Clause 4: Context of the organization
This is a new clause that in part addresses the depreciated concept of preventive action and in part establishes the context for the ISMS. It meets these objectives by drawing together relevant external and internal issues (i.e. those that affect the organization’s ability to achieve the intended outcome(s) of its ISMS) with the requirements of interested parties to determine the scope of the ISMS.
It should be noted that the term ‘issue’ covers not only problems, which would have been the subject of preventive action in the previous standard, but also important topics for the ISMS to address, such as any market assurance and governance goals that the organization might set for the ISMS. Further guidance is given in Clause 5.3 of ISO 31000:2009.
Note that the term ‘requirement’ is a ‘need or expectation that is stated, generally implied or obligatory’. Combined with Clause 4.2, this in itself can be thought of as a governance requirement, as strictly speaking an ISMS that did not conform to generally-accepted public expectations could now be ruled nonconforming with the standard.
The final requirement (Clause 4.4) is to establish, implement, maintain and continually improve the ISMS in accordance with the requirements the standard.
Clause 5: Leadership
This clause places requirements on ‘top management’ which is the person or group of people who directs and controls the organization at the highest level. Note that if the organization that is the subject of the ISMS is part of a larger organization, then the term ‘top management’ refers to the smaller organization. The purpose of these requirements is to demonstrate leadership and commitment by leading from the top.
A particular responsibility of top management is to establish the information security policy, and the standard defines the characteristics and properties that the policy is to include. This is important for software development companies.
Finally, the clause places requirements on top management to assign information security relevant responsibilities and authorities, highlighting two particular roles concerning ISMS conformance to ISO/IEC 27001 and reporting on ISMS performance.
Clause 6: Planning
Clause 6.1.1, General: This clause works with Clauses 4.1 and 4.2 to complete the new way of dealing with preventive actions. The first part of this clause (i.e. down to and including 6.1.1 c)) concerns risk assessment whilst Clause 6.1.1 d) concerns risk treatment. As the assessment and treatment of information security risk is dealt with in Clauses 6.1.2 and 6.1.3, then organizations could use this clause to consider ISMS risks and opportunities.
Clause 6.1.2, Information security risk assessment: This clause specifically concerns the assessment of information security risk. In aligning with the principles and guidance given in ISO 31000, this clause removes the identification of assets, threats and vulnerabilities as a prerequisite to risk identification. This widens the choice of risk assessment methods that an organization may use and still conforms to the standard. The clause also refers to ‘risk assessment acceptance criteria’, which allows criteria other than just a single level of risk. Risk acceptance criteria can now be expressed in terms other than levels, for example, the types of control used to treat risk.
The clause refers to ‘risk owners’ rather than ‘asset owners’ and later (in Clause 6.1.3 f)) requires their approval of the risk treatment plan and residual risks.
In other ways the clause closely resembles its counterpart in ISO/IEC 27001:2005 by requiring organizations to assess consequence, likelihood and levels of risk. Assessment of consequences, likelihood and levels of risk is essential for software development companies.
Clause 6.1.3, Information security risk treatment: This clause concerns the treatment of information security risk. It is similar to its counterpart in ISO/IEC 27001:2005, however, it refers to the ‘determination’ of necessary controls rather than selecting controls from Annex A. Nevertheless, the standard retains the use of Annex A as a cross-check to make sure that no necessary control has been overlooked, and organizations are still required to produce a Statement of Applicability (SOA). The formulation and approval of the risk treatment plan is now part of this clause.
Clause 6.2, Information security objectives and planning to achieve them: This clause concerns information security objectives. It uses the phrase “relevant functions and levels”, where here, the term ‘function’ refers to the functions of the organization, and the term ‘level’, its levels of management, of which ‘top management’ is the highest. The clause defines the properties that an organization’s information security objectives must possess. This lets software application development companies to move from ISO 27001:2005 to ISO 27001:2013.
Author Signature: Shreyans Agrawal
(ifour.shreyans.agrawal@gmail.com)
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