Annex A of ISO 27001 is probably the most mentioned annex of any management standard. Why is there so much talk about it? Why is it sometimes controversial?
If you have read the Annex A, you have seen that 133 security controls are listed there. If that is the case, what is the main part of the standard used for?
Annex A contains the following clauses (sometimes called ISO 27001 Annex A domains):
- A.5 Security policy
- A.6 Organization of information security
- A.7 Asset management
- A.8 Human resources security
- A.9 Physical and environmental security
- A.10 Communications and operations management
- A.11 Access control
- A.12 Information systems acquisition, development and maintenance
- A.13 Information security incident management
- A.14 Business continuity management
- A.15 Compliance
As already mentioned, Annex A contains 133 controls which, as can be seen from the names of the clauses, are not focused solely on IT – they also cover physical security, legal protection, human resources management, organizational issues, etc.
Therefore, you could consider Annex A as a form of a catalogue of security measures to be used during your treatment process – once you identify unacceptable risks in risk assessment, Annex A will help you choose the right control(s) to decrease those risks. And ensure you don’t forget any important control.
Annex A is where ISO 27001 and ISO 27002 come together – the controls in ISO 27002 are named the same as in Annex A of ISO 27001, but the difference is in the level of detail – ISO 27001 gives only a short definition of a control, while ISO 27002 gives detailed guidelines on how to implement the control.
If by now you are thinking that Annex A is a perfect implementation tool for your information security project, don’t be too optimistic – it also has some things that don’t make sense. For instance, some controls define almost the same issues, sometimes causing confusion – like A.9.2.6 (Secure disposal or re-use of equipment) and A.10.7.2 (Disposal of media). On the other hand some issues, like relationships with third parties, are scattered around various clauses of Annex A – you can find it in clause A.6.2 (External parties), A.8 (Human resources security) and A.10.2 (Third party service delivery management), and control A.12.5.5 (Outsourced software development). This sometimes makes Annex A difficult to use as an implementation tool.
But those are not the only ambiguities – in some of the controls, Annex A mentions policies and procedures, however it does not require those to be documented. It might seem funny, but only where the word “documented” appears, does the standard require written policies/procedures. When you analyze the whole Annex A, it mentions the word “documented” in only 6 controls (A.5.1.1, A.7.1.3, A.8.1.1, A.10.1.1, A.11.1.1, A.15.1.1) – that means you can implement all the other controls without documenting them.
However, you shouldn’t abuse this flexibility of Annex A – the larger the organization, the more documents you should produce in order to ensure that everyone is aware of (and complies with) your security procedures. On the other hand, you should be careful not to overdo the documentation – if it is excessive, no one is going to observe it.
Relationship with the main part of the ISO 27001
The main part of the standard, or more precisely the mandatory clauses 4 to 8 contain the management part of the standard – they prescribe the PDCA cycle (Plan-Do-Check-Act phases), including risk assessment and treatment, documentation control, records control, provision of resources, internal audit, management review, corrective and preventive actions, etc.
As said earlier, the risk assessment & treatment process is the main connection between clauses 4 to 8 and the controls from Annex A – it will help you decide whether individual controls from Annex A are necessary for decreasing risks or not.
It means clauses 4 to 8 and Annex A cannot exist one without the other – risk assessment does not make sense if there are no controls to decrease the risks, and the only way to determine the applicability of controls is through risk assessment.
In my opinion, this focus on risks and the flexibility to apply security controls according to what you consider as appropriate are the best things in ISO 27001 – you just have to be careful to take full advantage of them.