Building an Effective Information Security Management System (ISMS)

Jul 3

A documented Policy detailing Information Security Management System controls

An Information Security Management System should act as an index of governing policies, procedures, and controls within the company. It highlights critical areas across the enterprise and positions passive evidence collection. Although your particular ISMS should contain sections that are applicable to your company, here are some recommendations on key components to include:

Document/Governance Policy
Data Classification

Describes types of data
Data purposefulness
Data minimization
Retention: How long to keep which type of data?
Backup: How much of each type of data are we keeping for how long?
Destruction: Which data is destroyed when?

Access Management (aligned to Data Classification, each data type will matrix into the below bullets)

Logical access
Physical access
System to system access
Privileged access permissions

DR/BCP (aligned to Data Classification with the most critical data types prioritized)

Disaster Recovery: Restoring operations in case of a hard stop
Business Continuity Planning: Preventing that hard stop & scaling appropriately

Vendor Management

Tiering types of vendors (based on Data Classification and identifying which vendor handles the most important data)
Intake criteria & approvals
Operational measurements
Nonfulfillment
Disengaging

Asset Management

BYOD provisions
Standardized imaging based on role
API Inventory
Correlation & Support of other competencies (on this list)

Security Awareness

Clearly defined rules and training
Shared passwords/admin accounts/password refresh

Incident Management

Internal triggers (scans)
End users (requests & break fix)
External triggers (vendors)
Threats
Maintenance tracking

Change Management
Cryptographic Key Management
AI Policy
Perimeter security

Remember the main purpose for Company Documents

The purpose of company documents is to guide workers to be successful and provide structure for company operations. Properly maintained documents can significantly improve the effectiveness of a GRC program.

Don’t overcomplicate and include items that don’t apply to your company

Documenting policies and processes doesn’t need to be complicated; it should reflect what you do. This reflection ensures that policies and practices are aligned, helping to maintain consistency and clarity across the organization.

Key Considerations

When creating and maintaining company documents, avoid vague terms like “occasionally,” “periodically,” “routinely,” “from time to time,” “frequently,” and “recurring.” Auditors require specifics - If you don’t provide it to them, then you’re allowing them the freedom to come up with their own frequency definition. An example is “frequently” may mean monthly to you, but weekly to an auditor. Define the frequency, assign responsibilities, and set clear success criteria. Automation of controls and effective auditing are impossible without specific details.

Consistency and Clarity

Ensure that definitions are reflective of every document. Avoid simply copying and pasting text or adding unnecessary words. Properly defined documents should include:

Purpose and Scope: Clearly define the intent and extent of each document.
Definitions: Include relevant definitions to ensure clarity and consistency.
Internal Audits and Management: Outline procedures for internal audits and management reviews.
Record Management Protocol: Specify how data is gathered, the frequency of data collection, and data retention policies. Ensure that practices and policies are aligned.
Training and Communication: Detail the training requirements and how information will be disseminated.
Related Internal Documents: Refer to related documents rather than duplicating content. This approach helps in maintaining version control.
External References: Mention external controls and frameworks that guided the document creation.
Exception Process/Request: Define how exceptions are handled and requests are processed.
Non-compliance: Outline the consequences and actions for non-compliance.
Revision Schedule: Establish a schedule for reviewing and updating documents, typically annually or as needed.

Implementing and Maintaining the Policy

Implementing an Information Security Management System Policy is just the beginning. Regular reviews and updates ensure that the policy remains relevant and effective in addressing emerging threats and changes within the organization. Training and communication are vital to ensure that all employees understand and follow the policies. Regular internal audits and management reviews help in identifying gaps and areas for improvement, ensuring continuous compliance and security.

By following these guidelines, organizations can build a robust Information Security Management Policy that supports their overall GRC framework. Klever Compliance’s client successes demonstrate that with structured documentation and clear, specific policies, a company can meet regulatory requirements and maintain effective control over its operations.

At Klever Compliance, we transform GRC from a daunting challenge into a valuable asset for your business. Partner with us to achieve seamless governance, risk management, and compliance that makes sense for you. Transform the overwhelming to the empowering.

… article collaboratively written by Katherine Burke & Karina Klever

Karina Klever