Moving From ISO/IEC 27001:2005 To ISO/IEC 27001:2013

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TransitionguideMoving from ISO/IEC 27001:2005to ISO/IEC 27001:2013The new international standardfor information securitymanagement systems

ISO/IEC 27001 - Information Security Management - Transition guideSuccessful businesses understand the value of timely, accurateinformation, good communications and secrecy. Information security isas much about exploiting the opportunities of our interconnected worldas it is about risk management.That’s why organizations need robust information security management.This guide has been designed to help you meet therequirements of the new international standardfor information security management,ISO/IEC 27001:2013, which is the first revisionof ISO/IEC 27001:2005.ISO/IEC 27001:2013 specifies the requirements forestablishing, implementing, maintaining andcontinually improving an information securitymanagement system (ISMS) for any organization,regardless of type or size. BSI recommends thatevery business has a system in place to maintain theconfidentiality, integrity and availability ofinformation. This will include its own information aswell as customer information and other interestedparties. In an ever increasing interconnected worldthe wisdom of doing this cannot be overestimated.Meeting the requirements of the new internationalstandard has never been easier. This guide is basedon David Brewer’s new books ‘An introduction toISO/IEC 27001:2013’, which shares practical2guidance on how to meet the requirements ofISO/IEC 27001:2013, and ‘Understanding the newISO management system requirements’, which looksat management systems in general and how totransition them to the new standards. These booksare available through the BSI shop.This transition guide will help you understand therelationship between ISO/IEC 27001:2013 and itspredecessor ISO/IEC 27001:2005 and the impactthat the new standard is likely to have on yourexisting ISMS.NB. This transition guide is designed to be read inconjunction with BS ISO/IEC 27001:2013 — Informationtechnology —Security techniques — Informationsecurity management systems — Requirements. It doesnot contain the complete content of the standard andshould not be regarded as a primary source of referencein place of the standard itself.

bsigroup.comWhy adopt an information securitystandard?There are various reasons why organizations choose to have an information security managementsystem (ISMS). These broadly fit broadly into two categories: market assurance and governance.Market assurance concerns the ability of an ISMS to provide confidence, within the marketplace,in an organization’s ability to look after information securely. In particular, it inspires confidence thatthe organization will maintain the confidentiality, integrity and availability of customer information.Governance concerns how organizations are managed. In this case, an ISMS is recognized as beinga proactive way to manage information security.A typical scenario in the case of market assurance is when a companydemands various assurances from its suppliers in order for them tocontinue as suppliers to that company. The norm used to be that suchcompanies would require their suppliers to conform to ISO 9001, butnow companies are also looking for assurances from their supplierswith regards to ISO/IEC 27001. In this case, the company will have aduty of due care to preserve the security of the information in itscustody. If that information is shared with a supplier, then thecompany would be failing in its duty of care if the supplier’s handlingof that information was insecure. It doesn’t matter whether thecompany chooses to do this for reasons of governance or marketassurance, it only matters that it doesAs the two categories are closely related, an organization may initiallychoose to have an ISMS in order to inspire confidence within themarketplace. Once it has its ISMS, as it matures, the people within theorganization often experience the benefits of being able to bettermanage information security. Therefore the organization’s reasons forhaving an ISMS may expand to cover both market assurance andgovernance. Likewise, another organization might start out by havingan ISMS for better management. However, as its ISMS matures, it maycommunicate its experiences and news on successful certificationaudits to the marketplace and learn the power of market assurance toattract new customers.Implementing ISO/IEC 27001ISO/IEC 27001:2013 specifies the requirements for establishing, implementing, maintaining andcontinually improving an ISMS. These requirements describe the intended behaviour of an ISMSonce it is fully operational. The standard is not a step by step guide on how to build or create anISMS.However there are a number of books and other standards in theISO/IEC 27000 series of standards which can assist. There are threecore standards:1 ISO/IEC 27003: Information technology —Security techniques —Information security management system implementationguidance;2 ISO/IEC 27004, Information technology —Security techniques —Information security management — Measurement; and3 ISO/IEC 27005, Information technology —Security techniques —Information security risk management.All three guidance standards are currently being revised, and presentlyonly address the requirements of ISO/IEC 27001:2005.3

ISO/IEC 27001 - Information Security Management - Transition guideComparing ISO/IEC 27001:2013with ISO/IEC 27001:2005ISO/IEC 27001:2013 is the first revision of ISO/IEC 27001. First andforemost, the revision has taken account of practical experience ofusing the standard: there are now over 17,000 registrationsworldwide. However, there have been two other major influences onthe revision. The first is an ISO requirement that all new and revisedmanagement system standards must conform to the high levelstructure and identical core text defined in Annex SL to Part 1 of theISO/IEC Directives. Conformance to these requirements will have atendency to make all management system standards look the same,with the intention that management system requirements that arenot discipline-specific are identically worded in all managementsystem standards. This is good news for organizations that operateintegrated management systems, i.e. management systems thatconform to several standards, such as ISO 9001 (quality), ISO 22301(business continuity) as well as ISO/IEC 27001. The second influencewas a decision to align ISO/IEC 27001 with the principles andguidance given in ISO 31000 (risk management). Again, this is goodnews for integrated management systems as now an organizationmay apply the same risk assessment methodology across severaldisciplines.The result is that structurally ISO/IEC 27001:2013 looks very differentto ISO/IEC 27001:2005.In addition, there are no duplicaterequirements, and the requirements are phrased in a way, whichallows greater freedom of choice on how to implement them. Agood example of this is that the identification of assets, threats andvulnerabilities is no longer a prerequisite for the identification ofinformation security risks. The standard now makes it clearer thatcontrols are not to be selected from Annex A, but are determinedthrough the process of risk treatment. Nevertheless, Annex Acontinues to serve as a cross-check to help ensure that no necessarycontrols have been overlooked.New concepts have been introduced (or updated) as follows:4New/updated conceptExplanationContext of the organizationThe environment in which the organization operatesIssues, risks and opportunitiesReplaces preventive actionInterested partiesReplaces stakeholdersLeadershipRequirements specific to top managementCommunicationThere are explicit requirements for both internal and external communicationsInformation security objectivesInformation security objectives are now to be set at relevant functions and levelsRisk assessmentIdentification of assets, threats and vulnerabilities is no longer a prerequisite for theidentification of information security risksRisk ownerReplaces asset ownerRisk treatment planThe effectiveness of the risk treatment plan is now regarded as being more important thanthe effectiveness of controlsControlsControls are now determined during the process of risk treatment, rather than being selectedfrom Annex ADocumented informationReplaces documents and recordsPerformance evaluationCovers the measurement of ISMS and risk treatment plan effectivenessContinual improvementMethodologies other than Plan-Do-Check-Act (PDCA) may be used

bsigroup.comClause 0: IntroductionThis is a much shorter clause than its predecessor. In particular thesection on the PDCA model has been removed. The reason for this isthat the requirement is for continual improvement (see Clause 10)and PDCA is just one approach to meeting that requirement. Thereare other approaches, and organizations are now free to use them ifthey wish.The introduction also draws attention to the order in whichrequirements are presented, stating that the order does not reflecttheir importance or imply the order in which they are to beimplemented.Clause 1: ScopeThis, too, is a much shorter clause. In particular there is no referenceto the exclusion of controls in Annex A.Clause 2: Normative referencesThe only normative reference is to ISO/IEC 27000, Informationtechnology — Security techniques — Information securitymanagement systems — Overview and vocabulary.Clause 3: Terms and definitionsThere are no longer any terms or definitions in ISO/IEC 27001:2013.Instead, readers are referred to ISO/IEC 27000. However, pleaseensure that you use a version of ISO/IEC 27000 that was publishedafter ISO/IEC 27001:2013 otherwise it will not contain the correctterms or definitions. This is an important document to read. Manydefinitions, for example ‘management system’ and ‘control’ have beenchanged and now conform to the definitions given in the new ISOdirectives and ISO 31000. If a term is not defined in ISO/IEC 27000,please use the definition given in the Oxford English Dictionary. Thisis important, otherwise confusion and misunderstanding may be theresult.Clause 4: Context of the organizationThis is a new clause that in part addresses the depreciated concept ofpreventive action and in part establishes the context for the ISMS. Itmeets these objectives by drawing together relevant external andinternal issues (i.e. those that affect the organization’s ability to achievethe intended outcome(s) of its ISMS) with the requirements ofinterested 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 previousstandard, but also important topics for the ISMS to address, such asany market assurance and governance goals that the organizationmight set for the ISMS. Further guidance is given in Clause 5.3 ofISO 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 itselfcan be thought of as a governance requirement, as strictly speaking anISMS that did not conform to generally-accepted public expectationscould now be ruled nonconformant with the standard.The final requirement (Clause 4.4) is to establish, implement, maintainand continually improve the ISMS in accordance with therequirements the standard.Clause 5: LeadershipThis clause places requirements on ‘top management’ which is theperson or group of people who directs and controls the organizationat the highest level. Note that if the organization that is the subjectof the ISMS is part of a larger organization, then the term ‘topmanagement’ refers to the smaller organization. The purpose ofthese requirements is to demonstrate leadership and commitmentby leading from the top.A particular responsibility of top management is to establish theinformation security policy, and the standard defines thecharacteristics and properties that the policy is to include.Finally, the clause places requirements on top management to assigninformation security relevant responsibilities and authorities,highlighting two particular roles concerning ISMS conformance toISO/IEC 27001 and reporting on ISMS performance.Clause 6: PlanningClause 6.1.1, General: This clause works with Clauses 4.1 and 4.2 tocomplete the new way of dealing with preventive actions. The firstpart of this clause (i.e. down to and including 6.1.1 c)) concerns riskassessment whilst Clause 6.1.1 d) concerns risk treatment. As theassessment and treatment of information security risk is dealt within Clauses 6.1.2 and 6.1.3, then organizations could use this clause toconsider ISMS risks and opportunities.Clause 6.1.2, Information security risk assessment: This clausespecifically concerns the assessment of information security risk. Inaligning with the principles and guidance given in ISO 31000, thisclause removes the identification of assets, threats andvulnerabilities as a prerequisite to risk identification. This widens thechoice of risk assessment methods that an organization may use andstill conforms to the standard. The clause also refers to ‘riskassessment acceptance criteria’, which allows criteria other than justa single level of risk. Risk acceptance criteria can now be expressedin terms other than levels, for example, the types of control used totreat 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 planand residual risks.In other ways the clause closely resembles its counterpart inISO/IEC 27001:2005 by requiring organizations to assessconsequence, likelihood and levels of risk.5

ISO/IEC 27001 - Information Security Management - Transition guideClause 6.1.3, Information security risk treatment: This clauseconcerns the treatment of information security risk. It is similar to itscounterpart in ISO/IEC 27001:2005, however, it refers to the‘determination’ of necessary controls rather than selecting controlsfrom Annex A. Nevertheless, the standard retains the use of Annex Aas a cross-check to make sure that no necessary control has beenoverlooked, and organizations are still required to produce aStatement of Applicability (SOA). The formulation and approval of therisk treatment plan is now part of this clause.Clause 6.2, Information security objectives and planning to achievethem: This clause concerns information security objectives. It usesthe 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 thehighest. The clause defines the properties that an organization’sinformation security objectives must possess.Clause 7: SupportThis clause begins with a requirement that organizations shalldetermine and provide the necessary resources to establish,implement, maintain and continually improve the ISMS. Simplyexpressed, this is a very powerful requirement covering all ISMSresource needs.The clause continues with requirements for competence, awarenessand communication, which are similar to their counterparts inISO/IEC 27001:2005.Finally, there are the requirements for ‘documented information’.‘Documented information’ is a new term that replaces the referencesin the 2005 standard to ‘documents’ and ‘records’. Theserequirements relate to the creation and updating of documentedinformation and to their control. The requirements are similar to theircounterparts in ISO/IEC 27001:2005 for the control of documentsand for the control of records.Note that the requirements for documented information arepresented in the clause to that they refer to. They are not summarizedin a clause of their own, as they are in ISO/IEC 27001:2005.Clause 8: OperationThis clause deals with the execution of the plans and processes thatare the subject of previous clauses.1 Clause 8.1 deals with the execution of the actions determined inClause 6.1, the achievement of the information security objectivesand outsourced processes;2 Clause 8.2 deals with the performance of information security riskassessments at planned intervals, or when significant changes areproposed or occur; and3 Clause 8.3 deals with the implementation of the risk treatment plan.6Clause 9: Performance evaluationClause 9.1, Monitoring, measurement, analysis and evaluation: The firstparagraph of Clause 9.1 states the overall goals of the clause. As ageneral recommendation, determine what information you need toevaluate the information security performance and the effectivenessof your ISMS. Work backwards from this ‘information need’ todetermine what to measure and monitor, when, who and how. There islittle point in monitoring and making measurements just because yourorganization has the capability of doing so. Only monitor and measureif it supports the requirement to evaluate information securityperformance and ISMS effectiveness.Note that an organization may have several information needs, andthese needs may change over time. For example, when an ISMS isrelatively new, it may be important just to monitor the attendance at,say, information security awareness events. Once the intended ratehas been achieved, the organization might look more towards thequality of the awareness event. It might do this by setting specificawareness objectives and determining the extent to which theattendees have understood what they have learnt. Later still, theinformation need may extend to determine what impact this level ofawareness has on information security for the organization.Clause 9.2, Internal audit: This clause is similar to its counterpart inISO/IEC 27001:2005. However, the requirement holding managementresponsible for ensuring that audit actions are taken without unduedelay has been removed, as it is effectively covered by therequirements in Clause 10.1 (in particular 10.1 a), c) and d)). Therequirement that auditors shall not audit their own work has also beenremoved, as it is covered by the requirement to ensure objectivity andimpartiality (Clause 9.2 e)).Clause 9.3, Management review: Rather than specify precise inputsand outputs, this clause now places requirements on the topics forconsideration during the review. The requirement for reviews to beheld at planned intervals remains but the requirement to hold thereviews at least once per year has been dropped.Clause 10: ImprovementDue to the new way of handling preventive actions, there are nopreventive action requirements in this clause. However, there are somenew corrective action requirements. The first is to react tononconformities and take action, as applicable, to control and correctthe nonconformity and deal with the consequences. The second is todetermine whether similar nonconformities exist, or could potentiallyoccur. Although the concept of preventive action has evolved there isstill a need to consider potential nonconformities, albeit as aconsequence of an actual nonconformity. There is also a newrequirement to ensure that corrective actions are appropriate to theeffects of the nonconformities encountered.The requirement for continual improvement has been extended tocover the suitability and adequacy of the ISMS as well as itseffectiveness, but it no longer specifies how an organization achievesthis.

bsigroup.comAnnex AThe title of Annex A is now “reference control objectives and controls”and the introduction is simplified. It states that the control objectivesand controls are directly derived from ISO/IEC 27002:2013 and thatthe Annex is to be used in the context of Clause 6.1.3.During the revision of ISO/IEC 27002 the number of controls has beenreduced from 133 controls to 114 controls, and the number of majorclauses has been expanded from 11 to 14. Some controls are identicalor otherwise very similar; some have been merged together; somehave been deleted and some are new. For example:1 A.5.1.1, Policies for information security is ve

ISO/IEC 27001:2013 is the first revision of ISO/IEC 27001. First and foremost, the revision has taken account of practical experience of using the standard: there are now over 17,000 registrations worldwide. However, there have been two other major influences on the revision. The first is an ISO requirement that all new and revised

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Schiavo ex rel. Schiavo, _ F.3d _, 2005 WL 648897 (11th Cir. Mar. 23, 2005) (Schiavo I), stay denied, _ S. Ct. _, 2005 WL 672685 (Mar. 24, 2005). After that appeal was taken, the plaintiffs filed an amended complaint on March 22, 2005, adding four more counts, and a second amended complaint on March 24, 2005, adding a fifth count. On the basis of the claims contained in those new .