a risk, an issue, for you if you’re using bleeding edge technologies or the way that you’re using it.

What are ISO 27001 External Issues?

External issues, relevant to ISO 27001, are threats that could hinder the effective functioning of your information security management system (ISMS). In other words, these issues originate outside your organisation and, generally, are beyond your direct control.

When considering external issues and what could impact information security, the following can be a great guide:

• The social and cultural, political, legal, regulatory, financial, technological, economic, natural and competitive environment, whether international, national, regional or local.
• Key drivers and trends having impact on the objectives of the organisation; and
• Relationships with perceptions and values of external stakeholders.

Example External Issues

ISO 27001 Clause 4.1 external issues examples include

Economic Climate

The economic climate, for example during the pandemic, took a turn that meant the availability of resources and finances was impeded. That could impact you and therefore you would want a risk register and a risk item and to manage that through risk management. Another example could be that the economic climate is actually positive and is affecting you in a positive way to deliver your management system and therefore it doesn’t need a risk but you are just going to record it.

Technology Advances

Technological advances and relying on technologies that are going to be superseded, out of date or out of support. If your entire infrastructure is built around it then you’ve got a problem and you need to manage it even if you accept it.

How to write ISO 27001 Internal and External Issues

When recording the ISO 27001 Internal and External Issues, the standard does not stipulate that you should only record the negative. In other words, do not go out of your way to find and report the negative.

It’s possible that you have considered internal issues or external issues and, in fact, it is not an issue for you.

By writing down the issues and then providing an explanation, either positive or negative, you are demonstrating that you considered it. If the explanation is positive, it shows that you considered it, and a clever auditor won’t raise it as a problem thinking they’ve got one over on you.

You can confidently say, “Yes, we considered it, we documented it, and for us, it is not an issue.”

If the explanation is negative, indicating that you do have an issue, then describe the issue and indicate whether or not you have raised a risk in the risk register to address it.

It is expected and considered good practice for each issue that is an issue to be included in the risk register and managed via risk management.

What the auditor will check

The auditor is going to check a number of areas for compliance with Clause 4.1.

1. That you have documented your internal and external issues

The simplest way to do this is with the fully populated ISO 27001 Context of Organisation Template.

2. That you are risk managing internal and external issues

If you identify internal issues or external issues that can impact the information security management system and you are not addressing them directly then you need to manage it via risk management.

This means as a minimum putting it on the risk register and following your risk management process.

Be sure to link the issue to the risk by cross referencing.

3. That you have approved the included common issues

Auditors often raise common internal issues and external issues that they have seen elsewhere. Therefore, it is good practice to list out all potential internal issues and external issues that could impact your information security management system, regardless of whether they apply to you or not.

If they do not apply to you, record them and explain why. By doing this, you can demonstrate that you have conducted a thorough review and avoid awkward questions or the auditor raising points that you have considered but placed out of scope.

Since you have recorded these issues and determined that they do not apply, you can provide evidence to support your conclusion.

How to pass the audit

To successfully pass an audit of ISO 27001 Clause 4.1, a crucial step in achieving ISO 27001 Certification, you must ensure you have implemented the mandatory ISO 27001 documents and ISO 27001 polices. You are going to need to put in place ISO 27001 controls to:

• Identify Internal Issues
• Identify External Issues
• Document internal and external issues in a Context of Organisation Document

Top 3 Mistakes People Make

The top 3 mistakes people make for ISO 27001 clause 4.1 are

1. You have no evidence that anything actually happened

You need to keep records and minutes and documented evidence.

As a result, recording internal issues and external issues that apply and those that do not shows a thorough understand of the requirement and will avoid awkward questions.

2. You did not link to risk management

Where internal issues or external issues are identified but you cannot satisfy it you should have this on the risk register and managed via risk management.

This is a point often overlooked.

It must be remember that if you identify an issue and do nothing about, or cannot evidence that you have done something about it, it will be raised as a non conformity.

3. Your document and version control is wrong

Best practice for documentation includes:

• Keeping your document version control up to date
• Making sure that version numbers match where used
• Having a review evidenced in the last 12 months
• Having documents that have no comments

ISO 27001 Clause 4.1 FAQ