ISO 27001 Clause 8.1 Operational Planning and Control

ISO 27001 Operational Planning and Control

The ISO 27001 standard requires an organisation to plan, implement and control the processes needed to meet the requirements of Information Security.

What is ISO 27001 Clause 8.1?

ISO 27001 Clause 8.1 is the need to plan and control the processes necessary to meet the requirements of your objectives and the management of your risks.

Documented processes is going to fall into two categories.

• documented processes for the information security management system (the isms), 
• documented processes that support the annex a controls.

By doing this you can:

• Ensure Consistency: the single biggest reason to implement operations and document everything is so that you have process maturity and are consistent in your approach.
• Evidence effective operation of information security: by implementing operations you will have evidence of the management of information security and the measures and monitors that show that it is effective.
• Reduce errors: by having operations you are able to reduce errors by being consistent and continually improve and adapt as things change.

ISO 27001 Operational Planning and Control includes change management and outsourced process management.

ISO 27001 Clause 8.1 Definition

ISO 27001 defines ISO 27001 clause 8.1 as:

The organisation shall plan, implement and control the processes needed to meet information security requirements, and to implement the actions determined in clause 6 by
– establishing criteria for processes
– implementing control of the processes in accordance with the criteria
Documented information shall be available to the extent necessary to have confidence that the processes have been carried out as planned.
The organisation shall control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects, as necessary.
The organisation shall ensure that externally provided processes, products or services that are relevant to the information security management system are controlled

ISO 27001:2022 Clause 8.1 Operational Planning and Control

How to implement ISO 27001 Clause 8.1

Key Principles

• Processes are documented: the information security management system (ISMS) and business operations are documented. This is about having business process maturity which means having documented processes and a standardised way of operating that is performed in the same way irrespective of who operates the process. The output of the process is also the same irrespective of who operates it.
• Documentation is available: documentation is available to those that needed it when they need it including the inputs and outputs such as management reports.

General Guidance

There are many ways to document and evidence operational control. Consider the best methods for you.

When documenting operational processes you can have all your operational processes documented in one document called the Operations Manual (Ops Manual). This approach is great for smaller businesses.

Alternatively you can have many documents spread out in, and embedded in, the business and the operational areas where the processes are executed. This is more suited to a large organisation with teams and more people.

Consider it as a centralised or decentralised approach with the associated pros and cons of those kinds of implementation.

Finally there is always a hybrid approach where some processes are in the business but the ops manual remains the ‘shop window’ or the main reference point for those processes for management and control.

ISO 27001 Clause 8.1 Implementation Checklist

Operational Planning and Control ISO 27001 Clause 8.1 Implementation Checklist

1. Define Operational Processes

Clearly define and document all operational processes related to information security. This includes processes for incident management, change management, vulnerability management, access control, etc.

Challenge

Difficulty in documenting complex processes in a clear and concise manner.

Solution

Use flowcharts, diagrams, and plain language to document processes. Involve process owners and subject matter experts in the documentation process.

2. Establish Acceptance Criteria

Define clear acceptance criteria for all operational activities. This ensures that activities are performed to a consistent standard and meet the organisation’s security requirements.

Challenge

Setting realistic and measurable acceptance criteria.

Solution

Base acceptance criteria on industry best practices, regulatory requirements, and the organisation’s risk assessment. Pilot test new criteria where possible.

3. Allocate Resources

Identify and allocate the necessary resources (personnel, equipment, software, budget) to support operational processes.

Challenge

Resource constraints and competing priorities.

Solution

Prioritise resource allocation based on risk assessment and business impact. Justify resource requests with clear business cases.

4. Implement Controls

Implement the information security controls identified in the risk assessment and ISO 27001 Statement of Applicability (SoA). This includes technical controls (e.g., firewalls, intrusion detection systems) and organisational controls (e.g., policies, procedures, training).

Challenge

Complexity of implementing and managing multiple controls.

Solution

Prioritise control implementation based on risk and feasibility. Use a phased approach and leverage automation where possible.

5. Establish Operating Procedures

Develop detailed operating procedures for performing security-related tasks. These procedures should be clear, concise, and easy to follow.

Challenge

Keeping procedures up-to-date and relevant.

Solution

Implement a version control system for procedures and establish a regular review cycle. Solicit feedback from staff who use the procedures.

6. Manage Changes

Implement a formal change management process to ensure that changes to systems, applications, and processes do not introduce new security risks.

Challenge

Balancing the need for change with the need to maintain security.

Solution

Establish a change approval process that includes security review. Conduct thorough testing before implementing changes.

7. Monitor Performance

Regularly monitor the performance of operational processes and controls. This helps to identify potential issues and ensure that controls are operating effectively.

Challenge

Defining meaningful metrics and collecting data effectively.

Solution

Establish key performance indicators (KPIs) for operational processes and use automated tools where possible to collect and analyse data.

8. Manage Incidents

Implement an incident management process to handle security incidents effectively. This includes procedures for reporting, analysing, and responding to incidents.

Challenge

Responding to incidents quickly and effectively while minimising disruption.

Solution

Develop incident response plans and conduct regular incident response exercises. Establish clear communication channels for reporting incidents.

9. Maintain Documentation

Maintain accurate and up-to-date documentation for all operational processes, controls, and procedures.

Challenge

Keeping documentation current and accessible.

Solution

Use a centralised document management system and establish a process for updating documentation regularly.

10. Continuously Improve

Regularly review and improve operational processes based on monitoring data, incident reports, and feedback from stakeholders.

Challenge

Identifying areas for improvement and implementing changes effectively.

Solution

Conduct regular management reviews of operational performance. Encourage feedback from staff and implement a process for continual improvement.

ISO 27001 Clause 8.1 Audit Checklist

How to audit ISO 27001 Clause 8.1 Operational Planning and Control

1. Verify the Existence of Documented Processes

Verify that documented information security processes exist for all planned and controlled operations related to the ISMS. This includes processes for incident management, change management, access control, and vulnerability management.

• Examine process documentation (flowcharts, procedures) for completeness, clarity, and alignment with the ISMS.
• Interview process owners to understand how processes are implemented in practice.

2. Check Acceptance Criteria

Confirm that clear acceptance criteria have been defined for operational activities and that these criteria are being used to evaluate performance.

• Review documented acceptance criteria and interview staff responsible for performing and reviewing operational tasks.
• Observe operational activities (where possible) to verify that acceptance criteria are applied.

3. Ensure There is Adequate Resource Allocation

Ensure that adequate resources (people, budget, technology) are allocated to support the operation and control of the ISMS.

• Review resource allocation plans, budget documents, and staffing schedules.
• Interview managers and staff to assess the adequacy of resources.

4. Inspect Control Implementation

Verify that the information security controls identified in the risk assessment and ISO 27001 Statement of Applicability (SoA) have been implemented effectively.

• Perform control testing (e.g., technical testing of firewalls, review of access control lists).
• Examine configuration settings, logs, and other evidence of control implementation.

5. Ensure There is Monitoring and Review of Controls

Ensure that the effectiveness of operational controls is regularly monitored and reviewed.

• Review monitoring logs, performance reports, and management review minutes.
• Interview management and operational staff regarding monitoring and review activities.

6. Evaluate Operating Procedures

Assess the clarity, completeness, and currency of operating procedures for security-related tasks.

• Review operating procedures for accuracy, completeness, and ease of understanding.
• Interview staff to confirm their familiarity with and adherence to procedures.

7. Confirm There is Change Management

Confirm that a formal change management process is in place to control changes to the ISMS, including infrastructure, software, and processes.

• Examine change requests, approvals, and implementation records.
• Interview IT staff and users about the change management process.
• Review emergency change procedures.

8. Check Performance Monitoring

Confirm that the performance of operational processes and controls is being monitored regularly.

• Review performance monitoring reports, key performance indicators (KPIs), and dashboards.
• Interview staff responsible for monitoring performance and how the data is used.

9. Confirm There is Incident Management

Verify the existence and effectiveness of an incident management process to detect, respond to, and recover from security incidents.

• Review incident logs, incident reports, and post-incident reviews.
• Interview incident response team members.
• Conduct simulated incident scenarios.
• Verify that documents are readily accessible to relevant personnel.

10. Assess Continuous Improvement

Verify that operational processes are being regularly reviewed and improved based on monitoring data, incident reports, and feedback from stakeholders.

• Review management review minutes, improvement plans, and records of corrective actions.
• Interview management and staff to assess the organisation’s commitment to continual improvement.

11. Check Outsourcing Controls

Where processes are outsourced, confirm that appropriate controls are in place to manage the security risks associated with third-party involvement. This includes contractual agreements and ongoing monitoring.

• Review contracts with third-party providers, examine service level agreements (SLAs), and conduct interviews with both internal and external personnel.
• Review audit reports of outsourced providers where available.

12. Review Capacity Management

Verify that capacity planning is performed to ensure that sufficient resources are available to meet current and future business needs without compromising security.

• Review capacity plans, trend analysis data, and performance monitoring reports.
• Interview IT staff regarding capacity management processes.

13. Confirm There is Vulnerability Management

Ensure that a vulnerability management process is in place to identify, assess, and remediate security vulnerabilities.

• Review vulnerability scan reports, penetration testing results, and remediation plans.
• Interview IT security staff. Observe vulnerability scanning activities.

14. Gain Evidence of Backup and Restoration

Confirm that appropriate backup and restoration procedures are in place to protect critical data and systems.

• Review backup and restoration procedures, backup logs, and restoration test results.
• Conduct spot checks of backup media.

Example Records of Evidence

Examples of records that processes can generate include

• internal audit reports
• external audit reports
• IT management reports
• antivirus status reports
• patching status reports
• asset inventory
• the number of new users
• help desk statistic reports

Further Guidance on Operational Planning and Control

ISO 27001 provides further guidance in its Annex A controls, which were revised in 2022 in conjunction with changes to the ISO 27002 standard. Annex A specifically identifies required operational processes. Adhering to the principle that “if it isn’t documented, it doesn’t exist,” every control in Annex A necessitates a corresponding documented process. While we won’t cover every control, the following examples illustrate the type of processes required.

ISO 27001 Annex A 5.24 Response to information security incidents

The organisation should plan and prepare for managing information security incidents by defining, establishing and communicating information security incident management processes, roles and responsibilities

ISO 27001 Annex A 5.24 Information security incident management planning and preparation

ISO 27001 Annex A 5.26 Response to information security incidents

Information security incidents should be responded to in accordance with the documented procedures.

ISO 27001 Annex A 5.26 Response to information security incidents

ISO 27001 Annex A 5.37 Documented operating procedures

Operating procedures for information processing facilities should be documented and made available to personnel who need them.

ISO 27001 Annex A 5.37 Documented operating procedures

ISO 27001 Annex A 5.32 Intellectual property rights

The organisation should implement appropriate procedures to protect intellectual property rights.

ISO 27001 Annex A 5.32 Intellectual property rights

This is usually the function of the legal department and part of good legal practice. Legal will have many requirements of their own but we are interested for ISO 27001 certification in ensuring that they have handled intellectual property rights as well as the legal register.

ISO 27001 Annex A 8.32 Change Management

Changes to information processing facilities and information systems should be subject to change management procedures.

ISO 27001 Annex A 8.32 Change Management

How do you demonstrate compliance to ISO 27001 clause 8.1?

It is very simple and straightforward to demonstrate compliance with ISO 27001 clause 8.1 operational planning and control.

Document all of your processes, have plans in place that you can evidence and have evidence of the processes operating as you have documented that they should.

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