ISO 27001 AND ISO 27002 CHANGES FOR 2022

(ISO/IEC 27001:2022 and ISO/IEC 27002:2022)

Recently a publication notice was released regarding the ISO 27001 and ISO 27002 changes in 2022, which states that, “all organizations having an ISO 27001:2013 (ISMS) will be required to map and update their controls in place in accordance with the new recommendations in the revised ISO/IEC 27002:2002, considering their organizational needs and context.”

Highlight of ISO 27001 Updates

CHANGES TO ISO 27001 and ISO 27002 for 2022

ISO/IEC 27001:2022:

All organizations having an ISO 27001:2013 (ISMS) will be required to map and update their controls in place in accordance with the new recommendations in the revised ISO/IEC 27002:2002, considering their organizational needs and context.

ISO/IEC 27002:2022:

The current version of ISO 27002 that contains 114 controls divided over fourteen chapters, and  the version of ISO 27002:2022 that will contain 93 controls will all be divided over four categories/themes:

  • Chapter 5 Organizational (37 controls)
  • Chapter 6 People (8 controls)
  • Chapter 7 Physical (14 controls)
  • Chapter 8 Technological (34 controls)

THE NEW CONTROLS

The guidance section for each control have been examined and updated to reflect current advancements and practices (as necessary). Additionally, each control now has a ‘Purpose’ statement and a set of ‘Attributes’ to be used in conjunction with cybersecurity principles and other industry standards. An update to the standard also needs to factor in today’s threat landscape and security threats. The new controls are:

  1. Threat intelligence
  2. Information deletion
  3. Information security for the use of cloud services
  4. ICT readiness for business continuity
  5. Physical security monitoring
  6. Configuration management
  7. Data masking
  8. Secure coding
  9. Data leakage prevention
  10. Monitoring activities
  11. Web filtering

CONTROL ATTRIBUTES

These controls have five types of ‘attributes’ to make them easier to categorize:

  1. Control type (preventive, detective, corrective)
  2. Information security properties (confidentiality, integrity, availability)
  3. Cybersecurity concepts (identify, protect, detect, respond, recover)
  4. Operational capabilities (governance, asset management, etc.)
  5. Security domains (governance and ecosystem, protection, defense, resilience)

Timing & Enforcement:

A two-year transition period will be granted (unlike three years in several previous transitions).

FAQs ON ISO 27001 and ISO 27002

1. Will Accorian help us transition to the new revision of ISO 27001:2022?

We will assist in preparing material for the adjustments, and the organization will be able to upgrade until the 2022 revision is published, which is likely to occur soon, unless their existing ISO 27001 certificate expires after 2024, in which case, the certification bodies will conduct regular surveillance visits to ensure compliance with the new revision.  If the organization’s existing ISO 27001 certificate expires before 2024, then they will need to upgrade through subsequent re-certification.

2. We have chosen to begin implementing ISO 27001 now; which controls should we apply considering future changes?

Organizations should begin applying the clauses mentioned in the ISO 27001:2013 standard until this new standard is available. This will ensure the upcoming modifications and the work required to implement the new standard will be minimal.

2.1 How to plan a transition from ISO 27001:2013 revision to 2022 revision?

Contrary to popular belief, there will be no ISO 27001:2022 but an addendum to 27001:2013 (dubbed ISO/IEC 27001:2013+A1:2022, source). Annex A will be superseded by a normative version of ISO 27002:2022’s 93 new regulations (but without the useful hashtags).

If ISO 27001:2022 is amended, organizations who have already implemented ISO 27001:2013 are undoubtedly thinking to themselves, “Oh no, now that the 2022 revision has been published, we have to start over.” This is not true — while the 2022 revision does introduce some modifications, they are quite trivial. Organizations should plan for:

  • Assess the gap between the organization’s current controls and the new control set; update the organization’s risk assessment considering the their upcoming control update, and revise the organization’s statement of applicability considering their new risk assessment and new controls.
  • Update organizational security metrics in accordance with the organization’s new risk assessment and control procedures
  • Evaluate and alter third-party security solutions (e.g., Organization SIEM or GRC platform) to verify the artifacts used to show compliance support the new requirements.

3. Is the Auditor (certifying body) going to go through the revisions in the documentation?

If the organization is ISO 27001 Certified, the auditor will also examine documentation to determine whether the organization has made the necessary changes throughout the transition time. This will take place during regular surveillance audits.

ISO 27001 AND ISO 27002 Correlation & Differences in the updated versions of 2022

(ISO/IEC 27001:2022 and ISO/IEC 27002:2022)

ISO 27001 – A Framework for Information Security Management Systems

ISO 27001 is an ISMS (Information security management system) standard that emphasizes a risk-based approach to the management of people, processes, and technological controls. The standard’s structured nature to auditing people and technology interdependence enables the measurement, comparison, and improvement of multiple operational benchmarks if security breaches are detected.

The current standard, ISO/IEC 27001:2013, will shortly be replaced by ISO/IEC 27001:2022, the new international standard for information security management and will be renamed from “Information technology – Security techniques – Code of conduct for information security controls” to “Information security, cybersecurity, and privacy protection – Information security controls.”

Why should organizations implement ISO 27001

Businesses of all sizes face an imminent threat due to complex attacks, driven attackers and lack of current . Securing an organization’s information framework requires ensuring that security measures, controls, and policy guidelines fit the specific demands of an organization.

Adopting a proven security management system can fill gaps utilizing accurate and tried best practices. ISO 27001 is much more than a security standard. When implemented, the standard includes all stakeholders across the organization and has a scalable design that allows individuals, business units, or the whole organization to take responsibility for security in their environment.

This method aids management in strengthening security and increasing danger awareness at all levels of the organization. The ISO 27001 audit is frequently part of a more extensive organizational assessment that looks at all aspects of processes, technologies, and supply chains.

ISO 27001 a risk-based framework

Understanding that ISO 27001 is not a compliance tool but rather a risk-based framework and approach is critical. A risk-based strategy means that resources, cost, and time can be invested in minimizing threats based on the weightage of each threat and severity of the business risk. Thus making it possible to devote resources to initiatives that provide the greatest return on investment, rather than wasting time and money on “ticks in the compliance box” that have no real value.

What is the difference between ISO 27001 and 27002?

The distinguishing factor between ISO 27001 and ISO 27002 is that although an organization may achieve ISO 27001 certification, it cannot get ISO 27002 certification.

ISO 27001 is the primary standard, whereas ISO 27002 is a set of support controls that serves as a guideline and assists organizations in implementing best security practices to get ISO 27001 certification. They are following the same ISO 27000 Family.

How will the new ISO 27002 standard affect existing ISO 27001 certification or the current "first-time" implementation of the standard ?

If the 2022 revision of ISO 27001 is broadly identical to the 2013 revision, a recent version of Annex A will be applicable once the standard is published. This will be consistent with the controls specified in the new ISO 27002.

At the very least, organizations are expected to evaluate their risk assessment, identify appropriate new controls, and modify the ‘Statement of Applicability’ considering the revised ‘Annex A’. Organizations should evaluate the controls for any implementation modifications, as there are some new controls and revised guidelines for the remaining controls.

 

As previously stated, organizations are reminded that controls listed in ISO/IEC 27001 Annex A are not mandatory. ISO/IEC 27001 contains only two requirements: the use of Annex A’s control set as a reference for the comparison process (6.1.3 c)) and the development of a ‘Statement of Applicability’ (6.1.3 d)). These standards remain unaltered in ISO/IEC 27001:2022 and are essential to prevent accidental omissions.

Control themes of ISO 27001:2022

Control themes of ISO 27001:2022

Market assurance and governance

The advantages of deploying an information security management system (ISMS) is classified into these two key categories: Market Assurance and Governance.

Market Assurance refers to an information security management system’s (ISMS) ability to build market confidence in an organization’s ability to protect sensitive data. It demonstrates to external parties – clients, partners & investors that the organization will safeguard and maintain the security posture (including confidentiality, integrity, availability, and privacy of the customer’s information).

Governance is a collection of executive management responsibilities and processes to provide strategic direction, ensure objectives are being met, verify that risks are effectively managed, and validate that the enterprise’s resources are used effectively and responsibly.

To Summarize

The advantage of implementing the new controls is that because they are attribute-based, it is easier to focus on organization selections, which may reduce their compliance burden or help them see how to integrate the organization’s security processes better, thereby simplifying the implementation and management of the organization ISMS (information security management system).

Adobe’s Common Controls Framework of Industry-acclaimed security standards

Today’s world is an ever-changing scenario with changes to the technology sector happening more frequently than ever due to emerging technologies. The case is quite similar in the field of Cyber Security. There are a few industry-acclaimed cybersecurity standards for governing the processes and execution of these standards. These standards are usually built upon a framework of control objectives that need to be implemented by the organizations to comply with these standards. Compliance is measured in terms of control objectives meeting the compliance criteria and also other regulatory and statutory criteria.

Since most of these Cybersecurity standards speak of similar control objectives or lay emphasis on similar control areas, it is advisable to have the ‘Adobe’s Common Control Framework’, which means that if we are able to comply with a single requirement from a particular framework, in theory, we should be able to use the adherence of that requirement for ALL the similar frameworks. There are several approaches to achieving this Adobe’s Common Controls Framework both in theory and in practice and will be discussed in detail later on in this article. The most relevant security and privacy frameworks are ISO 27001, NIST, PCIDSS, GDPR, SOC Type 2.

There is a significant overlap of controls contained in these standards as all of these standards primarily deal with one requirement which is the protection of data. Protection of information from unauthorized disclosure, compromise, and theft forms the backbone or the building blocks of an Adobe’s Common Control Framework. This leverages the fact that similar controls or that the essence of the controls is the same across standards and can be used to gauge the adherence or compliance of an organization to the standard. In actual execution, while gauging the compliance of an organization, the Adobe’s Common Controls Framework is not only holistic but can reduce the effort and cost otherwise required by the organization to comply with individual standards.

There are two methods of developing the Adobe’s Common Control Framework for an organization and there are very subtle differences between the two methods. They are Controls harmonization and Controls Mapping.

Controls Harmonization:

Harmonization is the creation of a brand-new control language set from several source languages of standards taking into consideration content & context. In theory, the intent and meaning of the words and sentences remain intact, but the language and actual words of the individual standards have been changed with a new harmonized meaning defined. To achieve the usage of a single language as an industry, globally, it would have significant benefits and it would be the most efficient way to operate not only as security professionals but also as humans. Adobe’s Common Control Framework is an example of this type of construct. The benefits of having a single operating language can truly be amazing in terms of effort reduction and cost reduction.

Control Mapping:

Today, most brilliant and forward-thinking security professionals are using the control mapping method. The main idea behind this method is to keep the original language intact as much as possible while mapping and matching the intent and meaning of each sentence and word. This is the most practical and realistic approach because this is how humans fundamentally interact with each other globally. One can see this working in real life where two different languages are being spoken by individuals and kept mainly intact, but an interpreter or linguist is translating between the two — the map is developed in the mind of the linguist.

Some real-life examples of mapping for cybersecurity frameworks can be seen in HITRUST Framework, Cloud Security Alliance Framework, and even the U.S. Government formally uses mapping in NIST SP 800-53 Appendix H – NIST RMF to ISO 27001 Mapping Table. The benefits of control mapping are that it allows one to actually break away from a single monolithic language that is brittle when a new regulation is introduced. Control mapping is more holistic and comprehensive and aids the security professional in having a wider spectrum while implementing controls.

By now, as we have seen multiple security frameworks with rapidly emerging requirements are nothing but redundancy in controls across frameworks. Hence the way forward especially for a security consulting organization is to develop the Adobe’s Common Control Framework to gauge it’s client’s security posture comprehensively. Security risk and compliance teams are in a constant state of flux as they struggle to keep up with the ever-emerging regulations of a security framework or standard. Hence to restore stability in daily operations of compliance and security professionals, the Adobe’s Common Controls Framework is not only a savior but a game-changer too.

At Accorian, we are always committed to providing the best feasible security solution to our partners and clients as part of our service delivery. We apply Adobe Common Controls Framework (CCF) derived from multiple standards like ISO27001, PCIDSS, NIST, GDPR to gauge the security posture of an organization. Technically speaking our consultants at Accorian use Adobe Common Controls Framework (CCF) to conduct security maturity assessments of large and medium scale enterprises which in turn aid the consultants to draw out roadmaps for the elevation of the maturity level and the strategy involved in achieving it.

Risk Management Framework – Managing & Measuring what matters

A risk management program allows you to manage overall information security risk.  It is an approach to identify, quantify, mitigate, and monitor risks.  The reason to look at risk in a comprehensive manner is to make sure no one area is getting too much attention or, too little. Frameworks also help you identify the bigger elements of risk that need review and mitigation. Additionally, it help you to prioritize the treatment of certain risks. The adherence to risk frameworks also helps give your customers comfort that a standard risk management is in place and hence, reduce your audit burden. 

Typically, a Risk Management program comprises of the following phases:

  • Risk identification
  • Risk analysis
  • Risk evaluation
  • Risk treatment
  • Risk Monitoring

A good risk management framework will have the following characteristics:

  • Comprehensive in types of risks it covers
  • Practical for an organization to implement
  • Updated with current real-world risks
  • Based on controls that can be reviewed and audited
  • Reliable so that your vendors and customers can accept it

There are many risk management frameworks that one can choose from and it important to understand the advantages of each.

Common risk management frameworks include:

NIST (National Institute of Standards and Technology) framework is a comprehensive cybersecurity framework (CSF).  It is very widely accepted across different company sizes and business domains. Most cyber-security professionals are well aware of this framework as it is readily available.  Although widely available and very popular there is no certified third-party audit mechanism. Hence, it can only be self-assessed.  

SOC 2 Type 2 is an internal controls report based on the scope you define.  It is widely used in the United States to show the maturity of your controls.  A CPA firm that is part of the American Institute of CPAs (AICPA) conducts the audit & issues an assessment report.  The AICPA does not audit/review the assessment for completeness or quality. 

HITRUST CSF is a framework that came leverages NIST, SOC, and ISO along with others to create a more comprehensive standard.  It is widely implemented in the United States by organisations in the healthcare space.  Unlike others, although there are external assessors that are involved in the certification process, HITRUST reviews all assessments and issues the certificate. Additionally, among all the frameworks above it tends to be the most expensive to implement. 

It is important to choose a framework that matches your long-term security goals & needs.  At Accorian, we work with all of the above frameworks. We help organizations choose the right framework and aid with the implementation. This is done by augmenting our team into your security team to help steer the rollout, aid with query resolution, choosing of the right controls & workaround during mitigation advisory, facilitating the selection of vendors & products and end to end program management. 

Shukla CPA, d.b.a Accorian Assurance is a licensed, certified public accounting firm registered with the American Institute of Pubic Accountants (AICPA) and the Public Company Accounting Oversight Board (PCAOB). Esha IT Corp d.b.a Accorian is a global leader in cybersecurity and compliance professional services.

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