1. Purpose
This manual describes how the Organisation establishes, implements, maintains and continually improves its information security management system (ISMS). It is the top-level document of the library: it states what the ISMS covers, who is accountable for it, how its parts connect, and which policy, procedure, plan or template carries the detail for each topic.
It is written to follow the clause order of ISO/IEC 27001:2022 (clauses 4 to 10) so that a customer, auditor or new employee can find how each requirement is met without reading the whole library. It does not repeat the standard; it records the Organisation's own decisions.
- Give top management a single place that shows the ISMS is planned, resourced and working.
- Let any employee find the right document for a task within [two minutes] using the library map in section 8.2.
- Show an auditor or customer which document and which record evidences each ISMS requirement (Annexure B).
- Fix the vocabulary used by every other document so that terms mean the same thing everywhere.
2. Scope
This manual applies to the ISMS of the Organisation as defined in the scope statement in section 4.3. It binds all employees, contractors, consultants, interns and temporary staff, and any supplier that handles the Organisation's information under contract.
- In scope: [the Organisation's registered office, delivery centres, data centre and cloud hosting accounts], all information assets used to deliver [the Organisation's services] and all people who work in or for those locations.
- In scope: the processes in section 4.4, including processes carried out by suppliers on the Organisation's behalf.
- Out of scope: [named business units, products or sites that hold no customer or business-critical information]. Each exclusion is justified in the scope statement and reviewed at every management review.
- Out of scope: the personal devices and accounts of staff, except where they are used for Organisation business under the Mobile Device and Teleworking Policy.
3. Terms, Definitions and Documentation Structure
3.1 Terms and definitions
| Term | Meaning in this library |
|---|---|
| ISMS | The set of policies, procedures, roles, records, tools and activities through which the Organisation manages information security risk. |
| Top management | The [Board of Directors and the Chief Executive Officer], who direct and control the Organisation at the highest level. |
| Information Security Steering Committee (ISSC) | The cross-functional forum chaired by a member of top management that governs the ISMS and acts as the management review body. |
| Interested party | A person or body that can affect, be affected by, or perceive itself to be affected by the ISMS, for example a customer, regulator or supplier. |
| Risk owner | The person accountable for a risk and authorised to accept it or fund its treatment. |
| Asset owner | The person accountable for an information asset throughout its life, including its classification and who may access it. |
| Control | A measure that modifies risk. Controls are drawn from Annex A of the standard and from other sources as the risk treatment plan requires. |
| Statement of Applicability (SoA) | The record of which Annex A controls apply, why, whether they are implemented, and why any are excluded. See Statement of Applicability. |
| Nonconformity | A requirement of the standard, a contract, the law or an ISMS document that has not been met. |
| Documented information | Any policy, procedure, plan, form or record that the ISMS requires to be controlled and kept. |
| Information security event | An occurrence that may indicate a breach of policy or a failure of a control. An event that compromises confidentiality, integrity or availability is an incident. |
| Residual risk | The risk that remains after controls have been applied. |
| Library | The full set of A-series policies, B-series procedures and plans, and templates listed in section 8.2. |
3.2 How the ISMS documentation is organised
The ISMS is documented in four levels. Each level is more specific than the one above and must not contradict it. Where two documents conflict, the higher level applies until the lower document is corrected.
| Level | Document type | Purpose | Examples |
|---|---|---|---|
| 1 | Manual and policy | Direction from top management; the rules everyone follows | ISMS Manual; Information Security Policy |
| 2 | Topic policies | Mandatory rules for a topic, with accountable owner | Access Control Policy; Cryptography Policy; Supplier Relationship Management Policy |
| 3 | Procedures, processes and plans | Step by step method, time targets, roles and evidence | User Access Management Procedure; Incident Management Procedure; BCP and DR Procedure |
| 4 | Records, forms and registers | Evidence that the activity happened | Risk register; access request forms; audit reports; training records |
Document numbering follows the pattern SXL-A## for policies and SXL-B## for procedures and plans. Version control, approval, distribution and retention follow the Documents and Records Management Procedure.
3.2.1 Principles for writing and keeping ISMS documents
- Every policy statement is testable: a reviewer can tell whether it was followed.
- Every procedure names an owner, a time target and the record that proves the step was done.
- Every decision the Organisation must make (a period, threshold, tool or frequency) appears once, in square brackets, in the document that owns it.
- A document that nobody follows is corrected or withdrawn; it is not left in the library.
4. Context of the Organisation
This section covers clauses 4.1 to 4.4 of the standard. It records what the Organisation is, what shapes its information security risk, who has requirements of it, where the ISMS boundary lies and which processes make up the ISMS.
4.1 Understanding the Organisation and its context
The Organisation determines the external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcomes of the ISMS. These are recorded and maintained in the Internal and External Issues and Interested Parties statement, which is the controlled source for this clause.
- External issues cover law and regulation, the threat landscape, customer and market expectations, technology change, the supply chain, and economic or geopolitical conditions.
- Internal issues cover governance, strategy, culture, people and skills, the technology estate, the standards the Organisation has committed to, and the state of vulnerability and patch management.
- The Head of Information Security refreshes the issues list at least every [12 months], before each management review, and after any major change or incident that points to an issue not yet recorded.
- Each issue is rated for its effect on the ISMS ([High, Medium, Low]) and linked to the risk, objective or control that responds to it.
4.2 Understanding the needs and expectations of interested parties
The Organisation identifies the interested parties relevant to the ISMS, their requirements, and which of those requirements become obligations or commitments the ISMS must meet. The register is held in the Internal and External Issues and Interested Parties statement. A summary of the main groups follows.
| Interested party | Main requirements | Where addressed |
|---|---|---|
| Customers | Protection of their data, availability of service, timely breach notice, evidence of assurance | Information Security Policy; Supplier Relationship Management Policy; contract terms |
| Regulators and government bodies | Compliance with applicable law, incident reporting, record keeping | Data Protection and Privacy Policy; Data Protection Act Compliance Procedure; Information Security Incident Management Policy |
| Data subjects | Lawful, fair and secure handling of personal data; rights requests answered | Data Protection and Privacy Procedure |
| Employees and contractors | Clear rules, training, a safe place to report problems, fair treatment | HR Security Policy; Acceptable Usage Policy |
| Suppliers and partners | Clear security terms, fair audit rights, prompt payment, secure interfaces | Supplier Relationship Management Procedure |
| Owners, investors and insurers | Controlled risk, no surprises, evidence of due care | Cyber Compliance Plan; management review reports |
| Certification and audit bodies | Conforming ISMS, evidence of operation, access to records | Internal audit programme; this manual |
4.3 Determining the scope of the ISMS
The scope is set by considering the issues and requirements above, the interfaces and dependencies between what the ISMS covers and what it does not, and the activities performed by others on the Organisation's behalf. The scope statement is a controlled record approved by top management and reviewed at least every [12 months].
| Dimension | Included | Excluded and justification |
|---|---|---|
| Organisation units | [All business units that deliver the Organisation's services and the functions that support them] | [Any unit excluded, with the reason, for example no access to customer or critical information] |
| Locations | [Registered office, delivery centres, hosting facilities, remote working by staff] | [Any site excluded, with the reason] |
| Information and assets | Information in any form held, processed or transmitted for the in-scope services, and the assets that support it | [Assets owned by customers that the Organisation does not control] |
| Services and products | [List the services and products covered] | [Services still under development, until a go-live decision brings them in] |
| Technology | Networks, servers, endpoints, cloud services, applications, development and test environments, identity systems | [Systems run entirely by a customer] |
| People | Employees, contractors, consultants, temporary staff and interns | None |
| Interfaces and dependencies | Suppliers and cloud providers, under contract controls | The internal controls of the supplier, which are assured through supplier review |
4.4 Information security management system and its processes
The Organisation has established the ISMS processes below and manages them with defined owners, inputs, outputs and measures. Their interaction is: risk assessment feeds treatment and the Statement of Applicability; treatment produces controls and objectives; operation produces records; monitoring, audit and review test the result; and improvement actions go back into planning.
| Process | Owner | Key inputs | Key outputs | Governing document |
|---|---|---|---|---|
| Context and interested parties | Head of Information Security | Law changes, audit findings, incidents, market change | Issues and parties register | Internal and External Issues and Interested Parties |
| Risk assessment and treatment | Risk manager | Asset register, threat information, audit findings | Risk register, treatment plan, Statement of Applicability | Risk Management Policy |
| Objectives and planning | Information Security Steering Committee | Risk treatment plan, previous results | Objectives with owners and dates | this manual, section 6.2 |
| Awareness and competence | HR and Head of Information Security | Role requirements, incidents, new joiners | Trained and aware workforce, records | HR Security Policy |
| Document and record control | Document controller | New or changed documents | Approved, versioned library | Documents and Records Management Procedure |
| Operational control | Function heads | Procedures, change requests, tickets | Controlled operations and records | section 8.2 library |
| Incident management | Incident manager | Reports, alerts, monitoring | Resolved incidents, lessons learned | Incident Management Procedure |
| Monitoring and measurement | Head of Information Security | Logs, metrics, test results | Metrics pack, exceptions | Information Security Monitoring and Compliance Policy |
| Internal audit | Internal audit lead | Audit programme, records | Audit reports and findings | section 9.2 |
| Management review | Chair of the ISSC | Audit, metrics, risk status, feedback | Decisions and actions | section 9.3 |
| Corrective action and improvement | Process owners | Nonconformities, suggestions | Closed actions, better controls | section 10 |
5. Leadership
This section covers clauses 5.1 to 5.3. Top management owns the ISMS; the Head of Information Security runs it.
5.1 Leadership and commitment
Top management demonstrates leadership and commitment through the actions below. Each has a named evidence item so that commitment can be checked rather than assumed.
| Commitment | How it is shown | Evidence |
|---|---|---|
| Policy and objectives are set and fit the strategy | Top management approves the Information Security Policy and the annual objectives | Signed policy; ISSC minutes |
| The ISMS is built into business processes | Security reviews are mandatory gates in change, project and supplier onboarding | Change records; project gate records |
| Resources are available | An annual security budget and headcount plan is approved | Budget approval; staffing plan |
| The importance of the ISMS is communicated | Top management addresses all staff on security at least [twice a year] | Town hall slides; attendance |
| The ISMS achieves its intended outcomes | Top management reviews the metrics pack at least [quarterly] | ISSC minutes; metrics pack |
| People are directed and supported | Role holders have time allocated and security duties in their objectives | Job descriptions; appraisal goals |
| Continual improvement is promoted | Top management funds corrective actions and reviews overdue ones | Action tracker; review minutes |
| Other managers are supported in their roles | Function heads are held to account for their area's controls | Management review actions |
5.2 Information security policy
Top management has approved the Information Security Policy. It states the Organisation's commitment to protect the confidentiality, integrity and availability of information, to satisfy applicable requirements, and to improve the ISMS continually, and it provides the framework for objectives. It is available as documented information, communicated to all personnel at joining and every [12 months], and made available to interested parties on request.
- The policy is reviewed at least every [12 months] and after any significant change in context, risk or law.
- Topic policies in the library implement it. A topic policy cannot grant a permission the policy denies.
- Each employee and contractor acknowledges the policy in writing at joining and at each annual refresher; the record is kept by HR.
- Suppliers receive the parts of the policy relevant to their work through the contract and the Supplier Relationship Management Procedure.
5.3 Organisational roles, responsibilities and authorities
Responsibilities and authorities for roles relevant to information security are assigned, communicated and understood. The roles below apply to the whole library; individual documents add role detail where needed. The detailed policy-level roles are in the Information Security Policy.
| Role | Responsibilities and authority |
|---|---|
| Top management | Approves policy, scope, objectives and the risk acceptance criteria; provides resources; chairs or sponsors the ISSC; reviews the ISMS at planned intervals. |
| Information Security Steering Committee | Meets at least [quarterly]. Reviews risk, metrics, audit results, major incidents and exceptions; approves high-risk treatment plans and changes to ISMS scope. |
| Head of Information Security | Runs the ISMS; owns this manual and the library; reports to top management on ISMS performance; has authority to stop a change or release that breaches policy. |
| Risk manager | Runs the risk assessment cycle, maintains the risk register and the risk treatment plan, and reports risks to the ISSC. |
| Internal audit lead | Plans and conducts internal audits independently of the area audited; reports findings to top management. |
| Data Protection Officer or privacy lead | Advises on personal data obligations; monitors compliance with privacy requirements; is the contact point for regulators and data subjects. |
| Document controller | Maintains the library, version control, distribution and the master document list. |
| Risk owner | Accepts or treats the risks assigned; funds and tracks treatment actions. |
| Asset owner | Classifies assets, approves access, and ensures the protection required by the classification. |
| Function and department heads | Implement the ISMS in their area; keep the records the procedures require; ensure their people are trained. |
| HR | Runs screening, joining and leaving steps, training records and disciplinary action. |
| Legal and compliance | Identifies legal, regulatory and contractual requirements and reviews the contract terms that carry security obligations. |
| All personnel | Follow the policies; protect information they handle; report events and weaknesses at once; complete training. |
| Activity | Responsible | Accountable | Consulted | Informed |
|---|---|---|---|---|
| Approve the Information Security Policy | Head of Information Security | Top management | ISSC; Legal and compliance | All personnel |
| Approve the ISMS scope statement | Head of Information Security | Top management | ISSC; function heads | Interested parties on request |
| Maintain the risk register | Risk manager | Head of Information Security | Risk owners; asset owners | ISSC |
| Accept risks above medium | Risk owner | Top management | Head of Information Security | ISSC |
| Run the internal audit programme | Internal audit lead | Top management | Head of Information Security; process owners | ISSC |
| Hold management review | Head of Information Security | Top management | Function heads; internal audit lead | All personnel (summary) |
| Maintain the document library | Document controller | Head of Information Security | Document owners | All personnel |
| Report incidents to authorities | Incident manager | Head of Information Security | Legal and compliance; Data Protection Officer | Top management |
5.3.1 Information Security Steering Committee operation
- Members: [Chief Executive Officer or delegate (chair), Head of Information Security (secretary), heads of Technology, Operations, HR, Legal and compliance, Finance, and the Data Protection Officer].
- Quorum: [the chair or delegate and at least half of the members]. A decision is recorded in minutes and an action tracker with owner and date.
- Standing agenda: status of actions from the previous meeting, risk register changes, metrics, audit and assessment results, incidents and near misses, exceptions granted, regulatory change, resourcing, and proposed changes.
- Escalation: any member may call an extraordinary meeting within [five working days] for a major incident, a high-risk finding or a significant change.
5.3.2 Segregation of duties and independence
Duties that could be misused in combination are separated, and where full separation is impractical the activity is monitored and reviewed by someone not involved. Internal audit does not audit work it designed or ran. The person who requests an access right, change or exception does not also approve it.
- Examples that must be separated: raising and approving a change; creating and approving a user account; developing and releasing code to production; initiating and approving a payment to a supplier.
- Where a small team cannot separate a duty, the Head of Information Security records the reason and the compensating control in the exceptions register.
5.3.3 Contact with authorities and special interest groups
The Organisation keeps up-to-date contact details for the authorities it may need to notify (such as the national computer emergency response team, the data protection regulator, law enforcement and sector regulators), and for specialist forums, mailing lists and professional bodies used for threat and vulnerability information. The contact list is reviewed every [six months] by the Head of Information Security. Only the incident manager, Legal and compliance or a delegate named in the Information Security Incident Management Policy may make a notification to an authority.
6. Planning
This section covers clause 6.1 (actions to address risks and opportunities) and 6.2 (objectives). Clause 6.3 (planning of changes) is covered in section 11.
6.1 Actions to address risks and opportunities
When planning the ISMS the Organisation considers the issues and interested-party requirements from section 4 and determines the risks and opportunities that must be addressed to give assurance that the ISMS can achieve its outcomes, prevent or reduce undesired effects, and achieve improvement. Actions are planned into the risk treatment plan, the objectives and the schedule in the ISMS Compliance Scheduled Activities Plan.
6.1.1 Information security risk assessment
The Organisation defines and applies a risk assessment process that sets risk acceptance criteria and criteria for performing assessments, produces consistent, valid and comparable results, identifies risks to confidentiality, integrity and availability, names risk owners, and analyses and evaluates the risks. The full method, with scales, tables and templates, is in the Risk Management Policy.
- Frequency: a full assessment every [12 months], and an assessment on any trigger event: a new service, a major change, a significant incident, a new supplier of critical services or a change in law.
- The assessment is led by the risk manager with asset owners, and results are reviewed by the ISSC.
- Results are held in the risk register and reported in the metrics pack.
6.1.2 Information security risk treatment
For each risk above the acceptance threshold the risk owner selects a treatment option, determines the controls needed, compares them with Annex A to make sure none has been overlooked, and records the decision in the risk treatment plan. The Statement of Applicability records which Annex A controls apply, whether they are implemented, and the reason for any exclusion. Risk owners approve the treatment plan and accept the residual risk in writing.
6.1.3 Opportunities
Opportunities that arise from the ISMS, such as winning customers that require evidence of assurance, reducing audit effort through automation, or consolidating tools, are recorded in the issues register and assessed by the ISSC alongside risks. An opportunity that is approved becomes an objective or a project.
6.2 Information security objectives and planning to achieve them
Objectives are set at relevant functions and levels. They are consistent with the policy, measurable, take account of requirements and risk results, are monitored, communicated and updated as appropriate. For each objective the plan states what will be done, what resources are needed, who is responsible, when it will be completed and how results will be evaluated.
| Objective | Measure | Target | Owner | Reviewed |
|---|---|---|---|---|
| Reduce time to contain security incidents | Median hours from detection to containment | [Under 8 hours for high severity] | Incident manager | [Quarterly] |
| Keep systems patched | Percent of critical vulnerabilities closed within the patch window | [95 percent within 14 days] | Head of IT operations | [Monthly] |
| Maintain a trained workforce | Percent of staff completing annual awareness training | [98 percent within 30 days of due date] | HR | [Quarterly] |
| Control access | Percent of privileged access reviewed on schedule | [100 percent every 3 months] | Head of IT operations | [Quarterly] |
| Manage supplier risk | Percent of critical suppliers assessed in the last 12 months | [100 percent] | Procurement lead | [Half-yearly] |
| Test recovery | Percent of critical systems with a successful restore or failover test in the year | [100 percent] | Head of IT operations | [Half-yearly] |
| Close audit findings | Percent of audit actions closed by the due date | [90 percent] | Head of Information Security | [Quarterly] |
Objectives are documented in the objectives register (Annexure C), approved by the ISSC, and reviewed in each management review. An objective that is missed for [two consecutive periods] triggers a root cause review under the corrective action process in section 10.
7. Support
This section covers clauses 7.1 to 7.5.
7.1 Resources
The Organisation determines and provides the resources needed for the ISMS. The annual security plan states the budget, people and tools required for the objectives and the risk treatment plan. Resource gaps that prevent a control operating are raised to the ISSC within [10 working days] and recorded as a risk if not resolved.
7.2 Competence
The Organisation determines the competence needed for people whose work affects information security performance, ensures they are competent through education, training or experience, takes action where competence is lacking, and keeps evidence.
| Role group | Competence required | How assured | Evidence |
|---|---|---|---|
| Security team | Relevant professional qualification or demonstrated experience; annual technical training of [24 hours] | Hiring checks; annual development plan | Certificates; training log |
| System and network administrators | Hardening, patching, logging and backup practice for the platforms they run | Onboarding checklist; peer review | Checklist; access records |
| Developers | Secure coding practice and the System Development and Maintenance Procedure | Annual secure-coding course and code review | Course records; review records |
| Internal auditors | Knowledge of the standard and audit technique; independence | Auditor training; shadow audit | Auditor register |
| Risk owners and managers | Understanding of the risk method and their acceptance authority | Briefing at appointment and each year | Briefing record |
| All personnel | Awareness of policy, their responsibilities and how to report | Induction and annual training with assessment | Training records |
7.3 Awareness
Persons doing work under the Organisation's control are aware of the information security policy, their contribution to the effectiveness of the ISMS including the benefits of improved performance, and the implications of not conforming. Awareness covers induction within [first week], annual refresher, role-based modules, simulated phishing at least [quarterly], and targeted communication after incidents.
- Completion is tracked by HR and reported monthly; access is suspended for staff more than [30 days] overdue on mandatory training until it is complete.
- Awareness effectiveness is measured by test scores, phishing click and report rates, and the number of security events reported by staff.
7.4 Communication
The Organisation determines the internal and external communication relevant to the ISMS. Responsibility for each is fixed in the table below; no one else makes external statements about security.
| What | When | Who communicates | To whom | How |
|---|---|---|---|---|
| Information Security Policy and changes | At joining; on change; annually | Head of Information Security | All personnel | Learning platform and intranet |
| Security metrics and risk status | [Quarterly] | Head of Information Security | ISSC and top management | Metrics pack |
| Security alerts and advisories | As needed | Security operations | Affected staff or all | Email and chat channel |
| Incident notifications to customers | Within the time in the contract or [72 hours] | Incident manager with Legal and compliance | Affected customers | Written notice |
| Reports to authorities | As the law requires; see the Information Security Incident Management Policy | Incident manager or Data Protection Officer | Relevant authority | Official channel |
| Assurance responses to customers | On request | Head of Information Security | Customer security team | Questionnaire; summary of controls |
| Supplier requirements | At onboarding and on change | Procurement lead | Suppliers | Contract and security schedule |
7.5 Documented information
The ISMS includes the documented information required by the standard and the documented information the Organisation has determined to be necessary for the ISMS to be effective. The approach to creating, updating and controlling it is in the Documents and Records Management Procedure.
- Creating and updating: each document has a code, title, version, owner, approver, effective date and review date, and is approved before use.
- Control: the master library is held in [the document management system] with access control, change history and a single published copy. Printed copies are uncontrolled.
- Retention: records are kept for the periods in the retention schedule of the Documents and Records Management Procedure, with a minimum of [three years] for audit and risk records unless the law requires longer.
- Protection: documents are classified under the Information Classification and Handling Policy and protected from loss of confidentiality, improper use and loss of integrity.
- External documents, such as customer requirements and standards, are identified, kept current and controlled in the same system.
8. Operation
This section covers clauses 8.1 to 8.3 and presents the library, which is how operational control is delivered.
8.1 Operational planning and control
The Organisation plans, implements and controls the processes needed to meet requirements and to carry out the actions determined in section 6. Operational control is delivered through the policies and procedures listed in section 8.2, each of which names an owner, a time target and a record. Planned changes are controlled and the consequences of unintended changes are reviewed, as set out in section 11.
- Processes are executed as documented; deviations are recorded as nonconformities or exceptions.
- Outsourced processes and the supply of externally provided products and services that are relevant to the ISMS are identified and controlled through the Supplier Relationship Management Policy and Supplier Relationship Management Procedure.
- Documented information is kept to the extent needed to have confidence that processes were carried out as planned.
8.2 Library map
The tables below list every document in the ISMS library by exact title, grouped as in the library. Policies (A-series) state the rules; procedures, processes and plans (B-series) state how. Where a policy has a matching procedure, both are shown. Annexure B shows which clause each document supports.
8.2.1 ISMS framework documents
| Code | Document | How it supports the ISMS |
|---|---|---|
| A00 | ISMS Manual | This document: the structure of the ISMS and the map of the library. |
| A01 | Information Security Policy | Top management's policy, roles and principles; the parent of all topic policies. |
| A02 | Risk Management Policy | The risk assessment and treatment method, scales and templates. |
| A27 | Internal and External Issues and Interested Parties | The register of issues and interested-party requirements that shape scope and risk. |
| B00 | ISMS Compliance Scheduled Activities Plan | The calendar of recurring quarterly, half-yearly and yearly ISMS tasks. |
| B07 | Documents and Records Management Procedure | How documents and records are created, approved, controlled, retained and destroyed. |
| B24 | Cyber Compliance Plan | The consolidated plan that sets compliance objectives and the technical and organisational measures that meet them. |
| SOA | Statement of Applicability | The record of applicable Annex A controls, their status and the reasons for any exclusions. |
8.2.2 Access, assets and people
| Code | Document | How it supports the ISMS |
|---|---|---|
| A04 | Access Control Policy | Rules for granting, reviewing and removing access; the basis for least privilege. |
| B02 | User Access Management Procedure | Steps for joiner, mover and leaver access and periodic review. |
| A07 | HR Security Policy | Screening, terms of employment, awareness, discipline and leaving. |
| B08 | HR Security Procedure | Steps and records for pre-employment checks, onboarding and exit. |
| A09 | Acceptable Usage Policy | What people may and may not do with the Organisation's information and systems. |
| A14 | IT Asset Management Policy | Rules for owning, tracking and protecting IT assets across their life. |
| B01 | Asset Management Procedure | How assets are recorded, owned, valued and reviewed; the asset register. |
| B21 | Asset Disposal Process | Secure return, wiping and destruction of equipment and media. |
| A16 | Information Classification and Handling Policy | Classification levels and handling rules for each level. |
| B10 | Information Classification and Handling Procedure | How to classify, label, share and dispose of information. |
| A19 | Mobile Device and Teleworking Policy | Security rules for mobile devices and for working away from the office. |
| B13 | Mobile Device Management Procedure | Enrolment, configuration, loss handling and removal of mobile devices. |
| A31 | HR Succession Planning Policy | Cover for key security and operational roles. |
| A33 | Employee AI Usage Policy | Rules for staff use of generative and other AI tools with business information. |
8.2.3 Technology and operations: build, change and protect
| Code | Document | How it supports the ISMS |
|---|---|---|
| A05 | Backup and Restoration Policy | What is backed up, how often, how it is protected and how restoration is proved. |
| B03 | Backup Management and Retention Procedure | Backup schedules, monitoring, retention and restore tests. |
| A06 | Cryptography Policy | When encryption is required and the approved standards. |
| B12 | Cryptography Procedure | How encryption is applied, configured and verified. |
| B20 | Key Management Process | Generation, storage, rotation, recovery and retirement of keys. |
| A12 | Communications and Operations Security Policy | Operational rules for systems, networks, change windows and information transfer. |
| B14 | Network Security Procedure | Segmentation, firewall rules, remote access and network monitoring. |
| A15 | Systems Acquisition, Development and Maintenance Policy | Security requirements for buying, building and maintaining systems. |
| B18 | System Development and Maintenance Procedure | Secure development life cycle, testing and release steps. |
| A17 | Change Management Policy and Procedure | Approval, testing and rollback for changes to production. |
| A18 | Cloud Computing Security Policy and Procedure | Security requirements and steps for using cloud services. |
| B05 | Capacity Management and Planning Procedure | Forecasting and monitoring capacity so that availability is protected. |
8.2.4 Technology and operations: monitor, detect and fix
| Code | Document | How it supports the ISMS |
|---|---|---|
| A20 | Logging and Monitoring Policy | What is logged, protected and reviewed. |
| B11 | Logging and Monitoring Procedure | Log collection, review, alert handling and retention. |
| A21 | Malware Protection Policy | Requirements for detecting and preventing malicious software. |
| A22 | Patch Management Policy | Patching rules and time limits by severity. |
| B15 | Patch Management Procedure | Steps to assess, test, deploy and verify patches. |
| A23 | Problem Management Policy and Process | Finding and removing the root causes of recurring failures. |
| A24 | Secure Configuration Policy | Baselines and hardening for systems and devices. |
| A26 | Threat Intelligence Policy | Collection, analysis and use of threat information. |
| B19 | Vulnerability Assessment and Penetration Testing Procedure | Scanning and testing method, rating, reporting and retest. |
8.2.5 Resilience, suppliers, privacy and compliance
| Code | Document | How it supports the ISMS |
|---|---|---|
| A03 | Data Protection and Privacy Policy | Principles for processing personal data lawfully and securely. |
| B06 | Data Protection and Privacy Procedure | Steps for rights requests, impact assessments and breach handling. |
| B22 | Data Protection Act Compliance Procedure | Steps to meet statutory data protection obligations. |
| A29 | Data Governance Policy | Ownership, quality, lineage and lifecycle of data. |
| A08 | Information Security Monitoring and Compliance Policy | How compliance with policy, law and contract is checked. |
| A10 | Physical and Environmental Controls Policy | Rules for premises, equipment and environmental protection. |
| B16 | Physical and Environmental Security Procedure | Access to premises, visitors, equipment siting and inspection. |
| A11 | Information Security Incident Management Policy | Principles, roles and reporting duties for incidents. |
| B09 | Incident Management Procedure | Detection, triage, containment, recovery and review steps. |
| A13 | Information Security Aspects of Business Continuity Policy | Security during disruption and recovery. |
| B04 | BCP and DR Procedure | Business continuity and disaster recovery plans, tests and roles. |
| A25 | Supplier Relationship Management Policy | Security rules for selecting and managing suppliers. |
| B17 | Supplier Relationship Management Procedure | Due diligence, contract terms, monitoring and exit. |
| A28 | AI Governance Policy | Governance of AI systems built, bought or used. |
| A30 | Public Policy Advocacy and Regulatory Engagement Policy | Who may speak to regulators and policy makers and how. |
| B23 | Product Risk Assessment Procedure | Risk assessment of products and services before release and on change. |
8.3 Information security risk assessment and treatment in operation
Risk assessments are performed at planned intervals or when significant changes are proposed or occur, taking account of the acceptance criteria, and the results are retained as documented information. The risk treatment plan is implemented and the results of treatment are retained. Treatment actions are tracked to closure by the risk manager and reviewed by the ISSC [quarterly].
9. Performance Evaluation
This section covers clauses 9.1 to 9.3.
9.1 Monitoring, measurement, analysis and evaluation
The Organisation determines what needs to be monitored and measured, the methods used to ensure valid results, when monitoring and measuring is performed, who performs it, when results are analysed and evaluated, and who does that. Each document in the library carries its own measures; the ISMS-level measures below are reported to the ISSC in the metrics pack.
| Measure | Method | Frequency | Owner | Target |
|---|---|---|---|---|
| Open high and critical risks | Count from the risk register | [Monthly] | Risk manager | [Zero overdue treatment actions] |
| Security incidents by severity | Count and trend from the incident register | [Monthly] | Incident manager | [No high severity repeat of the same cause] |
| Mean time to detect and to contain | Timestamps in the incident record | [Monthly] | Incident manager | [As in objectives register] |
| Critical vulnerabilities past their patch window | Vulnerability scanner report | [Weekly] | Head of IT operations | [Zero] |
| Access review completion | Review records against schedule | [Quarterly] | Head of IT operations | [100 percent] |
| Training and phishing results | Learning platform and simulation tool | [Monthly] | HR; Head of Information Security | [98 percent trained; click rate under 5 percent] |
| Supplier assessments completed | Supplier register | [Quarterly] | Procurement lead | [100 percent of critical suppliers] |
| Audit findings overdue | Action tracker | [Monthly] | Head of Information Security | [Zero major overdue] |
| Recovery tests passed | BCP and DR test records | [Half-yearly] | Head of IT operations | [All critical systems within recovery time objective] |
When a measure falls outside target for [two consecutive periods], the owner reports a cause and a corrective action at the next ISSC meeting. Measures themselves are reviewed yearly to confirm they still show something decision makers need.
9.2 Internal audit
The Organisation conducts internal audits at planned intervals to provide information on whether the ISMS conforms to the Organisation's own requirements and the standard, and is effectively implemented and maintained. The programme covers every ISMS process and every clause of the standard at least once in each [12 months], with higher-risk areas and areas with earlier findings audited more often.
- Plan the programmeThe internal audit lead prepares an annual programme with scope, criteria, method, frequency and auditors, approved by the ISSC in [month 1]. Output: audit programme.
- Select auditorsAuditors are competent and independent of the area audited. Output: assignment letters.
- Notify and prepareThe auditee is notified at least [10 working days] before. Auditors prepare checklists from the documents, the previous findings and the risk register.
- Conduct the auditAuditors interview staff, inspect records and test controls on a sample basis, and record objective evidence.
- ReportA written report with findings graded as major nonconformity, minor nonconformity, observation or good practice is issued within [five working days] of the closing meeting.
- Agree actionsThe auditee proposes a correction, root cause and corrective action with dates within [10 working days]. Actions go to the tracker.
- Verify and reportThe audit lead verifies closure and reports the programme result to top management in the management review.
| Activity | Responsible | Accountable | Consulted | Informed |
|---|---|---|---|---|
| Annual audit programme | Internal audit lead | Top management | Head of Information Security | ISSC |
| Conduct audit | Internal auditor | Internal audit lead | Process owner | Head of Information Security |
| Corrective action | Process owner | Function head | Head of Information Security | Internal audit lead |
| Verify closure | Internal audit lead | Internal audit lead | Process owner | ISSC |
9.3 Management review
Top management reviews the ISMS at planned intervals, at least every [six months], to ensure its continuing suitability, adequacy and effectiveness. The review is held as an ISSC meeting with a fixed agenda.
| Required input | Typical source | Required output |
|---|---|---|
| Status of actions from previous reviews | Action tracker | Decisions on opportunities for continual improvement |
| Changes in external and internal issues relevant to the ISMS | Internal and External Issues and Interested Parties | Decisions on any need for changes to the ISMS, including scope |
| Changes in needs and expectations of interested parties | Interested-party register | Resource needs and approvals |
| Feedback on performance: nonconformities and corrective actions | Corrective action log | Changes to objectives, policy or risk acceptance criteria |
| Monitoring and measurement results | Metrics pack | Instructions for follow-up and owners |
| Audit results | Internal and external audit reports | Approval of the next audit programme |
| Fulfilment of information security objectives | Objectives register | Updated objectives |
| Feedback from interested parties | Customer surveys; complaints; regulator contact | Communication decisions |
| Results of risk assessment and status of treatment plan | Risk register; risk treatment plan | Approval of residual risk; changes to the plan |
| Opportunities for continual improvement | Suggestions; benchmark; lessons from incidents | Improvement projects approved |
Minutes record the decisions, owners and dates, and are issued within [five working days]. The template is Annexure D.
10. Improvement
This section covers clauses 10.1 and 10.2.
10.1 Continual improvement
The Organisation continually improves the suitability, adequacy and effectiveness of the ISMS. Sources of improvement are audit results, incident reviews, metrics, supplier and customer feedback, benchmarking, staff suggestions and changes in the threat landscape. Improvements above [a set effort threshold, for example 10 person-days] are approved as projects by the ISSC and tracked in the action tracker.
10.2 Nonconformity and corrective action
A nonconformity can be found in an audit, a review, an incident, a supplier assessment or by any employee. The same process applies to all of them.
- RecordThe finder logs the nonconformity in the action tracker with date, source, requirement breached and evidence. Target: within [two working days] of discovery.
- Contain and correctThe process owner takes immediate action to control and correct it and deals with the consequences. Target: within [five working days] for major, [15] for minor.
- Find the causeThe process owner determines the root cause using a method suited to the problem (for example five whys or a causal factor tree) and checks whether similar issues exist or could occur elsewhere.
- ActThe owner defines corrective action, resources, owner and due date; the Head of Information Security agrees the action. Major actions go to the ISSC.
- Verify effectivenessAfter [30 to 90 days] the audit lead or the Head of Information Security checks that the action worked and the cause has gone. Output: effectiveness note.
- Update the ISMSIf the review shows a change is needed to the ISMS, a document, risk or control, the change is made through the Documents and Records Management Procedure and the Change Management Policy and Procedure.
| Grade | Meaning | Containment | Closure target |
|---|---|---|---|
| Major | A requirement is not met, or a control fails in a way that could cause a significant incident | [5 working days] | [30 days] |
| Minor | A requirement is partly met or an isolated lapse with low risk | [15 working days] | [90 days] |
| Observation | No breach yet, but a weakness that may become one | Not required | [At next review] |
11. Planning of Changes
This section covers clause 6.3. When the Organisation determines the need for changes to the ISMS, the changes are carried out in a planned manner. This applies to changes to the scope, policies, risk method, controls, roles, tools and to the ISMS documents themselves.
- RaiseThe proposer submits a change to the Head of Information Security stating the purpose, the clauses and documents affected, and the expected benefit. Output: change request (Annexure E).
- AssessThe Head of Information Security considers the purpose and potential consequences, the integrity of the ISMS during the change, the availability of resources, and the allocation or reallocation of responsibilities and authorities. Time target: [10 working days].
- ApproveApproval authority depends on impact: a document wording change by the document owner; a procedure change by the Head of Information Security; a change to policy, scope, risk criteria or objectives by the ISSC, and the Information Security Policy by top management.
- ImplementThe change is made, communicated to those affected, and training given where needed. Output: updated documents, communication record.
- ReviewAfter [three months] the Head of Information Security confirms the change achieved its aim and caused no gap in control. Output: closure note.
| Type of change to the ISMS | Approver | Consultation | Evidence |
|---|---|---|---|
| Wording or format of a document | Document owner | None | Revision history |
| New or changed procedure or form | Head of Information Security | Process owner; document controller | Approval record; distribution log |
| New or changed topic policy | ISSC | Function heads; Legal and compliance | ISSC minutes |
| Change to the ISMS scope, risk acceptance criteria or Information Security Policy | Top management | ISSC; Legal and compliance | Signed approval |
| Emergency change to control a live risk | Head of Information Security, ratified by the ISSC within [10 working days] | As time allows | Emergency change record |
12. Compliance and Monitoring
Adherence to this manual is checked through the internal audit programme, the management review and the annual review of the library. The Head of Information Security reports at each ISSC meeting the number of documents past their review date, open nonconformities against this manual, and exceptions granted. Any document more than [30 days] past its review date is escalated to the ISSC.
13. Records and Evidence
| Record | Owner | Location | Retention |
|---|---|---|---|
| Approved scope statement and previous versions | Head of Information Security | [Document management system] | [Life of the ISMS plus 3 years] |
| Issues and interested-party register | Head of Information Security | [Document management system] | [3 years after superseded] |
| ISSC minutes and action tracker | Head of Information Security | [Document management system] | [5 years] |
| Risk register, treatment plan and acceptance records | Risk manager | [Risk register tool] | [5 years after closure] |
| Statement of Applicability with history | Head of Information Security | [Document management system] | [Life of the ISMS plus 3 years] |
| Objectives register and results | Head of Information Security | [Document management system] | [3 years] |
| Training and competence records | HR | [HR system] | [Employment plus 3 years] |
| Audit programme, reports and corrective actions | Internal audit lead | [Document management system] | [5 years] |
| Management review minutes and inputs | Head of Information Security | [Document management system] | [5 years] |
Annexure A: ISMS scope statement template
| Field | Entry |
|---|---|
| Organisation name and legal entity | |
| ISMS scope statement (one paragraph) | |
| Locations included | |
| Business units and services included | |
| Exclusions and justification | |
| Interfaces and dependencies on third parties | |
| Approved by and date | |
| Next review date |
Annexure B: Clause to document map
| Clause | Topic | Where it is met | Principal record |
|---|---|---|---|
| 4.1 | Context of the organisation | Internal and External Issues and Interested Parties | Issues register |
| 4.2 | Interested parties | Internal and External Issues and Interested Parties | Interested-party register |
| 4.3 | Scope | ISMS Manual, section 4.3 | Scope statement |
| 4.4 | ISMS and its processes | ISMS Manual, section 4.4 | Process table; library |
| 5.1 | Leadership and commitment | ISMS Manual, section 5.1 | ISSC minutes; budget approvals |
| 5.2 | Policy | Information Security Policy | Signed policy; acknowledgements |
| 5.3 | Roles and authorities | ISMS Manual, section 5.3; Information Security Policy | Role appointments |
| 6.1 | Risks and opportunities | Risk Management Policy; Statement of Applicability | Risk register; treatment plan |
| 6.2 | Objectives | ISMS Manual, section 6.2 | Objectives register |
| 6.3 | Planning of changes | ISMS Manual, section 11 | Change requests |
| 7.1 to 7.4 | Resources, competence, awareness, communication | ISMS Manual, section 7; HR Security Policy | Training records; communication plan |
| 7.5 | Documented information | Documents and Records Management Procedure | Master document list |
| 8.1 to 8.3 | Operation and risk treatment | The library in section 8.2 | Operational records |
| 9.1 | Monitoring and measurement | ISMS Manual, section 9.1; Information Security Monitoring and Compliance Policy | Metrics pack |
| 9.2 | Internal audit | ISMS Manual, section 9.2 | Audit programme and reports |
| 9.3 | Management review | ISMS Manual, section 9.3 | Review minutes |
| 10.1 | Continual improvement | ISMS Manual, section 10.1 | Action tracker |
| 10.2 | Nonconformity and corrective action | ISMS Manual, section 10.2 | Corrective action log |
Annexure C: Information security objectives register
| Ref | Objective | Measure and target | Owner | Due date | Status |
|---|---|---|---|---|---|
| OBJ-01 | |||||
| OBJ-02 | |||||
| OBJ-03 |
Annexure D: Management review minutes template
| Item | Entry |
|---|---|
| Date, time and place | |
| Chair and attendees | |
| Apologies and quorum met (yes or no) | |
| Actions from previous review: status | |
| Changes in issues and interested-party requirements | |
| Metrics, objectives and audit results | |
| Risk status and treatment plan | |
| Incidents and nonconformities | |
| Decisions on improvement and resources | |
| Actions: description, owner, due date | |
| Next review date |
Annexure E: ISMS change request
| Field | Entry |
|---|---|
| Change reference and date | |
| Proposed by | |
| Description and reason | |
| Clauses, documents and processes affected | |
| Consequences and risks of the change | |
| Resources and responsibilities needed | |
| Approver and decision | |
| Implementation date and communication | |
| Post-implementation review date and result |
14. 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.
15. 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.
16. 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
| Reference | Title |
|---|---|
| 4.1 | Understanding the organization and its context |
| 4.2 | Understanding the needs and expectations of interested parties |
| 4.3 | Determining the scope of the information security management system |
| 4.4 | Information security management system |
| 5.1 | Leadership and commitment |
| 5.2 | Policy |
| 5.3 | Organizational roles, responsibilities and authorities |
| 6.1.2 | Information security risk assessment |
| 6.1.3 | Information security risk treatment |
| 6.2 | Information security objectives and planning to achieve them |
| 7.2 | Competence |
| 7.3 | Awareness |
| 7.4 | Communication |
| 7.5 | Documented information |
| 8.1 | Operational planning and control |
| 9.1 | Monitoring, measurement, analysis and evaluation |
| 9.2 | Internal audit |
| 9.3 | Management review |
| 10.1 | Continual improvement |
| 10.2 | Nonconformity and corrective action |