27001-Gap-Analysis - Updated
27001-Gap-Analysis - Updated
Evidence: Yes No
Approved Information Security Policy
document.
Management sign-off or endorsement of the
policy.
Policy distribution records or acknowledgment
logs.
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 1
New requirement Phase Clause(s) Activity
Information security objectives are to be monitored. Assess 6.2.d) Have you established how information security
objectives are to be monitored and whom shall be
responsible for this?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
ISMS performance monitoring plan.
Key Performance Indicators (KPIs) linked to
each information security objective.
Defined metrics such as incident response
time, risk reduction rates, patch management
compliance,
New etc.
requirement Phase Clause(s) Activity
Changes to the ISMS are to be planned. Plan 6.3 Have you established a process for managing changes
to the ISMS? How are changes authorised?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Approved Change Management Policy
document.
Change Control Procedure detailing roles,
responsibilities, and workflows.
Evidence:
Change
New Request Forms (CRFs).
requirement Phase Clause(s) Activity
Completed CRFs Found
Changes in the needs and expectations of interested Action 9.3.2.c) Are the needs and expectations of interested parties
parties are to be addressed during management (relevant to the ISMS) reviewed during MR?
review.
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Management Review Agenda with a section
titled Needs and Expectations of Interested
Parties.
Version-controlled meeting agenda template
ensuring consistency in reviews.
New requirement Phase Control(s) Activity
Threat intelligence Plan 5.7 Have you identified your threat intelligence requirements
based upon a risk assessment of information,
information storage and information processing assets?
What information relating to security threats do you
collect/receive?
Is information relating to security threats analysed and if
so, by whom?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Approved risk assessment reports (aligned
with Clause 6.1.2).
Asset inventory or classification register
mapping threats to assets.
Records showing prioritization of threat
intelligence needs based on risk severity.
Evidence:
Threat Intelligence Requirements Document
outlining:
Types of threats to be monitored (e.g.,
malware, phishing, APTs).
Source of threats (external/internal,
sector-specific).
Relevant information assets to protect.
Documented relationship between risks and
threat intelligence needs.
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 2
New requirement Phase Control(s) Activity
Security considerations and controls for cloud Plan 5.23 Do you use any cloud services?
services.
How do you determine which cloud services are required
by your organization and which cloud model is the best
fit (IaaS, PaaS, SaaS, etc.)?
What controls do you have in place to monitor the
performance/effectiveness of your cloud service
provider?
Have you planned for changes to or termination of your
cloud service(s) provider? What are your processes for
this?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Cloud Usage Policy covering:
Criteria for selecting cloud services.
Assessment of business needs and alignment
with cloud models (IaaS, PaaS, SaaS).
Security and compliance considerations.
Evidence:
Cloud Needs Assessment Report detailing:
Specific organizational requirements (e.g.,
data storage, compute resources,
collaboration tools).
Comparison of cloud models (IaaS, PaaS,
SaaS) based on organizational needs.
Justification for the chosen cloud model.
Evidence:
Vendor selection criteria and comparison
reports.
Compliance checklists for providers (e.g.,
adherence to ISO 27001, GDPR, HIPAA, etc.).
Cloud provider contracts or Service Level
Agreements (SLAs) detailing performance
guarantees.
New requirement
Evidence: Phase Control(s) Activity
Business continuity
Performance and Logs
Monitoring IT readiness
and Reports: Plan 5.30 Does your BCP include requirements to ensure the
Metrics such as uptime, latency, and resource confidentiality, integrity and availability of information in
utilization. BC situations?
SLA compliance reports provided by the cloud Have the IT requirements for BC been tested?
service provider.
Have you established RTO/RPOs for your IT in BC
Security monitoring logs (e.g., access logs, situations?
event logs) from cloud services.
Evidence
Alerts or of compliance
incidents related(Client to complete)
to cloud service Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
performance.
(Assessor to complete)
Evidence:
Cloud Risk Assessment Reports identifying:
Evidence: Yes No
Potential
BCP risks (e.g.,
document datacovering:
sections breaches, service
downtime,
Measures to data residency
ensure issues).
data confidentiality during
Controls
BC implemented
situations to mitigate
(e.g., encryption, these risks.
access
Integration with ISMS risk treatment plans.
controls).
Controls to maintain data integrity (e.g.,
checksums, version control).
Strategies to ensure availability (e.g., backups,
redundant systems, failover mechanisms).
Clear roles and responsibilities for maintaining
CIA.
Evidence:
Records of testing activities such as:
Disaster recovery tests (e.g., restoring data
from backups, failover drills).
Tabletop exercises simulating BC situations.
Testing of alternative communication channels
and critical IT infrastructure.
Results of testing, including pass/fail
outcomes and corrective actions taken.
Approval or sign-off of testing results by senior
management or IT teams.
Evidence:
Management review meeting minutes
discussing BC plans.
Approval/sign-off of BCP and DRP documents.
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1
Updates made to recovery plans based on Page 3
New requirement Phase Control(s) Activity
Physical security monitoring Action 7.4 How do you ensure that your premises are continuously
monitored for unauthorised access?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Policy document covering:
Access control procedures (e.g., authorized
personnel only).
Physical barriers (e.g., gates, turnstiles, locked
doors).
Requirements
New requirementfor ID badges, biometric Phase Control(s) Activity
systems, or other identification methods.
Configuration management Action 8.9 Do you have a process for ensuring that systems are
Visitor management protocols (e.g.,
appropriately configured/hardened?
check-in/check-out systems).
How do you ensure that the above process is being
followed?
Is system configuration monitored and reviewed?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Policy document specifying configuration
hardening requirements for various systems
(e.g., servers, workstations, network devices,
applications).
Security baselines for operating systems,
applications, and network devices (e.g., CIS
Benchmarks, NIST standards).
Configuration settings for disabling
unnecessary services, applying security
patches, and restricting access rights.
Evidence:
Configuration review reports or audit logs
showing that configurations are periodically
checked for compliance with security
standards.
Internal audit records confirming that system
configurations adhere to the approved
hardening guidelines.
Reports from security or IT teams reviewing
New requirement Phase Control(s) Activity
configuration management processes and
Information deletion
ensuring compliance. Plan 8.10 Have you identified what information you hold as
Evidence: an organization and established rules governing its
retention and deletion?
Continuous monitoring solution (e.g., SIEM,
network monitoring tools) tracking Action 8.10 How do you ensure that information (when no longer
configuration changes in real time. required,) is deleted from your information systems,
devices or other storage media?
Reports from monitoring tools showing
Evidence offrom
deviations compliance (Client
the approved to complete)
configuration Has the client demonstrated they have Comments if required (Assessor to complete)
settings. met the requirements of this clause?
Alerts triggered when unauthorized changes (Assessor to complete)
or misconfigurations are detected on systems.
Evidence: Yes No
Policy document specifying information
retention periods for various categories of data
(e.g., financial records, customer data,
employee records).
Detailed retention schedules outlining how
long different types of information must be
kept before they can be deleted.
Guidelines for categorizing and labeling
information according to its sensitivity and
retention needs.
Evidence:
Clear process and workflow for managing the
retention and deletion of information (e.g.,
when information should be archived, when it
should be permanently deleted).
Documentation of legal, regulatory, and
business requirements that influence retention
periods (e.g., financial reporting laws, data
protection regulations).
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 4
Procedures outlining how to handle
New requirement Phase Control(s) Activity
Data masking Plan 8.11 Have you identified what sensitive data you hold as an
organization and established rules governing the need to
mask this data?
Plan 8.11 How is access to raw, sensitive data controlled?
Action 8.11 Do you have a process for masking data?
Plan 8.11 What applicable legislation have you considered with
regards to data and data masking?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
Policy document outlining the types of
sensitive data held by the organization (e.g.,
personally identifiable information (PII),
financial data, health information, payment
card information).
Classification labels or metadata on data,
indicating whether it is sensitive and requires
masking.
Records of data classification activities and
decisions, including a list of systems or
databases storing sensitive data.
Evidence:
A formal policy detailing how data masking is
applied, the types of sensitive data that require
masking, and the methods used (e.g.,
tokenization, encryption, redaction).
Step-by-step procedures that specify when
and how sensitive data should be masked in
systems, databases, and reports.
Documentation of any exceptions or specific
rules for handling particular types of sensitive
data.
New requirement
Evidence: Phase Control(s) Activity
Data leakage
Access controlprevention
lists (ACLs), role-based access Action 8.12 Have you identified what sensitive information you store,
controls (RBAC), or permission matrices process and/or transmit as an organization?
showing how access to sensitive data is Have you identified the systems, apps, tools that are
granted based on user roles and needs. used to store, process and/or transmit this sensitive
Logs and reports showing that only authorized information?
personnel have access to raw, unmasked Have you assessed your data leakage risks?
sensitive data.
What processes/tools do you have in place to prevent
Integration with authentication systems (e.g.,
data leakage?
multi-factor authentication, single sign-on) for
Evidence
sensitive of compliance
data access. (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
Evidence: met the requirements of this clause?
(Assessor to complete)
Screenshots or configuration files from data
masking tools (e.g., data tokenization, data
Evidence: Yes No
obfuscation software,document
A policy or guideline encryptionidentifying
tools) the
showing implementation and usage.
categories of sensitive information, such as
Reports from
Personally these tools
Identifiable demonstrating
Information (PII), that
sensitive data is
financial data, masked
health data,inintellectual
production
environments,
property, etc. as well as in non-production
environments
Detailed records(e.g., testing
of the or development).
classification of
Records
sensitive of periodic
data acrossvalidation to ensure theor
various departments
data masking
functions withinprocess is functioning
the organization correctly
(e.g., HR,
and securely.
finance, legal).
Evidence.
A register orWeinventory
secure datathat based on India IT
tracks sensitive
Act rules guidelines
data types and where they are stored or
processed.
Evidence:
An updated inventory of all systems, apps,
and tools (e.g., databases, cloud services,
email platforms, CRM systems) used in the
organization to handle sensitive data.
A mapping of sensitive data flows between
systems and external entities, showing where
data is stored, processed, and transmitted.
Network diagrams or data flow diagrams
illustrating the systems involved in the
handling of sensitive information.
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 5
Evidence:
New requirement Phase Control(s) Activity
Monitoring activities Action 8.16 Are your networks monitored for anomalous behaviour?
Plan 8.16 If/when detected, how is anomalous behaviour evaluated
and reported?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
A documented network monitoring policy that
includes the types of anomalies to be
detected, monitoring tools, and how
continuous monitoring is conducted.
A clear definition of "anomalous behavior,"
such as unusual network traffic patterns,
unauthorized access attempts, or abnormal
system behavior.
Policies outlining monitoring of both internal
and external traffic to detect potential threats
or breaches.
Evidence:
A detailed incident response procedure that
outlines the steps for evaluating anomalous
behavior once it is detected, including
investigation, containment, and remediation
New requirement Phase Control(s) Activity
processes.
Web filtering
Records of past incidents where anomalous Action 8.23 Is access to external websites managed to reduce
behavior was detected, evaluated, and exposure to malicious content?
responded to (e.g., reports from recent Are employees aware of the information security
security incidents or network breaches). risks that unmanaged web browsing poses to the
A clear process for escalating significant organization?
Evidence
anomalies oftocompliance
appropriate(Client
teams,toincluding
complete) Has the client demonstrated they have Comments if required (Assessor to complete)
security, IT, and management. met the requirements of this clause?
(Assessor to complete)
Evidence: Yes No
A documented policy specifying the types of
websites that employees are allowed to
access, restrictions on high-risk websites, and
procedures for handling requests to access
restricted sites.
A list of categories (e.g., entertainment, social
media, adult content) and associated risks that
are blocked or monitored.
Guidelines for managing access to
cloud-based services, social media, and other
web applications to minimize exposure to
malicious content.
Procedures for reviewing and updating the list
of blocked or restricted websites based on
New requirement
current security trends. Phase Control(s) Activity
Secure coding Plan 8.28 What secure coding principles and practices have you
Evidence: implemented in your organization?
Training records or attendance logs from
How do you ascertain competence of your developers?
mandatory cybersecurity awareness training
Evidence
sessions,ofincluding
compliance topics(Client
relatedtoto
complete)
the Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
dangers of visiting untrusted or unmanaged
(Assessor to complete)
websites (e.g., malware, phishing, social
engineering).
Evidence: Yes No
Training
A securematerials or presentation
coding policy slides that
or coding standards
discuss safe
document web
that browsing
defines practices,and
the principles the risks
of downloading
practices files
to follow fromOWASP
(e.g., untrustedTopsources,
10,
and the Software
Secure importance of followingLifecycle,
Development web access
control policies.
ISO/IEC 27034).
Documentation
Examples of regular
of specific secure awareness
coding practices
campaigns (e.g.,
included, such asemails, posters, internal
input validation, output
webinars) informing
encoding, proper error employees
handling,ofsecure
the risks of
malicious content
authentication on the web.
mechanisms, encryption of
Surveys
sensitiveor assessments
data, and protectionthat indicate
against common
employees understand
vulnerabilities (e.g., SQLthe importance
injection, of
cross-site
secure web browsing and the potential impact
scripting).
on the organization's security posture.
Evidence:
A developer competency framework that
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 6
defines the required skills and experience in
Part 2: ISO 27001:2022 Requirements
Tip: Ensure that you can demonstrate that each requirement of ISO 27001:2022 has been addressed within the ISMS.
Evidence: Yes No
Risk assessment reports that outline the
internal and external factors identified as
influencing the ISMS, such as organizational
culture, market conditions, regulatory
requirements, or technological changes.
Risk
ISO register or risk management reports
27001:2022 ISO 27001:2022 cross reference and the significant
listing the key issues impacting the changes from the 2013 version
organizations information security
4.3 Determining the scope of the quality management system Have external and internal issues and interested parties been
landscape, including environmental, legal, considered? Have interfaces and dependencies been identified and
technological, and socio-political factors. considered?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
Evidence:
met the requirements of this clause?
Minutes or reports from management review (Assessor to complete)
meetings that include discussions on both
Evidence
internal and external issues impacting Yes No
Comprehensive risk and context analysis that
information security.
identifies
Evidence internal andtaken
of actions external
as aissues affecting
result of those
the ISMS.
reviews to address or mitigate the identified
issues.
Documentation listing all identified interested
parties
ISO and their needs and expectations.
27001:2022 ISO 27001:2022 cross reference and the significant
Identification and mapping of interfaces and changes from the 2013 version
dependencies between internal and external
5.1 Leadership and commitment Can top management demonstrate their degree of leadership and
components. commitment to the ISMS.
Evidence
Analysis of compliance
of how (Client
internal and to complete)
external issues Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
and dependencies affect stakeholders.
(Assessor to complete)
Ongoing review and monitoring of
dependenciesISMS
Documented and issues.
policy signed by top Yes No
management outlining their commitment.
Risk
Activetreatment
involvementplansinthat address
the risk issues and
management
dependencies
process, impacting
including the ISMS.
endorsement of risk
treatment plans.
Establishment of measurable information
security
ISO objectives, regularly reviewed by top
27001:2022 ISO 27001:2022 cross reference and the significant
management. changes from the 2013 version
Provision of adequate resources for the
5.2 Policy Is an information security policy available and appropriate to the
implementation and maintenance of the ISMS. purpose and context of the organization and does it support the
Regular management reviews of the ISMS, strategic direction of the company?
including assessment of its performance and
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
effectiveness.
met the requirements of this clause?
Communication from top management (Assessor to complete)
highlighting the importance of information
A documented
security and accessible information
to all employees. Yes No
security
Continuouspolicy endorsed by
improvement top management.
efforts led by top
The policy is aligned
management to adaptwith
thethe
ISMSorganizations
to emerging
purpose,
threats. context, and strategic direction.
Strategic
Support for alignment of the policyactivities,
audits, compliance with the and
companys business
certifications goals,
to maintain theincluding growthof
effectiveness
and compliance.
the ISMS.
Effective communication of the policy to all
employees, contractors, and stakeholders.
Regular reviews and updates of the policy to
ensure its relevance and effectiveness.
Enforcement mechanisms and accountability
for adherence to the policy
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 7
ISO 27001:2022 ISO 27001:2022 cross reference and the significant
changes from the 2013 version
6.1 Actions to address risks and opportunities 6.1.2 Do you have a risk assessment process? Have you performed
risk assessments of your information and information storage/
processing assets?
6.1.3 Have you produced a Statement of Applicability (SOA) and is it
aligned to the new control groups and numbering system?
Is the SOA version controlled and dated?
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
NQA/ISO27001/GAP_ANALYSIS_TOOL/FEB23/V1 Page 8
ISO 27001:2022 ISO 27001:2022 cross reference and the significant
changes from the 2013 version
9.1 Monitoring, measurement, analysis and evaluation Organizations are now required to ensure that monitoring and
measuring produces valid, comparable and reproductive results.
You must also evaluate information security performance and the
effectiveness of the ISMS.
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this clause?
(Assessor to complete)
Evidence. Yes No
Documented policies and procedures for
handling, storing, and transmitting
authentication information securely.
Encryption and secure storage practices for
authentication information.
Access
ISO controls governing who can access
27001:2022 ISO 27001:2022 cross reference and the significant
authentication credentials and systems. changes from the 2013 version
Training programs to educate personnel on
5.18 Access rights Merging of 9.2.2, 9.2.5, 9.2.6 – No significant change.
secure handling of authentication information.
Evidence of compliance
Multi-factor (Client
authentication (MFA)to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
implementation for critical systems and met the requirements of this control?
applications. (Assessor to complete)
Audit
No logs and
changes incident response procedures
required Yes No
for authentication-related security events.
Regular reviews of authentication information
handling practices to ensure they are
up-to-date and effective.
6. People controls
ISO 27001:2022 ISO 27001:2022 cross reference and the significant
changes from the 2013 version
6.4 Disciplinary process 7.2.3 – Emphasis on information security violation and not breach.
Evidence of compliance (Client to complete) Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this control?
(Assessor to complete)
7. Physical controls
the process and understand how to report
events.
Incident management system records,
ISO 27001:2022
including tracking of reported events. ISO 27001:2022 cross reference and the significant
Procedures for handling and investigating changes from the 2013 version
events with clear escalation processes.
7.2 Physical entry Merging of 11.1.2 and 11.1.6 – No significant change.
Monitoring and auditing of the event reporting
Evidence
process toofensure
compliance
timely (Client to complete)
handling. Has the client demonstrated they have Comments if required (Assessor to complete)
met the requirements of this control?
Continuous improvement activities based on
(Assessor to complete)
lessons learned from reported events.
Compliance
No changes evidence
required that shows adherence Yes No
to legal and regulatory requirements for event
reporting.