ISO 27001 Gap Analysis Checklist V2
ISO 27001 Gap Analysis Checklist V2
Purpose
This tool is designed to assess the current situation and capability maturity model (CMM) level of each ISO 27001:2013 An
Instructions
1) Complete the Check List tab with findings, participants, and CMM level.
Note: Please see the Assessment Scale tab for the definition of CMM level.
0 – Non-existent / Not
1 – Initial / Ad Hoc
applicable
If not applicable, indicate the reason Indicate any plan to move forward to
why address the issues
2 – Repeatable but Intuitive 3 – Defined
4.1
4.2
4.2 (a)
4.2 (b)
4.3
4.3
4.4
4.4
5
5.1
5.1
5.2
5.2
5.3
5.3
6
6.1
6.1.1
6.1.2
6.1.3
6.2
6.2
7
7.1
7.1
7.2
7.2
7.3
7.3
7.4
7.4
7.5
7.5.1
7.5.2
7.5.3
8
8.1
8.1
8.2
8.2
8.3
8.3
9.1
9.1
9.2
9.2
9.3
9.3
10
10.1
10.1
10.2
10.2
Check List - Mandatory Requirements
Determine the aims of your organisation's ISMS and any issues that might affect its effectiveness Initial / Ad Hoc
Interested parties
Identify interested parties including applicable laws, regulations, contracts etc. Defined
Determine those parties' information security-relevant requirements and obligations Defined
ISMS scope
ISMS
Establish, implement, maintain and continually improve your ISMS according to the standard Initial / Ad Hoc
Leadership
Leadership and commitment
Top management must demonstrate leadership and commitment to the ISMS Initial / Ad Hoc
Policy
Planning
Actions to address risks and opportunities
Repeatable
Design/plan the ISMS to satisfy the requirements, addressing risks and opportunities
but Intuitive
Repeatable
Define and apply an information security risk assessment process
but Intuitive
Repeatable
Document and apply an information security risk treatment process
but Intuitive
Repeatable
Establish and document the information security objectives and plans
but Intuitive
Support
Resources
Managed &
Determine and allocate necessary resources for the ISMS
Measureable
Competence
Awareness
Repeatable
Establish a security awareness program
but Intuitive
Communication
Repeatable
Determine the need for internal and external communications relevant to the ISMS
but Intuitive
Documented information
Provide documentation required by the standard plus that required by the organisation Initial / Ad Hoc
Provide document titles, authors etc., format them consistently, and review and approve them Initial / Ad Hoc
Operation
Operational planning and control
Plan, implement, control and document ISMS processes to manage risks (i.e. a risk treatment
Non-existent
plan)
Information security risk assessment
Repeatable
Reassess and document information security risks regularly and on changes
but Intuitive
Repeatable
Implement the risk treatment plan (treat the risks!) and document the results
but Intuitive
Performance evaluation
Repeatable
Monitor, measure, analyse and evaluate the ISMS and the controls
but Intuitive
Internal audit
Management review
Improvement
Nonconformity and corrective action
Repeatable
Identify, fix and take action to prevent nonconformities from recurring, documenting the actions
but Intuitive
Continual improvement
Number of requirements 27
ndatory Requirements
Notes Rate
2.5
2
Done, permament process to be formalized 2
4
4
4
2
2
2
3
3
2.7142857
2
2
2.3333333
2.5
3
2
Current CMM level of each security control area of ISO 27001:2013 Mandatory Req
4. Context of Organization
8. Operation 7. Support
13 Mandatory Requirements
5. Leadership
6. Planning
port
Check List - Anne
A.6.2.2 Teleworking
A.7.1.1 Screening
A.7.1.2 Terms and conditions of
employment
A.11.2 Equipment
Objective: To prevent loss, damage, theft, or compromise of assets and interruption to the organization’s operations.
A.17.2 Redundancies
Objective: To ensure availability of information processing facilities.
A.17.2.1 Availability of information
processing facilities
A.18 Compliance
A.18.1 Compliance with legal and contractual requirements
Objective: To avoid breaches of legal, statutory, regulatory, or contractual obligations related to information security and of a
mation security
irection and support for information security in accordance with business requirements and relevant laws and
Control
A set of policies for information security shall be defined, approved by management, published, and
communicated to employees and relevant external parties.
Control
The policies for information security shall be reviewed at planned intervals, or if significant changes
occur, to ensure their continuing suitability, adequacy, and effectiveness.
curity
nt frameworkControl
to initiate and control the implementation and operation of information security within the
All information security responsibilities shall be defined and allocated.
Control
Conflicting duties and areas of responsibility shall be segregated to reduce opportunities for
unauthorized or unintentional modification or misuse of the organization’s assets.
Control
Appropriate contacts with relevant authorities shall be maintained.
Control
Appropriate contacts with special interest groups or other specialist security forums and professional
associations shall be maintained.
Control
Information security shall be addressed in project management, regardless of the type of project.
g
eleworking and use of mobile devices.
Control
A policy and supporting security measures shall be adopted to manage the risks introduced by using
mobile devices.
Control
A policy and supporting security measures shall be implemented to protect information accessed,
processed, or stored at teleworking sites.
and contractors understand their responsibilities and are suitable for the roles for which they are considered.
Control
Background verification checks on all candidates for employment shall be carried out in accordance
with relevant laws, regulations, and ethics, and shall be proportional to the business requirements, the
classification of the information to be accessed, and the perceived risks.
Control
The contractual agreements with employees and contractors shall state their and the organization’s
responsibilities for information security.
and contractors are aware of and fulfil their information security responsibilities.
Control
Management shall require all employees and contractors to apply information security in accordance
with the established policies and procedures of the organization.
Control
All employees of the organization and, where relevant, contractors shall receive appropriate
awareness education and training and regular updates in organizational policies and procedures, as
relevant to their job function.
Control
There shall be a formal and communicated disciplinary process in place to take action against
employees who have committed an information security breach.
ployment
n’s interests as part of the process of changing or terminating employment.
Control
Information security responsibilities and duties that remain valid after termination or change of
employment shall be defined, communicated to the employee or contractor, and enforced.
Control
Assets associated with information and information processing facilities shall be identified and an
inventory of these assets shall be drawn up and maintained.
Control
Assets maintained in the inventory shall be owned.
Control
Rules for the acceptable use of information and of assets associated with information and information
processing facilities shall be identified, documented, and implemented.
Control
All employees and external-party users shall return all of the organizational assets in their possession
upon termination of their employment, contract, or agreement.
receives an appropriate level of protection in accordance with its importance to the organization.
Control
Information shall be classified in terms of legal requirements, value, criticality, and sensitivity to
unauthorized disclosure or modification.
Control
An appropriate set of procedures for information labelling shall be developed and implemented in
accordance with the information classification scheme adopted by the organization.
Control
Procedures for handling assets shall be developed and implemented in accordance with the
information classification scheme adopted by the organization.
Control
Media shall be disposed of securely when no longer required, using formal procedures.
Control
Media containing information shall be protected against unauthorized access, misuse, or corruption
during transportation.
ss control
ion and information processing facilities.
Control
An access control policy shall be established, documented, and reviewed based on business and
information security requirements.
Control
Users shall only be provided with access to the network and network services that they have been
specifically authorized to use.
Control
A formal user registration and de-registration process shall be implemented to enable assignment of
access rights.
Control
A formal user access provisioning process shall be implemented to assign or revoke access rights for
all user types to all systems and services.
Control
The allocation and use of privileged access rights shall be restricted and controlled.
Control
The allocation of secret authentication information shall be controlled through a formal management
process.
Control
Asset owners shall review users’ access rights at regular intervals.
Control
The access rights of all employees and external-party users to information and information processing
facilities shall be removed upon termination of their employment, contract, or agreement, or adjusted
upon change.
control
ccess to systems and applications.
Control
Access to information and application system functions shall be restricted in accordance with the
access control policy.
Control
Where required by the access control policy, access to systems and applications shall be controlled by
a secure log-on procedure.
Control
Password management systems shall be interactive and shall ensure quality passwords.
Control
The use of utility programs that might be capable of overriding system and application controls shall be
restricted and tightly controlled.
Control
Access to program source code shall be restricted.
ctive use of cryptography to protect the confidentiality, authenticity, and/or integrity of information.
Control
A policy on the use of cryptographic controls for protection of information shall be developed and
implemented.
Control
A policy on the use, protection, and lifetime of cryptographic keys shall be developed and implemented
through their whole lifecycle.
ecurity
hysical access, damage, and interference to the organization’s information and information-processing facilities.
Control
Security perimeters shall be defined and used to protect areas that contain either sensitive or critical
information and information-processing facilities.
Control
Secure areas shall be protected by appropriate entry controls to ensure that only authorized personnel
are allowed access.
Control
Physical security for offices, rooms, and facilities shall be designed and applied.
Control
Physical protection against natural disasters, malicious attack, or accidents shall be designed and
applied.
Control
Procedures for working in secure areas shall be designed and applied.
Control
Access points such as delivery and loading areas, and other points where unauthorized persons could
enter the premises, shall be controlled and, if possible, isolated from information processing facilities to
avoid unauthorized access.
Control
Equipment shall be sited and protected to reduce the risks from environmental threats and hazards,
and opportunities for unauthorized access.
Control
Equipment shall be protected from power failures and other disruptions caused by failures in
supporting utilities.
Control
Power and telecommunications cabling carrying data or supporting information services shall be
protected from interception, interference, or damage.
Control
Equipment shall be correctly maintained to ensure its continued availability and integrity.
Control
Equipment, information, or software shall not be taken off-site without prior authorization.
Control
Security shall be applied to off-site assets, taking into account the different risks of working outside the
organization’s premises.
Control
All items of equipment containing storage media shall be verified to ensure that any sensitive data and
licensed software has been removed or securely overwritten prior to disposal or re-use.
Control
Users shall ensure that unattended equipment has appropriate protection.
Control
A clear desk policy for papers and removable storage media and a clear screen policy for information
processing facilities shall be adopted.
esponsibilities
ure operations of information-processing facilities.
Control
Operating procedures shall be documented and made available to all users who need them.
Control
Changes to the organization, business processes, information-processing facilities, and systems that
affect information security shall be controlled.
Control
The use of resources shall be monitored and tuned, and projections made of future capacity
requirements to ensure the required system performance.
Control
Development, testing, and operational environments shall be separated to reduce the risks of
unauthorized access or changes to the operational environment.
erate evidence.
Control
Event logs recording user activities, exceptions, faults, and information security events shall be
produced, kept, and regularly reviewed.
Control
Logging facilities and log information shall be protected against tampering and unauthorized access.
Control
System administrator and system operator activities shall be logged and the logs protected and
regularly reviewed.
Control
The clocks of all relevant information processing systems within an organization or security domain
shall be synchronized to a single reference time source.
e
operational systems.
Control
Procedures shall be implemented to control the installation of software on operational systems.
ement
technical vulnerabilities.
Control
Information about technical vulnerabilities of information systems being used shall be obtained in a
timely fashion, the organization’s exposure to such vulnerabilities evaluated, and appropriate
measures taken to address the associated risk.
Control
Rules governing the installation of software by users shall be established and implemented.
siderations
audit activities on operational systems.
Control
Audit requirements and activities involving verification of operational systems shall be carefully
planned and agreed on to minimize disruptions to business processes.
t
f information in networks and its supporting information processing facilities.
Control
Networks shall be managed and controlled to protect information in systems and applications.
Control
Security mechanisms, service levels, and management requirements of all network services shall be
identified and included in network services agreements, whether these services are provided in-house
or outsourced.
Control
Groups of information services, users, and information systems shall be segregated on networks.
information transferred within an organization and with any external entity.
Control
Formal transfer policies, procedures, and controls shall be in place to protect the transfer of
information through the use of all types of communication facilities.
Control
Agreements shall address the secure transfer of business information between the organization and
external parties.
Control
Information involved in electronic messaging shall be appropriately protected.
Control
Requirements for confidentiality or non-disclosure agreements reflecting the organization’s needs for
the protection of information shall be identified, regularly reviewed, and documented.
Control
The information-security related requirements shall be included in the requirements for new
information systems or enhancements to existing information systems.
Control
Information involved in application services passing over public networks shall be protected from
fraudulent activity, contract dispute, and unauthorized disclosure and modification.
Control
Information involved in application service transactions shall be protected to prevent incomplete
transmission, mis-routing, unauthorized message alteration, unauthorized disclosure, unauthorized
message duplication, or replay.
support processes
security is designed and implemented within the development lifecycle of information systems.
Control
Rules for the development of software and systems shall be established and applied to developments
within the organization.
Control
Changes to systems within the development lifecycle shall be controlled by the use of formal change
control procedures.
Control
When operating platforms are changed, business critical applications shall be reviewed and tested to
ensure there is no adverse impact on organizational operations or security.
Control
Modifications to software packages shall be discouraged, or limited to necessary changes, and all
changes shall be strictly controlled.
Control
Principles for engineering secure systems shall be established, documented, maintained, and applied
to any information system implementation efforts.
Control
Organizations shall establish and appropriately protect secure development environments for system
development and integration efforts that cover the entire system development lifecycle.
Control
The organization shall supervise and monitor the activity of outsourced system development.
Control
Testing of security functionality shall be carried out during development.
Control
Acceptance testing programs and related criteria shall be established for new information systems,
upgrades, and new versions.
r relationships
e organization’s assets that are accessible by suppliers.
Control
Information security requirements for mitigating the risks associated with supplier’s access to the
organization’s assets shall be agreed upon with the supplier and documented.
Control
All relevant information security requirements shall be established and agreed upon with each supplier
that may access, process, store, communicate, or provide IT infrastructure components for the
organization’s information.
Control
Agreements with suppliers shall include requirements to address the information security risks
associated with information and communications technology services and product supply chain.
agement
el of information security and service delivery in line with supplier agreements.
Control
Organizations shall regularly monitor, review, and audit supplier service delivery.
Control
Changes to the provision of services by suppliers, including maintaining and improving existing
information security policies, procedures, and controls, shall be managed, taking into account the
criticality of business information, systems, and processes involved and re-assessment of risks.
management
ecurity incidents and improvements
d effective approach to the management of information security incidents, including communication on security
Control
Management responsibilities and procedures shall be established to ensure a quick, effective, and
orderly response to information security incidents.
Control
Information security events shall be reported through appropriate management channels as quickly as
possible.
Control
Employees and contractors using the organization’s information systems and services shall be
required to note and report any observed or suspected information security weaknesses in systems or
services.
Control
Information security events shall be assessed and it shall be decided if they are to be classified as
information security incidents.
Control
Information security incidents shall be responded to in accordance with the documented procedures.
Control
Knowledge gained from analyzing and resolving information security incidents shall be used to reduce
the likelihood or impact of future incidents.
Control
The organization shall define and apply procedures for the identification, collection, acquisition, and
preservation of information, which can serve as evidence.
Control
The organization shall determine its requirements for information security and the continuity of
information security management in adverse situations, e.g. during a crisis or disaster.
Control
The organization shall establish, document, implement, and maintain processes, procedures, and
controls to ensure the required level of continuity for information security during an adverse situation.
Control
The organization shall verify the established and implemented information security continuity controls
at regular intervals in order to ensure that they are valid and effective during adverse situations.
ntractual requirements
, statutory, regulatory, or contractual obligations related to information security and of any security requirements.
Control
All relevant legislative statutory, regulatory, contractual requirements, and the organization’s approach
to meet these requirements shall be explicitly identified, documented, and kept up to date for each
information system and the organization.
Control
Appropriate procedures shall be implemented to ensure compliance with legislative, regulatory, and
contractual requirements related to intellectual property rights and use of proprietary software
products.
Control
Records shall be protected from loss, destruction, falsification, unauthorized access, and unauthorized
release in accordance with legislative, regulatory, contractual, and business requirements.
Control
Privacy and protection of personally identifiable information shall be ensured as required in relevant
legislation and regulation where applicable.
Control
Cryptographic controls shall be used in compliance with all relevant
agreements, legislation, and regulations.
security is implemented and operated in accordance with the organizational policies and procedures.
Control
The organization’s approach to managing information security and its implementation (e.g. control
objectives, controls, policies, processes, and procedures for information security) shall be reviewed
independently at planned intervals or when significant changes occur.
Control
Managers shall regularly review the compliance of information processing and procedures within their
area of responsibility with the appropriate security policies, standards, and any other security
requirements.
Control
Information systems shall be regularly reviewed for compliance with the organization’s information
security policies and standards.
Results
CMM Level Remarks Control Owner
4
2.3
3.6
3
2.66666666666667
4
2
1.66666666666667
2.33333333333333
2
3
1.66666666666667
2.275
2.5
2
2
1.6
2.33333333333333
2
1
1.66666666666667
2.5
3
3
2.5
2.75
3
2.5
1
1
2.42857142857143
2.42857142857143
3
3
2.5
2.33333333333333
2
2
2.66666666666667
2
Current CMM level of each security control area of ISO 27001:20
A.17 Information security aspects of business continuity management A.7 Human resourc
A.10 Cryptography
1
2
3
4
5
6
7
Mandatory documents and records required by ISO 27001:2013
(documents from Annex A are mandatory only if there are risks which would require their implementation.)
Scope of the ISMS (clause 4.3)
Information security policy and objectives (clauses 5.2 and 6.2)
Risk assessment and risk treatment methodology (clause 6.1.2)
Statement of Applicability (clause 6.1.3 d)
Risk treatment plan (clauses 6.1.3 e and 6.2)
Risk assessment report (clause 8.2)
Definition of security roles and responsibilities (clauses A.7.1.2 and A.13.2.4)
Inventory of assets (clause A.8.1.1)
Acceptable use of assets (clause A.8.1.3)
Access control policy (clause A.9.1.1)
Operating procedures for IT management (clause A.12.1.1)
Secure system engineering principles (clause A.14.2.5)
Supplier security policy (clause A.15.1.1)
Incident management procedure (clause A.16.1.5)
Business continuity procedures (clause A.17.1.2)
Statutory, regulatory, and contractual requirements (clause A.18.1.1)
Mandatory records:
Records of training, skills, experience and qualifications (clause 7.2)
Monitoring and measurement results (clause 9.1)
Internal audit program (clause 9.2)
Results of internal audits (clause 9.2)
Results of the management review (clause 9.3)
Results of corrective actions (clause 10.1)
Logs of user activities, exceptions, and security events (clauses A.12.4.1 and A.12.4.3)
Status (Existing / Not Existing)