Table of contents
ISO 27001 Monitoring, Measurement, Analysis, Evaluation
The ISO 27001 standard for ISO 27001 certification wants you to ensure the effective operation of the management system and to implement appropriate analysis and evaluation of the measures and monitors.
What Is ISO 27001 Monitoring, Measurement, Analysis, Evaluation?
ISO 27001 Clause 9.1 Monitoring, Measurement, Analysis, Evaluation requires an organisation to implement measures and monitors to evaluate the effectiveness of the information security management system. It is a requirement to maintain evidence of the results of measures and monitors.
ISO 27001 Monitoring, Measurement, Analysis, Evaluation Definition
The ISO 27001 standard defines ISO 27001 Monitoring, Measurement, Analysis, Evaluation as:
The organisation shall determine:
ISO27001:2022 Clause 9.1 Monitoring, Measurement, analysis, evaluation
a) what needs to be monitored and measured, including information security processes and controls;
b) the methods for monitoring, measurement, analysis and evaluation, as applicable, to ensure valid results. The methods selected should produce comparable and reproducible results to be considered valid.
c) when the monitoring and measuring shall be performed;
d) who shall monitor and measure;
e) when the results from monitoring and measurement shall be analysed and evaluated;
f) who shall analyse and evaluate these results.
Documented information shall be available as evidence of the results.
The organisation shall evaluate the information security performance and effectiveness of the information security management system.
What are the ISO 27001:2022 Changes to Monitoring, Measurement, Analysis, Evaluation?
There are clarification changes to the ISO 27001 Clause 9.1 Monitoring, Measurement, Analysis, Evaluation in the 2022 update.
- The words about the organisation evaluations the information security performance and the effectiveness of the management system have been removed. They are covered to a greater or lesser degree elsewhere in the clause.
- 9.1 b has been updated to give guidance on the methods of monitoring, measurement, analysis and evaluation and provides that they should produce comparable results and reproducible results to be considered valid. This was previously a footnote so no material change.
- 9.1 e has had the word ‘and’ removed with little to no consequence.
- A requirement for documented information to be available to evidence results has been included making it an explicit rather than implied requirement.
- Rather than retain appropriate documentation as evidence the line has been replaced with the requirement to evaluate the information security performance and effectiveness of the information security management system.
It says pretty much the same thing, with the same requirement with a change to the wording of how it says it.
Implementation Guide
You demonstrate compliance to ISO 27001 Clause 9.1 by having in place measures and monitors that you can show to an auditor and evidence of the operation of those measures and monitors with historical reports that show historic results.
Document your systems and processes
To understand what needs to be measured and monitored you must know what you have. Document your systems and processes. System architecture diagrams, network diagrams, server and virtual server layout diagrams, technology stacks, physical asset register and data asset register are examples of good, best practice documentation that will enable you to implement effective measures and monitors.
Conduct a risk assessment
Follow your risk management methodology and conduct a risk assessment on the assets that make up your products and services. This will allow you to prioritise your resources and identify they key systems that require monitoring.
Decide what to monitor
Looking at the functionality of the process and systems and using the diagrams and risk assessment decide exactly what it is that you are going to monitor. It is often not feasible to monitor everything. Make sure you are monitoring what is important and of risk.
Decide what to measure
The measures that make up the monitors should be decided. Exactly what are you going to measure, technically. This will be based on the technology that you have deployed and it’s inbuilt capabilities as well as a review of third party tools that may be required to plug any gaps.
Create a measures report
Reporting should be conducted at several levels. You will have automatic alerts on that feed into your various processes such as incident management as well as creating snap shot reports to satisfy the various needs of stakeholders in your organisation. You will maintain evidence of these reports.
Implement regular reviews
It is no point in having measures and monitors if they are not reviewed. Some tools have the capability to issue realtime alerts. It is also good practice to set aside time on a regular basis to preform manual reviews of the all of the data points that you are collecting. This includes a pass over of the automated alerts to ensure that none have been missed, they are configured correctly and being responded to correctly.
Implement exception steps
Exception steps are important as they define what happens when a measure or monitor hits a particular threshold. Implement steps that cover what happens if the measures and monitors fail, or exceed defined thresholds.
Regularly report the Management Review Team
It is a requirement to share the out put of the measure and monitors with the management review team as part of the process of continual improvement and oversight. Results should be shared and talked through as well as any required corrective actions.
Follow the continual improvement process
Measures and monitors will continually evolve so be sure to follow the continual improvement processes. Threat intelligence will lead to changes to what you monitor and how you respond.
Implementation Checklist
Monitoring, Measurement, Analysis, Evaluation ISO 27001 Clause 9.1 Implementation Checklist
Define What to Monitor
Decide what key things you need to track to know if your ISMS is working.
Challenge: Picking the right things to monitor can be hard. Too much data can be overwhelming.
Solution: Focus on what matters most to your business goals. Keep it simple and relevant. Involve different teams.
Set Clear Targets
For each thing you monitor, set a target. What level of performance do you want to achieve?
Challenge: Setting realistic targets can be tough. Targets that are too easy or too hard are not helpful.
Solution: Look at past performance. Consider industry best practices. Get input from experts.
Use the Right Tools
Choose tools that make it easy to collect and track data.
Challenge: Good tools can be expensive. It’s hard to find tools that fit all your needs.
Solution: Start with simple tools you already have. Explore free or low-cost options. Consider cloud-based solutions.
Collect Data Regularly
Gather data on a regular basis. How often depends on what you are monitoring.
Challenge: Collecting data can be time-consuming. It’s easy to fall behind.
Solution: Automate data collection where possible. Make it part of everyday routines. Use reminders and alerts.
Analyse the Data
Don’t just collect data, look at it! What does it tell you about your ISMS?
Challenge: Data analysis can be complex. It’s hard to spot trends and patterns.
Solution: Use charts and graphs to visualise data. Look for changes over time. Ask for help from data experts if needed.
Evaluate Performance
Compare your performance against your targets. Are you meeting your goals?
Challenge: It’s hard to be objective about performance. People may be defensive about bad results.
Solution: Use clear criteria for evaluation. Focus on learning and improvement. Be honest about your strengths and weaknesses.
Report Findings
Share what you learn with key people in your organisation.
Challenge: It’s hard to communicate complex data clearly. People may not be interested in the details.
Solution: Keep reports short and to the point. Use visuals to make data easier to understand. Focus on the key takeaways.
Take Action
If performance is not good enough, do something about it!
Challenge: Making changes can be difficult. People may resist new ways of working.
Solution: Prioritise actions based on their potential impact. Involve staff in making changes. Provide training and support.
Review the Process
Regularly check if your monitoring process is working well. Are you tracking the right things?
Challenge: It’s easy to get stuck in a rut. Things change, so your monitoring may need to change too.
Solution: Set a regular review schedule. Get feedback from staff. Look for ways to improve the process.
Document Everything
Keep records of your monitoring activities, analysis, and evaluations.
Challenge: Keeping records can be a burden. It’s hard to keep everything organised.
Solution: Use a central system for storing records. Make it easy for people to access the information they need. Keep records up to date.
Audit Checklist
Monitoring, Measurement, Analysis, Evaluation ISO 27001 Clause 9.1 Audit Checklist
Check Monitored Items
See what the organisation is tracking. Are they the right things for the ISMS?
Audit Technique: Review the documented list of monitored items. Check if they align with ISMS objectives and risk assessments.
Review Performance Targets
Are there clear targets for each thing being monitored? Are they realistic?
Audit Technique: Examine documented performance targets. Check if they’re measurable and achievable. Compare them to industry best practices.
Inspect Monitoring Tools
What tools are used to collect data? Are they suitable?
Audit Technique: Review the tools used for monitoring (e.g., SIEM systems, vulnerability scanners). Check if they are properly configured and maintained.
Examine Data Collection
How often is data collected? Is it regular and consistent?
Audit Technique: Review data collection schedules. Check if data is collected frequently enough to be useful. Examine data logs for completeness.
Check Data Analysis
Is the data being analysed properly? Are trends and patterns identified?
Audit Technique: Review reports and analyses of collected data. Check if they identify trends and areas for improvement.
Verify Performance Evaluation
Is performance being evaluated against the targets? How often?
Audit Technique: Review performance evaluation reports. Check if they compare actual performance against targets.
Review Reporting
Are the findings reported to the right people? Are the reports clear?
Audit Technique: Examine reports on monitoring and evaluation. Check if they are distributed to relevant stakeholders.
Check Actions Taken
When performance is below target, are actions taken? Are they effective?
Audit Technique: Review records of actions taken in response to performance issues. Check if the actions have led to improvements.
Review Monitoring Process
Is the whole monitoring process reviewed regularly? Is it still effective?
Audit Technique: Review the documented monitoring and evaluation process. Check if it is reviewed and updated periodically.
Check Record Keeping
Are records of monitoring, analysis, and evaluation kept properly?
Audit Technique: Examine records of monitoring activities, data analysis, and performance evaluations. Check if they are complete and up to date.
Further Guidance
There is further guidance provided in the ISO 27001 Annex A Controls that was revised in 2022 with changes to the ISO 27002 standard and specifically calls out required monitoring and analysis. As you would expect this a fundamental area for an information security management system and as such it touches most of the controls. Here will look at some actual specifics and take a look at what Annex A says.
There are many ways to implement measures and monitors and what is right for you will depend on your company culture and the tools available.
Consider the best methods for you that you know get results and where possible retain evidence of your measures and monitors.
Technical tools are great but also consider the manual reviews, checks and balances and consider for the manual processes how you will record them and evidence them.
Threat Intelligence
This is a new control introduced in 2022. Whilst not a direct measure and monitor it is an indirect measure and monitor that allows an organisation to gather threat intelligence to more effectively understand risk, what controls may be required and better protect itself.
Information relating to information security threats should be collected and analysed to produce threat intelligence.
ISO 27001:2022 Annex A 5.7 Threat Intelligence
Logging
Logging is one of the more straight forward measures and monitors that we can introduce and is often provided as a default capability of most applications and systems.
Logs that record activities, exceptions, faults and other relevant events should be produced, stored, protected and analysed.
ISO 27001:2022 Annex A 8.15 Logging
Monitoring, review and change management of supplier services
Supply chain security represents one of the biggest risks to any organisation as it is something that is outside your direct control. Ensuring a regular review and monitoring of their security practices and service delivery seeks to gain assurance that they are doing the right thing for information security and therefore protecting you, your customers and your clients.
The organisation should regularly monitor, review, evaluate and manage change in supplier information security practices and service delivery.
ISO 27001 Annex A 5.22 Monitoring, review and change management of supplier services
Physical security monitoring
The requirements of ISO 27002 clause 7.5 are satisfied by physical controls such as locked doors, person controlled reception areas, visitor cards, escorted visitors, potentially CCTV cameras and alarms. This is traditional security around access to physical locations.
Premises should be continuously monitored for unauthorised physical access.
ISO 27001:2022 Annex A 7.5 Physical security monitoring
Capacity Management
Monitoring, reporting, analysing and responding to capacity management is specifically aimed at the availability aspect of information security. Ensuring that information and systems are available when required and negating any unintended consequences of exceeding the capacity capabilities of those systems.
The use of resources should be monitored and adjusted in line with current and expected capacity requirements.
ISO 27001:2022 Annex A 8.6 Capacity Management
Configuration Management
Configurations, including security configurations, of hardware, software, services and networks should be established, documented, implemented, monitored and reviewed.
ISO 27001:2022 Annex A 8.9 Configuration Management
Logging
Similar to the next clause, 8.16 monitoring actives, this clause on logging is a bit of a catch all clause.
Logs that record activities, exceptions, faults and other relevant events should be produced, stored, protected and analysed.
ISO 27001:2022 Annex A 8.15 Logging
Monitoring Activities
We have seen some specific requirements on measures and monitors but now we enter what we call a ‘catch all’ clause that basically says monitor everything. There is an art and a science in actually deciding and justifying what you monitor so as not to have monitoring overload.
Networks, systems and applications should be monitored for anomalous behaviour and appropriate actions taken to evaluate potential information security incidents.
ISO 27001:2022 Annex A 8.16 Monitoring Activities
Security of Network Services
Security mechanisms, service levels and service requirements of network services should be identified, implemented and monitored.
ISO 27001:2022 Annex A 8.21 Security of Network Services
Outsourced Development
This is one of the few clauses in the statement of applicability that is often not applicable, especially if you do not outsource your software development or do software development. If you do then monitoring and review is required.
The organisation should direct, monitor and review the activities related to outsourced system development.
ISO 27001:2022 Annex A 8.30 Outsourced Development
ISO 27001 Templates
ISO 27001 templates are a great way to implement your information security management system. Whilst an ISO 27001 toolkit can save you up to 30x in consulting fees and allow you to deliver up to 10x faster these individual templates help meet the specific requirements of ISO 27001 clause 9.1
DO IT YOURSELF ISO 27001
All the templates, tools, support and knowledge you need to do it yourself.
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ISO 27001 Clause 9.1 FAQ
ISO 27001 Clause 9.1 Monitoring, Measurement, analysis, evaluation requires and organisation to implement measures and monitors to evaluate the effectiveness of the information security management system. It is a requirement to maintain evidence of the results of measures and monitors.
You demonstrate compliance to ISO 27001 Clause 9.1 by having in place measures and monitors that you can show to an auditor and evidence of the operation of those measures and monitors with historical reports that show historic results.
You can download ISO 27001 Clause 9.1 templates in the ISO 27001 Toolkit.
An example of ISO 27001 Clause 9.1 can be found in the ISO 27001 Toolkit.
A measure is something that can be observed to happen that has a quantitive value.
A monitor is the system by which the measures are collected and recorded.
Monitors are the systems by which the measures are captured. A monitor is an oversight or observation where as a measure is an actual value or metric.
You comply with ISO 27001 clause 9.1 by identifying which measures and monitors you need based on risk and business need and then implementing them. In addition you implement the processes to oversee and react to them and you implement effective reporting for governance and oversight. Finally you implement continual improvement and incident management processes to handle the out put of the processes.
An example measure for ISO 27001 clause 9.1 would be the number of machines with active anti virus, the number of machines patched, the number of people trained.
An example monitor for ISO 27001 clause 9.1 would be to have anti virus in place with auto alerts and reporting enabled, to have asset management software in place than handles patching and reports on failed patching attempts, to have a report that periodically shows the number of people that are not trained in information security.
The analysis of ISO 27001 measure and monitors is performed by the allocated system and process owner. They are best placed to understand the results and provide guidance based on those results.
As often as is necessary based on risk. It would not be unreasonable for the review to be conducted monthly.
For as long as is necessary based on business need and risk. It would not be unreasonable to keep the results for a rolling period of 18 months.
You share the results with the owner of the thing, process, system that is being measured and monitored. In addition you share it with the Management Review Team as part of the process of continual improvement for oversight and signify.
Follow your process of continual improvement and make the necessary changes to the measure and monitor.