ISO 27002 Control 5.35: Why Independent Security Reviews Matter
Information security is a core aspect of an organisation’s data governance practices.
So much so, that it’s necessary to eliminate complacency by conducting regular independent reviews of how an organisation manages the people, processes and technologies involved in maintaining an effective information security operation.
Purpose of Control 5.35
Control 5.35 requires organisations to carry out independent reviews of their information security practices – both at planned intervals and when major operational changes occur – to ensure that information security management policies are:
- Adequate – They have the capacity to achieve adherence
- Suitable – They try to achieve the correct goals
- Effective – They work as intended
Attributes Table
Control 5.35 is a preventive and corrective control that maintains risk by creating processes that facilitate regular reviews of an organisation’s information security management practices.
| Control Type | Information Security Properties | Cybersecurity Concepts | Operational Capabilities | Security Domains |
|---|---|---|---|---|
| #Preventive | #Confidentiality | #Identify | #Information Security Assurance | #Governance and Ecosystem |
| #Corrective | #Integrity | #Protect | ||
| #Availability |
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Ownership of Control 5.35
Control 5.35 deals primarily with operational matters. As such, ownership should reside with the COO, or CISO (if present).
General Guidance on Control 5.35
The overarching aim is for management to create and implement processes that cater for independent reviews of their information security practices.
Reviews should focus on any changes that are required to improve an organisation’s approach to information security, including:
- The information security policy.
- Topic-specific policies.
- Related controls.
Any review should be conducted by a person inside or outside the organisation that doesn’t have a vested interest in what they are investigating, such as:
- Internal auditors.
- Independent departmental managers.
- Third-party organisations.
Whoever conducts the review should have the relevant operational competence to make a sound judgement on their findings, and (in the case of internal staff) their job role should not inhibit them from making a valid and legitimate assessment.
The results of the review should be thoroughly recorded, stored and reported to the Manager (or groups of Managers) who requested it, and in certain cases to C-suite level or ownership.
Reviewers should seek to establish whether or not information security practices are compliant with the organisation’s “documented objectives and requirements” stated within the information security policy, or any topic-specific policies.
Alongside periodic reviews, it may be necessary to initiate ad-hoc reviews. These reviews can be justified across 5 key areas:
- Any laws, guidelines or regulations are amended which affect the organisation’s information security operation.
- Major incidents occur that have an impact on information security (data loss, intrusion etc).
- A new business is created, or major changes are enacted to the current business.
- The organisation adopts a new product or service that has information security implications, or makes underlying changes to a current product or service.
- Major changes are made to the organisation’s bank of information security controls, policies and procedures.
Supplementary Guidance
ISO/IEC 27007 and ISO/IEC TS 27008 contain further guidance on the practice of independent reviews.
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Changes and Differences from ISO 27002:2013
27002:2022-5.35 replaces 27002:2013-18.1.2 (Independent review of information security).
27002:2022-5.35 contains the same general guidance as 27002:2013-18.1.2, but goes a step further in stipulating specific examples of when an organisation should carry out ad-hoc reviews, alongside its periodic reviews.
New ISO 27002 Controls
New Controls
| ISO/IEC 27002:2022 Control Identifier | ISO/IEC 27002:2013 Control Identifier | Control Name |
|---|---|---|
| 5.7 | New | Threat intelligence |
| 5.23 | New | Information security for use of cloud services |
| 5.30 | New | ICT readiness for business continuity |
| 7.4 | New | Physical security monitoring |
| 8.9 | New | Configuration management |
| 8.10 | New | Information deletion |
| 8.11 | New | Data masking |
| 8.12 | New | Data leakage prevention |
| 8.16 | New | Monitoring activities |
| 8.23 | New | Web filtering |
| 8.28 | New | Secure coding |
Organisational Controls
People Controls
| ISO/IEC 27002:2022 Control Identifier | ISO/IEC 27002:2013 Control Identifier | Control Name |
|---|---|---|
| 6.1 | 07.1.1 | Screening |
| 6.2 | 07.1.2 | Terms and conditions of employment |
| 6.3 | 07.2.2 | Information security awareness, education and training |
| 6.4 | 07.2.3 | Disciplinary process |
| 6.5 | 07.3.1 | Responsibilities after termination or change of employment |
| 6.6 | 13.2.4 | Confidentiality or non-disclosure agreements |
| 6.7 | 06.2.2 | Remote working |
| 6.8 | 16.1.2, 16.1.3 | Information security event reporting |
Physical Controls
| ISO/IEC 27002:2022 Control Identifier | ISO/IEC 27002:2013 Control Identifier | Control Name |
|---|---|---|
| 7.1 | 11.1.1 | Physical security perimeters |
| 7.2 | 11.1.2, 11.1.6 | Physical entry |
| 7.3 | 11.1.3 | Securing offices, rooms and facilities |
| 7.4 | New | Physical security monitoring |
| 7.5 | 11.1.4 | Protecting against physical and environmental threats |
| 7.6 | 11.1.5 | Working in secure areas |
| 7.7 | 11.2.9 | Clear desk and clear screen |
| 7.8 | 11.2.1 | Equipment siting and protection |
| 7.9 | 11.2.6 | Security of assets off-premises |
| 7.10 | 08.3.1, 08.3.2, 08.3.3, 11.2.5 | Storage media |
| 7.11 | 11.2.2 | Supporting utilities |
| 7.12 | 11.2.3 | Cabling security |
| 7.13 | 11.2.4 | Equipment maintenance |
| 7.14 | 11.2.7 | Secure disposal or re-use of equipment |
Technological Controls
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