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Comparing “Records of Processing Activities” (ROPA) and “Data Protection Impact Assessments” (DPIA) (with Podcast)

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Understanding ROPA and DPIA: Key GDPR Concepts for Tech Companies

Podcast of this article:


 

 

 

Let’s explore two essential components of GDPR compliance: Records of Processing Activities (ROPA) and Data Protection Impact Assessments (DPIA).

ROPA provides a comprehensive overview of your data handling, while DPIA focuses on assessing and mitigating risks for specific, higher-risk activities.

Records of Processing Activities (ROPA): Your Company’s Data Map

Think of ROPA as your company’s data map. It documents every step of the data journey, from collection to deletion.

It’s about what data you collect, including why, how, and with whom you share it.

A well-maintained ROPA is crucial for demonstrating GDPR compliance and building trust with your users.

What ROPA Covers

  • Purposes of Processing: Be specific! Instead of “marketing,” say “personalized email marketing based on user browsing history” or “improving product recommendations based on user purchase data.”
  • Categories of Data Subjects: Identify who the data relates to (e.g., customers, employees, website visitors, app users).
  • Categories of Personal Data: List the types of data you process (e.g., name, email address, IP address, location data, browsing history, biometric data).
  • Recipients of Personal Data: Specify who you share data with (e.g., cloud storage providers, marketing agencies, analytics platforms, law enforcement). Include both internal and external recipients.
  • Transfers to Third Countries: If you transfer data outside the EU, document the safeguards in place (e.g., adequacy decisions, standard contractual clauses).
  • Data Retention Periods: Specify how long you keep different types of data. This should be based on legal requirements and business needs.
  • Technical and Organizational Security Measures: Briefly describe the security measures you have in place to protect the data (e.g., encryption, access controls, data masking).

ROPA Examples for Tech Companies

  • Social Media Platform: A social media platform’s ROPA would detail processing activities related to user profiles, posts, photos, friend connections, messaging, targeted advertising, and data analytics. It would specify data categories (e.g., profile information, IP address, location data, browsing history), purposes (e.g., personalized content delivery, targeted advertising, platform improvement), and recipients (e.g., advertising partners, analytics providers).
  • SaaS Provider: A SaaS provider’s ROPA would document processing related to user account management, data storage, application usage tracking, customer support interactions, and billing. It would include details about data categories (e.g., user credentials, company data, usage logs), purposes (e.g., providing the service, improving performance, customer support), and recipients (e.g., cloud hosting providers, payment processors).
  • Mobile App Developer: A mobile app developer’s ROPA would cover data processing within the app, such as collecting user location data for personalized recommendations, accessing contacts for social features, or tracking in-app purchases. It would detail the data categories (e.g., location, contacts, purchase history), purposes (e.g., personalized recommendations, social features, in-app advertising), and recipients (e.g., location services providers, advertising networks).

Data Protection Impact Assessments (DPIA): Proactive Risk Management

A DPIA is a more in-depth analysis triggered by specific processing activities that pose a high risk to individuals.

With the DPIA you’re identifying risks, and also finding ways to mitigate them and demonstrating that you’ve considered data protection all the way.

What DPIA Covers

  • Description of the Processing Operations: Clearly explain the planned processing, including the purposes, data categories, and processing methods.
  • Necessity and Proportionality: Justify why the processing is necessary and proportionate to the intended purpose. Are there less intrusive ways to achieve the same goal?
  • Assessment of Risks to Individuals: Identify potential risks to individuals’ rights and freedoms, such as identity theft, discrimination, loss of control over their data, or reputational damage. Consider the likelihood and severity of these risks.
  • Measures to Address the Risks: Describe the measures you will implement to mitigate the identified risks. This might include technical measures (e.g., encryption, anonymization), organizational measures (e.g., access controls, data minimization policies), and legal measures (e.g., data processing agreements).
  • Consultation with Data Protection Authorities (DPA): In some cases, you may need to consult with your local DPA before carrying out high-risk processing.

DPIA Examples for Tech Companies

  • Facial Recognition Software: A company developing facial recognition software for security purposes would need a DPIA. The DPIA would assess risks related to accuracy, bias, potential for misuse, and impact on individuals’ privacy and freedom of movement. Mitigation measures might include strict access controls, data anonymization techniques, and clear guidelines for use.
  • AI-Powered Recommendation Engine: A company launching a new AI-powered personalized recommendation engine that analyzes large volumes of user data would require a DPIA. The DPIA would analyze the risks of profiling, discrimination, and loss of privacy. Mitigation measures could include data minimization, differential privacy techniques, and user consent mechanisms.
  • Biometric Authentication: A company implementing large-scale biometric authentication for access control would need a DPIA. The DPIA would evaluate the risks of data breaches, identity theft, and potential misuse of biometric data. Mitigation measures could include secure storage of biometric data, multi-factor authentication, and strict access controls.

ROPA and DPIA: Similarities and Differences

ROPA and DPIA are like two sides of the same coin – both essential for responsible data handling under GDPR. They work together to ensure your data processing is transparent, accountable, and respects individuals’ privacy.

Similarities

  • GDPR Compliance:
    • Both ROPA and DPIA are mandated by the GDPR (Articles 30 and 35, respectively).
    • They’re not optional; they’re legal requirements for many organizations.   
  • Focus on Data Protection:
    • At their core, both aim to protect individuals’ rights and freedoms related to their personal data.
    • They promote a privacy-first approach to data processing.
  • Documentation is Key:
    • Both require thorough documentation.
    • ROPA is the documented record of your processing activities, and DPIA results in a documented risk assessment report.
    • Good record-keeping is crucial for demonstrating compliance.   
  • Accountability:
    • Both contribute to demonstrating accountability.
    • By maintaining a ROPA and conducting DPIAs, you show that you’re taking data protection seriously and actively managing risks. 

Differences

  • Scope:
    • ROPA covers all your data processing activities,
    • DPIA focuses on specific, high-risk processing activities.
    • Think of ROPA as the big picture and DPIA as a focused close-up.
  • Purpose:
    • ROPA’s primary purpose is to document and provide transparency about all your data processing.
    • DPIA’s main goal is to assess and mitigate the risks of particular processing activities that are likely to be high-risk.  
  • Requirement:
    • ROPA is a general requirement for most organizations (especially those with over 250 employees or those processing sensitive data).
    • DPIA is only required when processing activities are likely to result in a high risk to individuals’ rights and freedoms. It’s triggered by specific circumstances.
  • Outcome:
    • ROPA produces a comprehensive record of your processing activities.
    • DPIA results in a risk assessment report outlining potential risks and the measures you’ll take to mitigate them.
    • One is a detailed inventory, the other a focused risk analysis.  
  • Timing:
    • ROPA is an ongoing requirement – you need to keep it updated as your processing activities change.
    • DPIA is conducted for specific projects or plans before they are implemented. It is a point-in-time assessment. 

In a nutshell:

  • ROPA is your ongoing data processing inventory, demonstrating your overall approach to data protection.
  • DPIA is a targeted risk assessment for specific, potentially high-risk projects, ensuring you’ve considered and addressed privacy concerns before they become a problem.
  • Both are essential tools in your GDPR compliance toolkit.

The post Comparing “Records of Processing Activities” (ROPA) and “Data Protection Impact Assessments” (DPIA) (with Podcast) first appeared on Sorin Mustaca on Cybersecurity.

Accelerating feature delivery in software development

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My company develops security products for all major operating systems. We work with startups and with big companies, all striving to develop features (functional and non-functional) as fast and as good as possible.

While on the first view this seems like a contradiction, there are actually ways of implementing exactly this.

For security software development teams aiming to deliver features more frequently, streamlined processes and efficient workflows are essential.

You guessed, the keywords are agile methods with the related activities such as automated testing, strategic prioritization, agile delivery, efficient workflows, regular and early feedback.

Below are several approaches that emphasize frequent and reliable delivery.

Define requirements with speed in mind

Clear, concise requirements set a strong foundation for quick delivery. Ensuring each feature has straightforward objectives and well-defined acceptance criteria reduces delays caused by back-and-forth clarifications. For security-focused teams, requirements should include key security considerations without overloading the development process. By clarifying expectations from the start, developers can stay on track, avoiding unnecessary revisions and accelerating overall delivery. This being said, also do not change the direction too often (called Pivoting). If you don’t allow feature to “sit”, the product will never reach maturity.

Setup incremental, agile delivery

Breaking down feature development into small, manageable increments supports faster delivery. Rather than waiting for a full release, an incremental approach allows developers to deliver small updates frequently. This Agile-inspired method brings quick wins, shortens feedback cycles, and lets teams adjust direction as needed based on real-world usage. Incremental delivery ensures that new functionality reaches users sooner, making the product more responsive to changing needs.

Optimize for efficiency

Security doesn’t have to slow down delivery. By embedding secure coding practices into the team’s daily workflows, developers can build security right into each feature rather than adding it at the end. Code reviews focused on security can be streamlined with checklists or automated tools, keeping the process efficient. This “security-first” mindset ensures that features remain secure while minimizing delays, as there’s no need for last-minute security fixes.

Invest in CI/CD

Automated testing is key to quick, reliable feature deployment. Automated tests that cover basic functionality and security requirements provide instant feedback, allowing developers to identify and address issues faster. Implementing continuous integration (CI) tools that automatically trigger these tests during development helps the team validate new features on the go. By automating tests, the team gains more time for development and can release updates with minimal manual intervention.

Integrating DevSecOps practices into the development pipeline enables seamless security without slowing down delivery. Automated security checks within the CI/CD pipeline provide fast, reliable security validations, allowing developers to address issues before deployment. This approach keeps the pipeline moving smoothly, as security checks become an integrated part of the process, rather than an additional step that slows down delivery.

Encourage collaborative and efficient workflow

Encourage open communication between developers, security teams, and testers to streamline workflows. Collaborative sessions for discussing roadblocks or coordinating on shared goals help prevent bottlenecks. An open environment where team members share updates and resolve issues collectively accelerates progress by addressing concerns in real time. By emphasizing collaboration, teams can work faster, catching potential blockers early and adapting quickly to new requirements.

Use regular retrospectives to identify and remove delivery obstacles

Post-release retrospectives focused on delivery efficiency help identify and eliminate roadblocks. By analyzing each release or sprint for delays and other issues, teams can identify specific pain points in the development or deployment process. These retrospective sessions allow the team to adjust practices and improve their ability to deliver quickly, refining the workflow with each iteration.

 

The post Accelerating feature delivery in software development first appeared on Sorin Mustaca on Cybersecurity.

Understanding Defense in Depth in IT Security

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The recent outage caused by Crowdstrike’s faulty update has create a lot of discussions. I wrote a post on LinkedIn where I asked the readers why are IT professionals using Crowdstrike on some systems that shouldn’t be in need of such protection in the first place.

The answers in various groups were mostly related to:

  • protect everything against everyone
  • assume the worse
  • assume that you are compromised.

I do not agree with such a shallow answer. And this raises a question about Defense in Depth.

Defense in Depth

Defense in Depth is a cybersecurity strategy that employs multiple layers of security controls to protect an organization’s assets and information. This approach is based on the premise that no single security measure is foolproof. By implementing several layers of defense, even if one control fails, others are in place to mitigate risks. The concept is inspired by military defense strategies, where a series of defensive positions are used to delay or prevent an attack.

A common misconception about Defense in Depth is that it requires identical security measures across all layers of an IT environment. In reality, this is neither necessary nor practical. Different layers have different requirements based on their specific functions, vulnerabilities, and the types of threats they are exposed to. Applying the same controls universally can lead to inefficiencies, increased costs, and potential performance issues.

In my opinion, this is what happened in many cases during the Crowdstrike outage: admins installed the EDR solution simply on all available devices, without doing an analysis of the threats they are exposed to. This is called threat modeling, and the first step after identifying the assets to protect is to analyze their threat landscape: this is the set of threats they are potentially exposed to. Once the potential threats are identified, then the appropriate security controls can be defined. But, it is important that the right controls are used based on the risk level of the potential threat. The mistake here is that people try to protect against any potential risk, no matter how improbable it might be. So, it is not worth to protect against every potential risk.

But, this operation is, at least at first sight, expensive, time consuming and very few people know how to do it.

So, what happens in most cases is that people consider to be cheaper to buy additional licenses and accept easily a slight reduction in performance due to the tool monitoring everything (“throw” more hardware on it).

And this might be OK, if everything works perfect all the time. Well, it doesn’t !

If this sounds too theoretical, then let’s have a closer look at various layers where applications run.

  • Running at the Web Application Layer: This layer might need strong authentication mechanisms, input validation, and encryption to protect against web-based attacks such as SQL injection or cross-site scripting (XSS).
  • Running at the Network Layer: Here, firewalls, intrusion detection systems (IDS), and virtual private networks (VPNs) are more appropriate to guard against network-based threats like DDoS attacks or unauthorized access.
  • Running at the Endpoint Layer: Devices such as laptops and mobile phones might require antivirus software, device encryption, and endpoint detection and response (EDR) solutions to prevent malware infections and data breaches.

Each layer of security addresses different risks, and the controls should be tailored to the specific threats and the environment.

For instance, a high-value database containing sensitive customer information might warrant multiple layers of encryption, strict access controls, and regular auditing. In contrast, a low-value, non-critical application might only require basic security measures.

Of course, there are applications having parts that run on more than one layer. When this happens, then you must correctly create the threat model and identify the risks at each layer.

For example, if you have a computer which just displays flights schedules, without having an interaction with the exterior other than retrieving data from an internal webservice, you probably do not need a dedicated endpoint security product for it.

Why? Because you will not allow access to the machine other than the service account for patches and running the required software.

If you’re unsure, and the machine runs Windows, than the default Defender is more than enough.

Create a Threat Model for your endpoints

If you don’t know how to create a threat model for an endpoint (and not only Windows, MacOS and Linux are equally affected), here is a list of potential threats and their mitigations.

Important note:
If you apply correctly the principles of Defense in Depth, you will NEVER all all these potential risks applicable to your devices.

Even if you remotely consider that some or all these risks can occur, do not forget that the Risk is proportional to the Probability of occurrence and Impact effect:

  • Probability of occurrence – what are the chances that the risk actually occurs: Very probably, Probably, Sometimes, Unlikely, Never.
  • Impact effect: Catastrophic, Very high, High, Medium, Low.

Potential Risks on an Endpoint

  • Malware Infections

    • Risk: Viruses, Trojans, ransomware, spyware, and other malicious software can compromise the system.
    • Security Controls:
      • Antivirus/anti-malware software
      • Regular system scans and updates
      • Application whitelisting
      • Sandboxing suspicious files
      • Backup with versioning control (good for ransomware attacks)

  • Unpatched Software

    • Risk: Vulnerabilities in outdated software can be exploited by attackers.
    • Security Controls:
      • Automated patch management systems with rollback functionality
      • Regular software updates
      • Vulnerability scanning tools
      • Centralized patch distribution

  • Unauthorized Access

    • Risk: Unauthorized users may gain access to the endpoint, leading to data breaches or system compromise.
    • Security Controls:
      • Strong password policies
      • Multi-factor authentication (MFA)
      • User account control (UAC)
      • Role-based access controls (RBAC)

  • Data Theft

    • Risk: Sensitive data may be copied, transmitted, or stolen from the endpoint.
    • Security Controls:
      • Full disk encryption (e.g., BitLocker)
      • Data loss prevention (DLP) tools
      • USB port control and removable media encryption
      • Secure backup solutions

  • Physical Theft

    • Risk: The endpoint itself may be physically stolen, leading to loss of data and access to the network.
    • Security Controls:
      • Physical security measures (locks, secure storage)
      • Device tracking and remote wipe capabilities
      • Full disk encryption
      • BIOS/UEFI passwords

  • Drive-by Downloads

    • Risk: Malicious websites may automatically download and install malware without user consent.
    • Security Controls:
      • Web filtering and browser security plugins
      • Regular updates to browsers and plugins
      • Application whitelisting
      • Disabling automatic execution of scripts in browsers

  • Network-based Attacks

    • Risk: Attackers may exploit vulnerabilities in the network to compromise the endpoint.
    • Security Controls:
      • Personal firewall
      • Network segmentation
      • Secure VPN connections
      • Intrusion detection and prevention systems (IDPS)

  • Misconfigured Security Settings

    • Risk: Insecure configurations can leave the endpoint vulnerable to attacks.
    • Security Controls:
      • Regular security audits and compliance checks
      • Hardening guides and best practices (e.g., CIS benchmarks)
      • Group policies for centralized management
      • Security baselines and templates

Potential Human Risks

Phishing Attacks

  • Risk: Users may be tricked into divulging sensitive information or downloading malicious software through deceptive emails or websites.
  • Security Controls:
    • Email filtering with anti-phishing capabilities
    • User awareness training
    • Web filtering and reputation services
    • Multi-factor authentication (MFA)

Insider Threats

  • Risk: Malicious or negligent insiders may intentionally or unintentionally cause harm.
  • Security Controls:
    • User activity monitoring and logging
    • Least privilege principle
    • Endpoint detection and response (EDR)
    • Insider threat detection tools

Instead of conclusion: Balancing Security and Usability

The most critical aspect of Defense in Depth is balancing security and usability.

Over-securing can lead to decreased productivity, increased costs, and user dissatisfaction.

For instance, implementing multi-factor authentication (MFA) at every step might significantly slow down legitimate users, leading to frustration and potential workarounds that can undermine security.

A well-designed Defense in Depth strategy finds the right balance by applying strict controls where necessary and lighter measures where the risk is lower.

The goal is to create a robust security posture that protects against a wide range of threats without overburdening the system or its users.

 

The post Understanding Defense in Depth in IT Security first appeared on Sorin Mustaca on Cybersecurity.

ISO 27001:2022 and TISAX: overlaps and differences

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Introduction

ISO 27001:2022 and TISAX VDA ISA 6.0 are two prominent standards in the realm of information security management, particularly within the automotive industry. While ISO 27001 provides a global framework for establishing, implementing, maintaining, and continually improving an information security management system (ISMS), TISAX (Trusted Information Security Assessment Exchange), based on the VDA ISA (Information Security Assessment) framework, is tailored to meet the specific needs of the automotive sector.

This article delves into the nuances of these two standards, highlighting their overlaps, the ways in which TISAX leverages ISO 27001, and the distinct features that set TISAX apart.

Overview of ISO 27001:2022

ISO 27001:2022 is the latest revision of the internationally recognized standard for information security management. It provides a comprehensive approach to managing sensitive company information so that it remains secure. This involves a risk management process, which includes people, processes, and IT systems by applying a risk management process.

Key Features of ISO 27001:2022

  • Risk-Based Approach: Emphasizes the identification and management of risks through a continuous improvement process.
  • Annex A Controls: Contains 93 controls categorized under four themes: Organizational, People, Physical, and Technological.
  • PDCA Cycle: The Plan-Do-Check-Act cycle is integral for continuous improvement.
  • Context of the Organization: Requires understanding of internal and external factors impacting information security.
  • Leadership Commitment: Highlights the importance of top management’s involvement in the ISMS.

Overview of TISAX VDA ISA 6.0

TISAX, a standard specific to the automotive industry, is based on the VDA ISA (Verband der Automobilindustrie Information Security Assessment) catalog. TISAX ensures that automotive manufacturers and suppliers meet strict information security requirements to protect sensitive information.

Key Features of TISAX VDA ISA 6.0

  • Sector-Specific: Tailored specifically for the automotive industry.
  • VDA ISA Catalog: Based on the VDA ISA framework, which is a detailed checklist of requirements and controls. It is split in several areas of interest:
    • Information security – containing everything that belongs to an ISMS
      • IS Policies and Organization
      • Information Security Policies
      • Organization of Information Security
      • Asset Management
      • IS Risk Management
      • Assessments
      • Incident and Crisis Management
      • Human Resources
      • Physical Security
      • Identity and Access Management
      • Identity Management
      • Access Management
      • IT Security / Cyber Security
      • Cryptography
      • Operations Security
      • System acquisitions, requirement management and development
      • Supplier Relationships
      • Compliance
    • Prototype Protection – focused on physical and cyber protection of prototypes
    • Data Protection – focused on policies for protecting privacy and secrets
  • Assessment Levels: Comprises different levels of assessment depending on the type of information and its criticality.
  • Labeling System: Provides a TISAX label indicating compliance, which can be shared with partners within the automotive ecosystem.
  • Focus on KPIs: VDA ISA provides a large set of examples on how to measure certain controls effectively.

Overlaps between ISO 27001:2022 and TISAX VDA ISA 6.0

While TISAX and ISO 27001 serve different purposes, they share several common elements. TISAX leverages the fundamental principles of ISO 27001, creating a robust framework that is both comprehensive and specific to the automotive sector.

In the VDA ISA 6.x (and previous) there are the columns “Reference to other standards” (column P) and “Reference to implementation guidance” (column Q) which point to known standards. Of course, there is no coincidence that the most reference standard is the ISO 27001 in both versions 2022 and 2013.

In the guidance we usually see reference to the Annex A of the ISO 27001 standard (both versions).

 

In the column W there is “Further information” containing explanations of what can be described by the respective control.

Risk Management

Both ISO 27001 and TISAX emphasize a risk-based approach to information security. ISO 27001 mandates a formal risk assessment process, while TISAX incorporates this through the VDA ISA requirements, ensuring that organizations identify and manage risks relevant to the automotive industry.

Control Objectives and Controls

ISO 27001:2022 and TISAX VDA ISA 6.0 share a common structure in terms of control objectives and specific controls. Many of the controls listed in Annex A of ISO 27001 are reflected in the VDA ISA catalog, ensuring a comprehensive approach to securing information.

While this is a common trait shared by the standards, the TISAX is making use of other standards than ISO 27001: NIST, BSI other ISO standards.

Continuous Improvement

Both standards advocate for continuous improvement. ISO 27001’s PDCA cycle and TISAX’s periodic reassessment and updating of security measures ensure that organizations continually enhance their security posture in response to evolving threats.

TISAX VDA ISA has a sheet called “Maturity Levels” containing descriptions of the Maturity Levels 0 to 5.

Documentation and Record-Keeping

ISO 27001 requires detailed documentation of the ISMS, including risk assessments, policies, and procedures. TISAX also mandates thorough documentation as part of its assessment criteria, ensuring that organizations maintain a clear record of their security practices.

Third-Party Management/Suppliers Relationships

Third-party risk management is a critical component in both standards. ISO 27001 includes controls for managing supplier relationships and ensuring their compliance with information security requirements. Similarly, TISAX places a strong emphasis on securing information exchanged with suppliers and partners, crucial for maintaining the integrity of the automotive supply chain.

Differences between ISO 27001:2022 and TISAX VDA ISA 6.0

Despite their overlaps, ISO 27001 and TISAX have several distinctions, reflecting their different scopes and target audiences.

Industry Focus

ISO 27001 is a generic standard applicable to any organization, regardless of its sector. TISAX, however, is designed specifically for the automotive industry, addressing unique challenges such as the secure exchange of data between manufacturers and suppliers.

Assessment Process

ISO 27001 involves a formal certification process conducted by accredited bodies, leading to ISO 27001 certification. TISAX, on the other hand, employs a mutual assessment model where organizations are assessed by ENX approved audit providers, and successful assessments result in a TISAX label. This label can then be shared with other automotive industry stakeholders, facilitating trust and compliance.

Control Specificity

While ISO 27001 provides a broad framework of controls applicable to various industries, TISAX’s controls are highly specific to the automotive sector. The VDA ISA catalog includes detailed requirements for protecting manufacturing data, ensuring compliance with industry-specific regulations, and safeguarding automotive intellectual property.

Levels of Assessment

TISAX introduces different levels of assessment (Basic(Must and Should), High, and Very High) depending on the sensitivity and criticality of the information being protected. ISO 27001 does not have a tiered assessment system but rather a uniform certification standard.

Focus Areas

TISAX places significant emphasis on physical security, secure development of automotive products, and compliance with industry-specific legal requirements. ISO 27001, while comprehensive, does not delve into sector-specific issues with the same level of detail.

Commercial vs Open standards

ISO 27001 is an open international standard governed by the Internation Standards Organisation (ISO). The TISAX trademark is owned by the organization ENX, formed by many OEMs in automotive sector.

 

Implementation of TISAX Using ISO 27001

TISAX leverages ISO 27001’s framework to build a robust and industry-specific information security system. Many organizations begin with ISO 27001 certification and then adapt their ISMS to meet the additional requirements of TISAX.

Integration of Standards

  1. Foundation in ISO 27001: Organizations often establish a basic ISMS in accordance with ISO 27001. This includes conducting risk assessments, implementing controls, and ensuring continuous improvement.
  2. Customization to TISAX Requirements: Once the foundational ISMS is in place, organizations tailor it to meet TISAX requirements, which may involve additional controls specific to automotive data security and third-party management.
  3. Assessment and Labeling: Organizations undergo a TISAX assessment conducted by an approved audit provider. Successful completion results in the issuance of a TISAX label, demonstrating compliance with industry-specific security requirements.

Benefits of Integration

Integrating ISO 27001 with TISAX offers several benefits:

  • Streamlined Compliance: Simplifies the process of meeting both generic and sector-specific security requirements.
  • Enhanced Trust: The TISAX label, backed by ISO 27001’s rigorous framework, enhances trust among automotive industry partners.
  • Cost Efficiency: Leveraging ISO 27001 as a foundation reduces duplication of effort and resources in implementing security measures.

Conclusion

ISO 27001:2022 and TISAX VDA ISA 6.0 represent critical standards for information security, particularly within the automotive sector. While they share common principles such as risk management and continuous improvement, TISAX’s industry-specific focus and detailed requirements for automotive set it apart. By leveraging the robust framework of ISO 27001, organizations can start to effectively implement TISAX, ensuring comprehensive protection of sensitive automotive data and fostering trust within the industry.

Understanding the connections between these standards and their unique requirements is very important for organizations aiming to achieve a high level of information security and compliance.

The post ISO 27001:2022 and TISAX: overlaps and differences first appeared on Sorin Mustaca on Cybersecurity.

Introduction to CISA’s Secure by Design Initiative

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What is Secure by Design?

Secure by Design products are those where the security of the customers is a core business requirement, not just a technical feature. Secure by Design principles should be implemented during the design phase of a product’s development lifecycle to dramatically reduce the number of exploitable flaws before they are introduced to the market for broad use or consumption. Products should be secure to use out of the box, with secure configurations enabled by default and security features such as multi-factor authentication (MFA), logging, and single sign on (SSO) available at no additional cost. (Source)

Secure by Design is an initiative by the Cybersecurity and Infrastructure Security Agency (CISA) aimed at integrating cybersecurity practices into the design and development phases of technology products and systems. The goal is to ensure that security is considered a fundamental element from the outset, rather than an afterthought. This approach helps in reducing vulnerabilities and enhancing the resilience of systems against evolving cyber threats.

Sounds familiar?

Yes, because we know for the past 20 years or more the Microsoft initiative:   Secure by design – Secure by default – Secure operations

 

 

 

Who Should Be Interested?

This initiative is crucial for software developers, system designers, engineers, and manufacturers involved in creating and deploying digital solutions. It is also vital for policy makers and business leaders who oversee the management and governance of cybersecurity risks in their organizations.

Why Is It Important?

Incorporating cybersecurity measures early in the design process can significantly mitigate risks, reduce costs associated with addressing security flaws after deployment, and improve consumer trust. Secure by Design supports not only the protection of individual products but also the overall security posture of national infrastructure and business ecosystems.

Focus of the Initiative

The primary focus of the Secure by Design initiative is to create a systematic, standardized approach to cybersecurity, ensuring that every phase of technology development includes security as a core component. This involves collaborative efforts among stakeholders to adopt best practices that promote security from the initial stages of product and system development.

Topics Covered by the Initiative

Development and Implementation of Security Practices

  • Guidelines for integrating security into software development life cycles (SDLC).
  • Establishment of security benchmarks and standards for new technologies.

Stakeholder Collaboration

  • Engagement with private sector, academia, and international bodies to harmonize security standards.
  • Public-private partnerships to advance security innovations and solutions.

Regulatory Compliance and Risk Management

  • Frameworks for compliance with emerging laws and standards in cybersecurity.
  • Strategies for risk assessment and management integrated into the design process.

Implementation and Auditing

How to Implement

  • Create a Secure Software Development Lifecycle with security protocols and checklists tailored to each stage of the design and development processes.
  • Incorporate automated security testing tools to assess vulnerabilities during the development phase.
  • Continuous monitoring and updating of security measures as part of ongoing maintenance.

Auditing

  • Regular security audits conducted by internal or third-party auditors to ensure adherence to established standards.
  • Use of automated auditing tools to provide ongoing assessments of security posture.

Responsibility and Governance

Who Is Responsible?

  • Chief Information Security Officers (CISOs) and IT managers are primarily responsible for overseeing the implementation of Secure by Design principles.
  • Developers, engineers, and product managers are accountable for incorporating these principles into their workflows and outputs.

Governance

  • Establishment of a governance structure to enforce security standards and practices.
  • Regular reviews and updates to security policies to align with technological advancements and threat landscapes.

Conclusion and further steps

CISA’s Secure by Design initiative represents a proactive shift in cybersecurity strategy, emphasizing the importance of integrating security at the foundational level of technology development. By fostering a collaborative environment among all stakeholders, it aims to standardize and strengthen cybersecurity practices across industries, thereby enhancing the security and resilience of digital infrastructures and systems.

 

CISA’s Secure by Design Alert Series

highlights the prevalence of widely known and documented vulnerabilities, with available and effective mitigations, that have not been eliminated. Alerts are released in response to threat actor activity, but further demonstrate how secure by design software development can help reasonably protect against malicious cyber actors successfully exploiting predictable and well-known vulnerabilities.

Check here their page for Alerts: https://www.cisa.gov/securebydesign/alerts

Secure by Design Blogs

Learn what’s top of mind at CISA and our efforts to help make technology products secure by design.

https://www.cisa.gov/securebydesign/blogs

The post Introduction to CISA’s Secure by Design Initiative first appeared on Sorin Mustaca on Cybersecurity.

Implementing ISO 27001:2022 Annex A.18 – Compliance

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We started the ISO 27001:2022 series with the promise of explaining how the 14 categories of controls can be implemented.

Today we end the series with ISO 27001:2022 Annex A.18, “Compliance”, which addresses the importance of ensuring that organizations comply with relevant laws, regulations, contractual agreements, and other requirements related to information security. This annex focuses on ensuring that the organization identifies and adheres to all applicable legal, statutory, regulatory, and contractual requirements regarding information security and the requirements of the ISMS itself.

Understanding the Importance of Compliance

Annex A.18 is divided into several controls designed to help organizations manage and demonstrate compliance with various information security requirements.

These controls aim to prevent breaches of legal, statutory, regulatory, or contractual obligations related to information security and the security requirements of the organization.

Compliance with legal, regulatory, and contractual requirements is essential for organizations to maintain the confidentiality, integrity, and availability of information assets and mitigate legal and regulatory risks.

Annex A.18 emphasizes several key aspects:

  • Legal and Regulatory Requirements: Identifying and understanding applicable laws, regulations, and industry standards related to information security.
  • Contractual Obligations: Ensuring compliance with contractual agreements, service level agreements (SLAs), and data protection agreements with customers, partners, and suppliers.
  • Risk Management: Assessing and mitigating legal and regulatory risks associated with non-compliance, including financial penalties, legal liabilities, and damage to reputation.

Key Controls in Annex A.18:

  • A.18.1.1 Identification of Applicable Legislation and Contractual Requirements: Identify all relevant requirements that the organization must comply with.
  • A.18.1.2 Intellectual Property Rights (IPR): Ensure protection of IPR, covering software, information content, and patents.
  • A.18.1.3 Protection of Records: Securely manage records in accordance with legal, regulatory, and contractual requirements.
  • A.18.1.4 Privacy and Protection of Personally Identifiable Information: Ensure the protection of personal information as per privacy laws and other requirements.
  • A.18.1.5 Regulation of Cryptographic Controls: Use cryptographic controls as required by legislation, regulations, and agreements.

Practical Implementation of Annex A.18

Legal and Regulatory Compliance Assessment

Practical Examples

  1. Regulatory Mapping: Identify and map relevant legal and regulatory requirements, such as data protection laws (e.g., GDPR, CCPA), industry standards (e.g., PCI DSS, HIPAA), and sector-specific regulations (e.g., SOX for financial services).
  2. Compliance Assessment: Conduct compliance assessments to evaluate the organization’s adherence to legal and regulatory requirements, including data protection principles, security controls, and breach notification obligations.

Contractual Compliance Management

Practical Examples

  1. Contract Review: Review contractual agreements, SLAs, and data processing agreements to identify information security requirements, confidentiality obligations, data protection clauses, and compliance obligations.
  2. Compliance Monitoring: Monitor compliance with contractual agreements by tracking performance metrics, service levels, and adherence to contractual terms and conditions.

Risk Management and Compliance Monitoring

Practical Examples

  1. Risk Assessment: Assess legal and regulatory risks associated with non-compliance, including financial penalties, legal liabilities, and reputational damage, and implement measures to mitigate these risks.
  2. Compliance Monitoring: Establish processes for ongoing compliance monitoring, including periodic reviews, audits, and assessments to ensure adherence to legal, regulatory, and contractual requirements.

We know Compliance is hard, so here are some more examples:

More examples

  1. Compliance Framework Development
    • Example: A multinational corporation needs to comply with the GDPR for its operations in Europe and the CCPA for those in California.
    • Implementation: Establish a compliance framework that identifies all applicable legal and regulatory requirements for each region of operation. Maintain a database of these requirements and update it as laws evolve.
  2. Training and Awareness
    • Example: An organization handling sensitive patient data under HIPAA must ensure that all employees are aware of the requirements.
    • Implementation: Develop ongoing training programs and workshops to educate employees about their responsibilities under relevant laws and how these impact their day-to-day operations.
  3. Auditing and Monitoring
    • Example: A financial services firm regularly audits its data handling practices to ensure compliance with the Sarbanes-Oxley Act.
    • Implementation: Implement a schedule for regular audits, both internal and external, to assess compliance with legal and contractual obligations. Use automated tools to monitor compliance continuously.
  4. Handling Intellectual Property
    • Example: A software development company uses proprietary code that needs to be protected under copyright laws.
    • Implementation: Implement IPR controls, including secure storage, access controls, and regular audits of IPR usage and adherence to licensing agreements.
  5. Privacy Management
    • Example: A retail company collects customer data and needs to comply with privacy laws in multiple jurisdictions.
    • Implementation: Deploy a privacy management solution that helps in classifying, managing, and protecting personal data in compliance with all applicable privacy laws.

Auditing Annex A.18 Implementation

The audit process for ISO 27001:2022’s Annex A.18 involves verifying that the organization has effectively implemented the controls to meet compliance requirements. The audit typically includes:

  1. Document Review: Review policies, procedures, compliance records, training records, audit reports, and any actions taken on previous audit findings.
  2. Interviews: Discuss with management and staff to assess their understanding and implementation of compliance controls.
  3. Observation: Observe processes and controls in operation to verify that they function as intended.
  4. Compliance Verification: Check compliance with specific legal, regulatory, and contractual requirements through evidence collection and analysis.
  5. Report Findings: Provide a detailed report of the audit findings with recommendations for improvement if any non-conformities are found.

Conclusion

Effective implementation of ISO 27001:2022 Annex A.18 ensures that an organization not only meets its legal and contractual obligations but also demonstrates a commitment to comprehensive information security management.

By establishing a structured compliance program and conducting thorough audits, organizations can maintain high standards of information security and build trust with stakeholders.

The post Implementing ISO 27001:2022 Annex A.18 – Compliance first appeared on Sorin Mustaca on Cybersecurity.

Implementing ISO 27001:2022 Annex A.17 – Information Security Aspects of Business Continuity Management

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We started the ISO 27001:2022 series with the promise of explaining how the 14 categories of controls can be implemented.

Today we address ISO 27001:2022 Annex A.17, “Information Security Aspects of Business Continuity Management” is crucial for organizations to ensure the resilience of their information security management systems (ISMS) in the face of disruptive events.

This annex provides guidelines for integrating information security into business continuity management processes to minimize the impact of disruptions and ensure the continuity of critical business operations.

Understanding the Importance of Business Continuity Management

Annex A.17 of ISO 27001:2022 outlines the controls necessary to ensure that information security is an integral part of the organization’s business continuity management. The annex emphasizes the need to prepare for, respond to, and recover from incidents that can impact the availability of critical information assets.

Business continuity management (BCM) is essential for organizations to prepare for and respond to disruptions that could affect their ability to deliver products and services.

Annex A.17 emphasizes several key aspects:

  • Risk Assessment: Identifying and assessing risks that could disrupt business operations and impact information security.
  • Business Impact Analysis: Evaluating the potential consequences of disruptions on critical business processes and information assets.
  • Business Continuity Planning: Developing and implementing strategies and procedures to maintain essential functions during and after disruptive events.
  • Testing and Exercise: Conducting regular testing and exercises to validate the effectiveness of business continuity plans and improve response capabilities.

 

Key Controls in Annex A.17:

  • A.17.1 Information Security Continuity: Ensure that information security continuity is embedded within the organization’s overall business continuity management systems.
  • A.17.2 Redundancies: Implement redundancy measures to ensure availability of information processing facilities.

Practical Implementation of Annex A.17

  1. Risk Assessment and Business Impact Analysis (BIA):
    • Example: An e-commerce company assesses the impact of a server downtime on its operations. The BIA shows significant revenue loss for each hour of downtime.
    • Implementation: Develop and implement continuity strategies based on the results of BIA. This includes identifying critical systems and processes and the extent of their protection.
  2. Establishing Redundancy and Resilience:
    • Example: A financial institution uses multiple data centers in geographically diverse locations to ensure data availability even in the case of a natural disaster.
    • Implementation: Invest in redundant hardware, failover systems, and data mirroring techniques to ensure continuous service and data availability.
  3. Developing and Implementing Business Continuity Plans:
    • Example: A healthcare provider ensures that all critical patient information systems have backups and are capable of being restored quickly in any emergency.
    • Implementation: Prepare detailed business continuity plans that include recovery objectives, strategies, and employee responsibilities. Regularly train staff on their roles during a disruption.
  4. Testing and Exercises:
    • Example: A technology firm conducts bi-annual drills to simulate different scenarios including cyber-attacks and power failures.
    • Implementation: Regular testing and rehearsal of business continuity plans to evaluate their effectiveness and make necessary adjustments.
  5. Embedding Information Security into Business Continuity:
    • Example: Incorporate cybersecurity measures into the business continuity plans of an online retailer to protect against data breaches during disruptions.
    • Implementation: Ensure that information security practices are maintained during a disruption, including access controls, encryption, and secure communication channels.

Auditing Annex A.17 Implementation

The audit of ISO 27001:2022’s Annex A.17 focuses on verifying that the business continuity plans and controls are in place, effective, and in alignment with the organization’s overall security policies. The audit process typically involves the following steps:

  1. Documentation Review: Auditors review all relevant documentation including the business impact analysis, risk assessments, continuity plans, and previous audit reports.
  2. Interviews: Conduct interviews with key personnel involved in business continuity management to assess their understanding and implementation of the policies.
  3. Observation and Testing: Direct observation of drills and testing processes, and reviewing logs and records to verify that procedures are regularly executed and monitored.
  4. Report Findings and Recommendations: Provide a detailed report of findings with any non-conformities and suggest corrective actions.

Conclusion

Implementing Annex A.17 of ISO 27001:2022 effectively ensures that an organization can protect its critical information assets during disruptions. By following structured implementation and regular audits, organizations can not only comply with ISO 27001 but also enhance their resilience against unforeseen events, thereby safeguarding their operations and reputation in the long term.

The post Implementing ISO 27001:2022 Annex A.17 – Information Security Aspects of Business Continuity Management first appeared on Sorin Mustaca on Cybersecurity.

Implementing ISO 27001:2022 Annex A.16 – Information Security Incident Management

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We started the ISO 27001:2022 series with the promise of explaining how the 14 categories of controls can be implemented.

Today we address ISO 27001:2022 Annex A.16, “Information Security Incident Management” is crucial for organizations to effectively detect, respond to, and recover from security incidents. This annex provides guidelines for establishing an incident management process to minimize the impact of security breaches and ensure the continuity of business operations.

Understanding the Importance of Information Security Incident Management

Incident management is a fundamental aspect of information security, helping organizations mitigate the impact of security incidents and protect sensitive information assets. Annex A.16 emphasizes several key aspects:

  • Timely Response: Promptly detecting and responding to security incidents minimizes their impact on operations and prevents further damage.
  • Containment and Recovery: Implementing effective containment and recovery measures helps restore affected systems and data to normal operations.
  • Continuous Improvement: Regularly reviewing and updating incident management procedures ensures their effectiveness and alignment with evolving threats and technologies.

Implementing Annex A.16 in Practice

Establishing Incident Management Procedures

Practical Examples:

  1. Incident Identification: Implement mechanisms to detect and identify security incidents, such as intrusion detection systems (IDS), security information and event management (SIEM) systems, and user reporting mechanisms.
  2. Incident Classification: Define criteria for classifying incidents based on severity, impact, and urgency to prioritize response efforts effectively.
  3. Incident Response Team: Establish an incident response team comprising key personnel responsible for coordinating and executing incident response activities.

Incident Response and Containment

Practical Examples

  1. Response Plan: Develop incident response plans outlining roles, responsibilities, and actions to be taken during security incidents, including containment, eradication, recovery, and communication procedures.
  2. Containment Measures: Implement measures to contain and mitigate the impact of security incidents, such as isolating affected systems, disabling compromised accounts, or blocking malicious traffic.
  3. Evidence Preservation: Preserve evidence related to security incidents for forensic analysis and investigation purposes, ensuring the integrity and admissibility of evidence.

Incident Analysis and Recovery

Practical Examples

  1. Root Cause Analysis: Conduct root cause analysis to identify the underlying causes of security incidents and implement corrective actions to prevent recurrence.
  2. System Restoration: Restore affected systems and data to normal operations following security incidents, using backup and recovery procedures to minimize downtime and data loss.
  3. Communication: Communicate with stakeholders, including senior management, employees, customers, and regulatory authorities, regarding the nature and impact of security incidents and steps taken for resolution.

Audit of Compliance with Annex A.16

Auditing compliance with Annex A.16 involves assessing the effectiveness of incident management procedures and practices. The audit process typically includes:

  • Audit Preparation: Gathering documentation related to incident management procedures, incident response plans, and incident logs.
  • On-site Audit: Assessing implementation of incident management controls through interviews, document reviews, and observations of incident response activities.
  • Audit Findings: Analyzing audit findings and identifying areas of non-compliance or improvement opportunities.
  • Reporting: Documenting audit results and providing recommendations for corrective actions to address identified issues.
  • Follow-up: Monitoring implementation of corrective actions and conducting follow-up audits to verify compliance.

Conclusion

ISO 27001:2022 Annex A.16 underscores the importance of establishing robust incident management procedures to effectively respond to security incidents and minimize their impact on business operations. By implementing incident identification, response, containment, and recovery measures, organizations can enhance their resilience to security threats and ensure the continuity of critical business functions. Regular audits help assess compliance with Annex A.16 requirements and drive continuous improvement in incident management practices, enabling organizations to adapt to evolving security challenges effectively. Prioritizing information security incident management is essential for organizations seeking to protect sensitive information assets and maintain trust and confidence in their operations.

The post Implementing ISO 27001:2022 Annex A.16 – Information Security Incident Management first appeared on Sorin Mustaca on Cybersecurity.

NIS-2: 10 common misconceptions about the regulation

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We wrote here about NIS2 and we will continue to add more content about it.

Because we are getting closer to October 17th, many people are getting more and more nervous about NIS2.

Despite its significance, there are numerous misconceptions and misinterpretations circulating about the scope and implications of this regulation.

This article aims to clarify some of the misconceptions,  which I collected mostly from LinkedIn and articles about NIS-2.

 

Note:

“NIS2” and “NIS-2” are exactly the same thing. I am using both in this article only because of SEO.

 

 

1. NIS2 starts being applied in the EU starting 17.10.2024

Truth is that the regulation is already applicable in the EU since it was approved. This deadline applies to the individual countries of the EU to convert and apply the NIS2 requirements in local laws.

If national authorities fail to properly implement EU laws, the Commission may launch a formal infringement procedure against the country in question. If the issue is still not settled, the Commission may eventually refer the case to the Court of Justice of the European Union.

 

2. Limited scope of application

Contrary to the belief that NIS-2 only applies to large tech companies, the directive significantly broadens its scope compared to its predecessor, NIS.

NIS-2 extends beyond just critical infrastructure sectors like energy and transport, encompassing a wide array of sectors such as digital services, public administration, and healthcare.

It mandates a security and incident reporting framework that applies to both Essential and Important Entities, significantly expanding the list of sectors and services affected.

3. NIS-2 Is Just About Cybersecurity

While cybersecurity is a core component, NIS-2 is not merely about preventing cyberattacks. The directive emphasizes a comprehensive approach to security, which includes resilience against a wide range of threats.

This includes but it is not limited to:

  • supply chain security,
  • incident response, and
  • crisis management.

It establishes a baseline for security measures and incident notifications that entities must adhere to, ensuring a uniform level of security across member states.

4. NIS-2 compliance is the same across all EU countries

Although NIS-2 sets a framework for cybersecurity across the EU, member states have some flexibility in implementation. This means that there can be variations in how directives are enforced from one country to another, depending on local laws and regulations.

Companies operating across multiple jurisdictions need to be aware of and comply with local variations to ensure full compliance.

5. Heavy penalties are the main compliance driver

While it is true that NIS-2 can impose hefty fines for non-compliance, focusing solely on penalties misses the broader objective of the directive.

NIS-2 is designed to cultivate a culture of security and resilience. It encourages entities to proactively manage their cybersecurity risks and to collaborate with national authorities.

This cooperative approach is fundamental to enhancing the overall cybersecurity posture of the EU.

6. NIS-2 does not affect third-party suppliers

NIS-2 places explicit requirements on the security practices of third-party suppliers. Entities covered under the directive are required to ensure that their supply chains are secure.

This includes mandatory risk assessments and incident reporting requirements that extend to service providers, reflecting an understanding that security is only as strong as the weakest link in the supply chain.

 

7. NIS-2 contains rules for AI, IoT, Industry 4.0.

NIS-2 sets a framework for cybersecurity and it does not address anything in particular. However, the rules described can be very well applied to companies in the fields like those mentioned that fall under the regulation applicability.

The companies active in Digital Infrastructure Services (Internet Nodes, DNS Service Providers, TLD Registries, Cloud Providers, Data Centers, Content Delivery Networks, Trust Services, Communication Networks, Communication Services ) and in

ICT Service Management (B2B only) (Managed Services (IT, Networks/Infrastructure, Applications), Managed Security Services (Risk and Cyber Security) ) are potentially directly affected by the regulation. However, there are clear criteria about which companies are affected.

 

8. Any company with activity in the domains marked as Important and Essential is affected by NIS-2

Although the domains are under the NIS-2 regulation, a company is affected if it meets the criteria:

  • Essential Entities (EE):
    • at least 250 employees and
    • 50 Mil € revenue
  • Important Entities (IE):
    • at least 50 employees and
    • 10 Mil € revenue

If a company doesn’t have these characteristics, then, in general, it is not affected by the regulation directly. It is highly recommended that even in such cases the companies follow the regulation’s requirements, since it will increase their resilience against cyber attacks.

However, an entity may still be considered “essential” or “important” even if it does not meet the size criteria, in specific cases such as when it is the sole provider of a critical service for societal or economic activity in a Member State.

 

9. All affected companies must certify for NIS-2

A the time of writing this post there is no certification for NIS-2. This might change in the future, especially when because we don’t know at this time how the regulation will be implemented in each of the EU member states.

There are consulting companies that sell consulting services and guarantee that a company will get the “NIS-2  certification” if they bus their services. While buying consulting is in general a good thing, the only thing that can be obtained is help in meeting the requirements of the regulation.

I recommend to stay away from offers that promise things that don’t exist.

 

10. Companies can buy software/hardware products to become conform with NIS-2

Although conformity is sometimes made easier by using specialized software and hardware products, there is no requirement or recommendation to purchase anything.

Some security providers and consulting companies are offering On The Shelf  (OTS) products that promise immediate conformity with NIS-2 (or guarantee obtaining a “certification” – see point 9 above).

If you look at the series of articles in the NIS2 area of this website, you will see that actually quite a lot of  steps involve an ISMS, a cybersecurity framework, cybersecurity products and so on.

These can be implemented with commercial or open source products, but there is still need to know where and how to install them in order to become conform.

I can very well imagine that there will be soon commercial offerings with sets of templates for implementing the NIS-2 requirements, just like there are with ISO 27001, TISAX and other certifications.

The post NIS-2: 10 common misconceptions about the regulation first appeared on Sorin Mustaca on Cybersecurity.

Implementing ISO 27001:2022 Annex A.15 – Supplier Relationships

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We started the ISO 27001:2022 series with the promise of explaining how the 14 categories of controls can be implemented.

Today we address ISO 27001:2022 Annex A.15, “Supplier Relationships”, which is crucial for organizations in order to ensure the security of information assets shared with external suppliers. This annex provides guidelines for managing supplier relationships effectively to mitigate risks and maintain information security.

From an IT security perspective, suppliers are external entities or third-party organizations that provide goods, services, or resources to support an organization’s operations.

These suppliers often play a critical role in the organization’s IT infrastructure, providing hardware, software, cloud services, and other technology solutions.

Suppliers may also have access to sensitive information, systems, or networks of the organization, making them potential security risks.

Therefore, managing supplier relationships is essential for ensuring the security of information assets and mitigating risks associated with third-party access.

 

Understanding the Importance of Supplier Relationships

Supplier relationships play a vital role in the overall information security posture of organizations. Annex A.15 emphasizes several key aspects:

  • Risk Management: Assessing and managing risks associated with suppliers who have access to sensitive information.
  • Contractual Agreements: Establishing clear contractual agreements that define security responsibilities and obligations.
  • Monitoring and Review: Continuously monitoring supplier performance and adherence to security requirements.

Implementing Annex A.15 in Practice

Supplier Selection and Evaluation

Practical Examples:

  1. Risk Assessment: Conduct thorough risk assessments of potential suppliers to evaluate their security controls, practices, and potential risks to information assets.
  2. Due Diligence: Perform due diligence checks, such as reviewing security certifications, conducting site visits, and requesting security documentation from suppliers.
  3. Security Requirements: Clearly communicate security requirements to suppliers during the selection process, including data protection measures, access controls, and incident response capabilities.

Contractual Agreements

Practical Examples:

  1. Security Clauses: Include specific security clauses in contracts that outline security requirements, confidentiality obligations, data protection measures, and compliance with relevant regulations.
  2. Data Protection: Address data protection requirements, including data handling procedures, data encryption, and secure transmission methods.
  3. Service Level Agreements (SLAs): Define SLAs for security-related metrics, such as incident response times, availability guarantees, and security incident notification procedures.

Monitoring and Review

Practical Examples:

  1. Ongoing Assessment: Continuously monitor supplier performance and security practices to ensure compliance with contractual agreements and security requirements.
  2. Audits and Reviews: Conduct periodic audits and reviews of supplier security controls, practices, and compliance with contractual obligations.
  3. Incident Response: Establish procedures for managing security incidents involving suppliers, including incident reporting, investigation, and remediation.

Audit of Compliance with Annex A.15

Auditing compliance with Annex A.15 involves assessing the effectiveness of supplier relationship management practices. The audit process typically includes:

  • Audit Preparation: Gather documentation related to supplier relationships, contracts, and security controls.
  • On-site Audit: Assess implementation of supplier management controls through interviews, document reviews, and observations.
  • Audit Findings: Analyze audit findings and identify areas of non-compliance or improvement opportunities.
  • Reporting: Document audit results and provide recommendations for corrective actions to address identified issues.
  • Follow-up: Monitor implementation of corrective actions and conduct follow-up audits to verify compliance.

Conclusion

ISO 27001:2022 Annex A.15 emphasizes the importance of effectively managing supplier relationships to protect information assets and mitigate risks. By implementing robust supplier management practices, organizations can ensure compliance with security requirements, maintain confidentiality, integrity, and availability of sensitive information, and enhance overall information security posture. Regular audits help assess compliance with Annex A.15 requirements and drive continuous improvement in supplier relationship management processes.

The post Implementing ISO 27001:2022 Annex A.15 – Supplier Relationships first appeared on Sorin Mustaca on Cybersecurity.