There are significant changes in store for the ISO 27001 and 27002 standards in 2022, which has resulted in a surge of inquiries. Many are curious about how these changes will impact organizations that are already certified in ISO 27001 and those that are in the process of obtaining certification. This piece will outline some of the primary changes and their potential effects.
First, the 2022 revision of ISO 27001 has not been formally published yet (as of July 2022). Regardless, we still have a good idea of what it will look like as the Annex A controls are aligned with the implementation guidance found in ISO 27002, which was published in February and is available here.
The implementation timeline for the updated version of ISO 27001, which is set to be released in 2022, has yet to be formally established. However, industry experts are predicting that organizations will have at least 18 to 24 months to comply with the new standard.
During this timeframe, organizations will need to take the necessary steps to update their information security management systems (ISMS) and ensure they are aligned with the new requirements outlined in the updated standard. This may include conducting a gap analysis to identify areas of non-compliance and implementing corrective actions to address any deficiencies.
Required management clauses are not changing
Organizations that have already implemented ISO 27001 understand that the framework is a management standard first and foremost. The management requirements for implementing and maintaining an Information Security Management System (ISMS) are contained in the ISO Clauses 4 through 10. Those clauses are not materially changing.
Changes to the Annex A controls
The upcoming updates to the ISO 27001 standard will primarily impact the Annex A controls. For those who may not be familiar, the Annex A controls refer to the set of controls that organizations typically use to manage and minimize information security risks in a normative manner.
While organizations are not necessarily obligated to adopt all the controls listed in Annex A, most choose to implement them as they provide a comprehensive framework for addressing common information security concerns. Therefore, any changes made to these controls will have a significant impact on the information security practices of organizations.
With that said, let’s take a closer look at the specific changes being made to the Annex A controls in the upcoming update of the ISO 27001 standard.
Organization of the controls
In the current framework, there are 114 controls organized into 14 categories (A.5-A.18). In the 2022 version, there are 93 controls organized into four categories (A.5-A.8). Although the organization of controls is substantially different, the content is more consistent.
There are 12 net new controls which I list in this blog post. The remaining 81 controls are largely the same as existing controls—in some cases, the wording has been altered slightly or controls have been combined.
Another significant change to the look and feel of the new Annex A controls is the addition of an “Attribute Table” for each control. The Attributes are five pieces of metadata that give the user more insight into the function and intent of each control. The categories of Attributes are:
- Control type
- Information security properties
- Cybersecurity concepts
- Operational capabilities
- Security domains
The Control types indicate “when and how the control modifies the risk.” The meaning of the three types is fairly self-evident:
A preventative control should be implemented to prevent an information security event or incident. A detective control detects the possible occurrence of an event or incident, and a corrective control is used to respond to an incident and restore a safe, secure operating environment. The Information security properties describe the aspect of information security protection the control contributes to. The properties are related to the familiar “CIA Triad”:
The Cybersecurity concepts are a logical grouping related to the association of controls in ISO 27110. The concepts are similar to the logical grouping used by the NIST Cybersecurity Framework. The concepts are:
The Operational capabilities describe 15 practitioner capabilities that these controls support. Most controls are related to a single capability, but a few controls relate to multiple. The capabilities are:
- Asset management
- Information protection
- Human resource security
- Physical security
- System and network security
- Application security
- Secure configuration
- Identity and access management
- Threat and vulnerability management
- Supplier relationships security
- Legal and compliance
- Information security event management
- Information security assurance
Finally, the controls are grouped into four high-level Security domains:
- Governance and ecosystem
The attributes are not requirements and are only to be used to the extent that an organization finds them helpful or useful. An organization is free to disregard, modify, or add to the attributes in accordance with its own ISMS and management preferences.
The current control “objectives” have been changed to “purpose” statements, and these purposes/objectives are listed for every control, not just at the control category level as they are in the current version. I’d argue that this makes the control purpose a bit clearer and more granular, and I expect most users will find this change helpful.
Content of control changes
ISO 27002 provides significant guidance with respect to each control. This is extremely useful as it gives a complete picture of the intent of the control, as well as practical examples regarding what implementation might look like. This guidance is also excellent for organizations that have achieved compliance and are now looking to understand or deepen their control maturity. While a complete article could be written about each net-new control, I’ll provide some highlights here.
5.7 Threat Intelligence: This is an extension of the previous control regarding subscribing to alerts. Assuming an organization is receiving alerts about threats and vulnerabilities, the next step is to develop the capability and associated processes for analyzing and assessing that information to create relevant and actionable intelligence.
5.16 Identity Management: The access management controls require the unique identification of individuals. The guidance states that non-human identities shall be managed, and shared accounts [shall be] limited and tightly controlled.
5.23 Security for Cloud Services: The guidance states that organizations shall implement processes, procedures, and policies for managing cloud services; ISO recognizes that the use of cloud services introduces certain risks for organizations that need to be proactively managed.
5.30 ICT Readiness for Business Continuity: This control requires planning and testing continuity plans for the organization’s technology. Many people think this is part of the current ISO standard, but the current Annex A technically only has controls addressing maintenance of information security continuity processes (but no explicit control to perform business continuity planning).
7.4 Physical Security Monitoring: A new control to continuously monitor protected physical spaces with technologies like cameras and/or physical intrusion detection systems.
8.1 User Endpoint Devices: The new guidance states that controls shall be implemented to protect information on endpoints (i.e. laptops).
8.9 Configuration Management: The new guidance states that secure configurations shall be defined and managed for hardware, software, and services.
8.10 Information Deletion: The new guidance states that data retention policies and processes shall ensure that data is deleted when no longer needed by the organization.
8.11 Data Masking: The new guidance states that controls shall be implemented to limit the exposure of sensitive data. The control language says “masking” but should be thought of more as “de-identification”, as the guidance includes pseudonymization and anonymization.
8.12 Data Leakage Prevention: This is a data loss prevention (DPL) control. The new guidance states that automated tools should prevent sensitive data from being sent to unauthorized recipients.
8.22 Web Filtering: The new guidance states that outbound web traffic should be filtered to prevent malware from connecting to command and control servers, as well as to prevent traffic to other malicious websites.
8.28 Secure Coding: The new guidance states that secure coding principles shall be applied to minimize vulnerabilities in code. The current control set requires rules for the secure development of software and systems, while the new control language is focused on the application and implementation of code security practices.