We wrote here https://www.sorinmustaca.com/how-to-nis2-eu-directive/ that the 3rd step in implementing the requirements of the directive is to establish a cybersecurity framework.
If you haven’t read what a cybersecurity framework means, then you should read article: https://www.sorinmustaca.com/demystifying-cybersecurity-terms-policy-standard-procedure-controls-framework/ .
An ISMS is typically based on the ISO 27001 standard, which provides a framework for establishing, implementing, maintaining, and continually improving information security within an organization.
Establishing a cybersecurity framework is usually achieved together with, or while implementing an Information Security Management System (ISMS) based on a standard like ISO 27001. So, before going to the NIS2 Step 3, I must explain why is it important to have a “good” ISMS.
This article will guide you through the steps to create a solid foundation for the ISMS which uses a cybersecurity framework.
Here are the steps you must follow to implement your ISMS:
Get Top Management Support
Before you start, synchronize with the top management in order to define company’s goals in this regard. Usually it should be clear, since the company strives to receive a certification like ISO 27001, ISO 16949, TISAX, CSMS, etc..
Then secure the commitment and support of senior management by helping them understand the necessary resources and efforts.
In all standards that require an ISMS it is imperative to have the commitment of the management because their feedback and support are required in several places along the way.
Define the scope of your ISMS: determine which assets, processes, and locations will be covered by the ISMS.
This will help in setting boundaries for your security efforts. Some certifications require an assessment per location and scope, so this needs to be developed properly and in accordance with company’s goals.
Create policies that help identify and assess information security risks.
How to identifying assets: List all the information assets your organization handles, such as data, hardware, software, and personnel, intellectual property.
How to identify threats and vulnerabilities: Determine potential risks and vulnerabilities that could impact your assets.
How to assess risks: Analyze the likelihood and potential impact of these risks.
How to calculate risk levels: Prioritize risks based on their severity.
Develop a policy for risk treatment plan:
How to implement controls: Select and implement security controls and measures to mitigate identified risks.
Document policies and procedures that enforce the creation of security controls.
Allocate responsibilities: Assign roles and responsibilities for managing and monitoring security measures.
Set risk acceptance criteria: Determine which risks can be accepted, mitigated, or transferred.
Establish the ISMS Framework
Establish the ISMS framework based on ISO 27001:
Define information security objectives.
Develop an information security policy.
Create a risk assessment methodology.
Define criteria for risk acceptance.
Develop and implement security controls.
Execute the ISMS based on the established framework:
Train employees: Provide information security training to all staff members.
Implement security controls: Put in place the technical, administrative, and physical controls identified in your risk treatment plan.
Monitor and review: Continuously monitor the effectiveness of your controls and review your risk assessment.
Measurement and Evaluation
Regularly measure and evaluate the performance of your ISMS to ensure that it remains effective and aligned with your objectives.
Conduct internal audits.
Perform security testing (e.g., penetration testing, vulnerability scanning).
Analyze security incident data.
Conduct regular management reviews to assess the ISMS’s performance and effectiveness.
Ensure that the ISMS is aligned with the organization’s strategic goals.
Make improvements based on review findings.
Use the results of audits, reviews, and incidents to continually improve the ISMS.
Update policies and procedures as needed.
Enhance security controls based on new threats and vulnerabilities.
Maintain employee awareness and training.
If your organization desires ISO 27001 or any other certification, engage an accredited certification body to perform an external audit and certification assessment.
Be careful because several certification require a pre-certification or pre-assessment performed either with in-house auditors (internal) or external auditors.
Maintain detailed documentation of all ISMS activities, including policies, procedures, risk assessments, and audit reports.
Maintain a log of all changes in time, because this demonstrates continual improvement and usage.
Training and Awareness
Continuously educate and raise awareness among employees regarding information security policies and best practices.
Incident Response and Recovery
Develop an incident response plan to address security incidents promptly and effectively.
Remember, and make sure that your management remembers as well, that implementing and maintaining an ISMS is an ongoing process. Even if certifications are renewed only after 3 years (usually) it is important that in these 3 years the ISMS is lived.
Regularly update your risk assessments and adapt your security controls to evolving threats and business needs. Continuous improvement is key to the success of your ISMS.
The post How to implement an Information Security Management System (ISMS) first appeared on Sorin Mustaca on Cybersecurity.