ISMS Compliance Scheduled Activities Plan

Calendar of the recurring quarterly, half-yearly and yearly ISMS activities, with owners, due dates and the evidence each must leave behind.

SXL-B00Plan1,908 words 9 min readOwner: Head of Information Security
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Template draft. Replace everything in [square brackets] with your own decision, delete what does not describe what you really do, and approve it through your own document control. It is not legal advice and does not make an organisation compliant or certified.

1. Purpose

This plan sets the calendar of recurring activities that keep the ISMS operating between audits. It turns requirements spread across the library into dated tasks with one owner each and a named record, so that nothing depends on someone remembering that a review is due.

  • Make every recurring ISMS task visible, dated and owned.
  • Define the evidence an auditor will be shown for each task.
  • Give the Head of Information Security an early warning when a task is slipping.

2. Scope

The plan covers tasks that recur at least once a year and are required by the policies, procedures and plans in the library. It applies to every function head and role holder named as an owner.

  • In scope: quarterly, half-yearly and yearly tasks in sections 6 to 8, and the event-driven reviews in section 9.
  • Out of scope: daily and weekly operational routines such as monitoring, scanning and backup jobs, which are run under the relevant procedures and reported through the metrics pack.

3. Objectives

  • Complete at least [95 percent] of scheduled tasks by their due date in every quarter.
  • Leave no task without evidence: [100 percent] of completed tasks have a record in the evidence location.
  • Close every missed task, with a reason and a new date, within [10 working days] of the due date.
  • Review the plan itself [every 12 months] so that it matches changes to the library.

4. Roles and Responsibilities

RoleResponsibilities
Head of Information SecurityOwns the plan; publishes the calendar [before each year starts]; chases late tasks; reports completion to the ISSC.
Task ownerPerforms the task by the due date, saves the evidence, and tells the plan coordinator when complete or at risk.
Plan coordinatorKeeps the calendar and the completion log; sends reminders [10 working days] and [3 working days] before each due date.
Function headsMake sure their people have the time to perform tasks assigned to them.
Internal audit leadSamples completed tasks and their evidence during the audit programme.
Top managementReceives the completion rate and decides on resources when tasks are repeatedly missed.
ActivityResponsibleAccountableConsultedInformed
Publish the annual calendarPlan coordinatorHead of Information SecurityTask ownersISSC
Perform scheduled tasksTask ownerFunction headHead of Information SecurityPlan coordinator
Track completion and chasePlan coordinatorHead of Information SecurityTask ownersISSC
Approve a change of dateHead of Information SecurityHead of Information SecurityTask ownerISSC
Verify evidence by samplingInternal audit leadTop managementHead of Information SecurityISSC
Review the plan itselfHead of Information SecurityTop managementISSC; task ownersAll task owners

5. How the Calendar Is Run

  1. PublishBefore the year starts the plan coordinator copies this plan into [the calendar tool] with a due date for each task, set in the first [month of the quarter]. Output: calendar with owners. Time target: [15 working days] before year start.
  2. RemindOwners are reminded [10 working days] and [3 working days] before the due date. The reminder links to the detail document and the evidence folder.
  3. Perform and recordThe owner performs the task and records the date, the result and the evidence location in the completion log (Annexure A).
  4. VerifyThe plan coordinator checks that the evidence exists and matches the task. Time target: [5 working days] after completion.
  5. EscalateA task more than [5 working days] late is reported to the Head of Information Security; more than [15 working days] late, to the ISSC with a reason and a recovery date.
  6. ReportThe completion rate by quarter and the list of late tasks go to the ISSC and into the management review.
  • A date may be moved only with the approval of the Head of Information Security and only within the same quarter. A task moved across a quarter boundary is recorded as a missed task.
  • Where a task's evidence is produced by a tool, an export or screenshot with the date is acceptable.
  • Do not combine tasks in one meeting unless each leaves its own record.

6. Quarterly Tasks

These tasks are performed in every quarter. The due date is [the last working day of the first month after quarter end] unless stated.

TaskOwnerEvidenceDetail document
Review user access to critical systems and remove unneeded accountsSystem owners; Head of IT operationsSigned access review sheet; removal ticketsUser Access Management Procedure
Review privileged and administrator accountsHead of IT operationsPrivileged account list with approvalsAccess Control Policy
Hold the Information Security Steering Committee meeting with the metrics packHead of Information SecurityAgenda, metrics pack, minutesISMS Manual
Review the risk register and treatment plan progressRisk managerUpdated register; overdue action listRisk Management Policy
Review vulnerability scan results and the patch backlog against the patch windowsHead of IT operationsScan report; backlog report; exceptionsPatch Management Procedure
Run a phishing simulation and follow up with those who failHead of Information SecurityCampaign report; follow-up recordHR Security Policy
Perform sample restore tests from backupHead of IT operationsRestore test record with timingsBackup Management and Retention Procedure
Review firewall and network access rulesNetwork leadRule review record; removed rulesNetwork Security Procedure
Reconcile the asset register with discovery tools and the finance fixed asset listAsset managerReconciliation reportAsset Management Procedure
Review the incident register for trends and lessons learnedIncident managerTrend report; lessons logIncident Management Procedure
Review critical supplier performance and security incidentsProcurement leadSupplier review recordSupplier Relationship Management Procedure
Review log source coverage and alert rulesSecurity operations leadCoverage report; rule changesLogging and Monitoring Procedure
Check training completion and chase overdue staffHRCompletion reportHR Security Procedure
Review the exceptions register and the documents past review dateHead of Information Security; document controllerExceptions list; overdue documents listDocuments and Records Management Procedure
Review physical access lists for secure areasFacilities leadSigned access listPhysical and Environmental Security Procedure

7. Half-Yearly Tasks

Half-yearly tasks fall in the second and fourth quarters unless the calendar sets otherwise. The due date is the end of the month in which the half closes.

TaskOwnerEvidenceDetail document
Hold the management review of the ISMSTop managementMinutes, inputs pack and decisionsISMS Manual
Run a recovery or failover test for critical systemsHead of IT operationsTest plan, result and issues logBCP and DR Procedure
Run a tabletop exercise of a major incidentIncident managerScenario, attendance, findingsIncident Management Procedure
Review the authorities and special interest groups contact listLegal and complianceUpdated listISMS Manual
Review the legal and regulatory requirements summaryLegal and complianceUpdated summary; change notesInternal and External Issues and Interested Parties
Audit half of the ISMS clauses and processesInternal audit leadAudit reportISMS Manual
Review cryptographic keys and certificates for rotation and expirySecurity engineering leadKey inventory with datesKey Management Process
Review baseline configurations for critical platformsPlatform ownersBaseline review recordSecure Configuration Policy
Review the threat intelligence sources and how they were usedSecurity operations leadSource review noteThreat Intelligence Policy
Test mobile device wipe and lost-device process on a sampleHead of IT operationsTest recordMobile Device Management Procedure

8. Yearly Tasks

Yearly tasks are placed in the calendar so that no month carries more than [four] of them.

TaskOwnerEvidenceDetail document
Perform the full risk assessment and update the risk treatment planRisk managerRegister; treatment plan; acceptancesRisk Management Policy
Review the Statement of ApplicabilityHead of Information SecurityUpdated statement with approvalStatement of Applicability
Review the ISMS scopeHead of Information SecuritySigned scope statementISMS Manual
Review all policies and procedures and re-approveDocument ownersRevision history; approvalDocuments and Records Management Procedure
Review issues and interested partiesHead of Information SecurityUpdated registersInternal and External Issues and Interested Parties
Set and approve objectivesISSCObjectives registerISMS Manual
Approve the annual internal audit programme and complete itInternal audit leadProgramme; reports; closure summaryISMS Manual
Commission an external penetration test and retestHead of Information SecurityReport; retest reportVulnerability Assessment and Penetration Testing Procedure
Complete full disaster recovery exercise and business impact reviewBusiness continuity leadExercise report; revised planBCP and DR Procedure
Reassess all critical suppliersProcurement leadAssessment recordsSupplier Relationship Management Procedure
Complete annual awareness training and policy acknowledgement for all staffHRTraining and acknowledgement recordsHR Security Policy
Recertify all user accessSystem ownersSigned recertificationUser Access Management Procedure
Review data protection records and impact assessmentsData Protection OfficerUpdated records; assessmentsData Protection and Privacy Procedure
Review retention and destroy information past its periodDocument controller; data ownersDestruction logDocuments and Records Management Procedure
Review cryptography standards and the Cyber Compliance PlanHead of Information SecurityReview note; updated planCyber Compliance Plan
Review cyber insurance cover against riskFinance leadPolicy review noteCyber Compliance Plan

9. Event-Driven Reviews

EventReview requiredTiming
Major incidentPost-incident review; risk register and controls updateWithin [10 working days] of closure
Significant change to scope, systems or suppliersRisk assessment; Statement of Applicability checkBefore go-live
New or changed law or customer requirementUpdate issues, parties and legal summaryWithin [10 working days]
Critical audit findingCorrective action under the ISMS ManualPer severity target
Merger, acquisition or reorganisationScope and roles reviewBefore the change takes effect

10. Annual Calendar

Month 1 is the first month of the Organisation's [financial year]. The table shows where the tasks above fall so that the load is even.

MonthQuarterly tasksHalf-yearly tasksYearly tasks
Month 1Quarter review windowNoneSet objectives; approve audit programme
Month 2NoneNoneReview all policies (first third)
Month 3NoneAuthorities list; legal summaryReview all policies (second third)
Month 4Quarter review windowNoneReview issues and parties; scope
Month 5NoneRecovery testReassess critical suppliers
Month 6NoneManagement review; internal audit of first half; key reviewFull risk assessment begins
Month 7Quarter review windowNoneRisk assessment completed; Statement of Applicability
Month 8NoneNonePenetration test and retest
Month 9NoneTabletop exerciseAwareness training and acknowledgement
Month 10Quarter review windowNoneAccess recertification
Month 11NoneNoneData protection review; retention destruction
Month 12NoneManagement review; internal audit of second half; recovery testFull recovery exercise; insurance review

11. Measures

MeasureTargetHow measured
Tasks completed by due date, each quarter[95 percent]Completion log
Completed tasks with evidence verified[100 percent]Coordinator check and audit sample
Tasks more than 15 working days late[Zero]Completion log
Dates moved across a quarter boundary[Under 5 percent]Change record
Escalations answered within the deadline[100 percent]ISSC minutes

12. Records and Evidence

RecordOwnerWhere keptRetention
Annual calendar and its versionsPlan coordinator[Calendar tool][3 years]
Completion log with evidence linksPlan coordinator[Document management system][5 years]
Evidence for each taskTask owner[Document management system][As stated in the detail document, minimum 3 years]
Escalation and date change recordsHead of Information Security[Document management system][3 years]

Annexure A: Completion log

TaskOwnerDue dateCompleted onResultEvidence location
Example: quarterly access reviewHead of IT operations[Date][Date]Complete; 12 accounts removed[Link]

Annexure B: Missed task and date change record

TaskOriginal due dateReasonNew dateApproved byRisk accepted in the meantime

13. Exception

Exceptions to this document are allowed only where compliance is not practicable and the risk has been assessed. A request must state what is to be excepted, why, the risk it creates, the compensating controls, and an end date no later than [6 months]. It is approved in writing by the document owner and the risk owner, recorded in the exceptions register, and reviewed at the end date. An exception does not change the document.

14. Enforcement

Compliance is monitored through internal audits, management review and routine checks by the document owner. Non-compliance is reported through the incident or non-conformity process and handled under the organisation's disciplinary procedure, and under the terms of any contract for people who are not employees. Serious or repeated non-compliance may lead to loss of access and, where the law is broken, to referral to the authorities.

15. Review

This document is reviewed at least every [12 months], and when there is a significant change to the organisation, its systems, its risks or the law, or after an incident that shows it was not effective. Each review is recorded in the revision history.

ISO/IEC 27001:2022 references

ReferenceTitle
9.1Monitoring, measurement, analysis and evaluation
9.2Internal audit
9.3Management review
10.1Continual improvement
A.5.36Compliance with policies, rules and standards for information security
A.5.37Documented operating procedures
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