Technical vulnerabilities that have the potential to impact PII and privacy-related assets are almost impossible to completely eradicate, regardless of budget, staffing levels or expertise.
As such, ISO requires organisations to operate with a robust set of vulnerability management controls that both identify potential technical vulnerabilities, and provide clear guidance on the remedial action required to mitigate any commercial, operational or reputational damage.
ISO 27001 6.9.6 contains two sub-clauses that deal with the topic of vulnerability management, split between technical management, and how organisations should consider software installations:
Neither sub-clause contains any PIMS or PII-specific guidance, nor are there any UK GDPR implications to consider.
Organisations should obtain an up-to-date list of all assets (see Controls 5.9 and 5.14) that are owned and operated by the organisation, including:
When identifying vulnerabilities that have the potential to impact upon PII and privacy protection, organisations should:
Organisations should develop policies and procedures (including automatic updates) that detect vulnerabilities across all its products and services, and receive vulnerability assessments relating to the supply of said products and services.
ISO advises organisations to make a public effort to track down any vulnerabilities – including the use of structured bounty programs – and use forums and public research activity to raise awareness of potential exploits and security issues.
If, following a security incident, remedial action has been taken that could in any way affect customers (or their perception of the data held), organisations should consider engaging with certified security specialists to distribute information about attack vectors.
Throughout the process of evaluating vulnerabilities, organisations should:
When addressing vulnerabilities after they have been identified, organisations should:
If an update is not forthcoming, and remedial action is prevented by external factors, organisations should:
An audit trail should be kept of all relevant vulnerability management activities, and the organisation’s vulnerability management process should be reviews to ensure it is both fit for purpose, and meets the growing needs of the organisation.
Where cloud-based software is concerned, the organisation should ensure that the service provider’s stance towards vulnerability management is aligned with its own. Organisations should seek to obtain written confirmation of any responsibilities via a binding service agreement (see ISO 27002 Control 5.32).
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In order to protect the availability and integrity of PII, and administer change, organisations should:
When utilising vendor-supplied software, applications should be kept in good working order and in accordance with the issuers guidelines.
ISO makes it explicitly clear that organisations should avoid using unsupported software unless absolutely necessary. Organisations should seek to upgrade incumbent systems, rather than use out-of-date or unsupported legacy applications.
A vendor may require access to an organisation’s network in order to perform an installation or update. Such activities should be authorised and monitored at all times (see ISO 27002 Control 5.22).
ISO 27701 Clause Identifier | ISO 27701 Clause Name | ISO 27002 Control | Associated GDPR Articles |
---|---|---|---|
6.9.6.1 | Management of Technical Vulnerabilities | 8.8 – Management of Technical Vulnerabilities for ISO 27002 | None |
6.9.6.2 | Restriction on Software Installation | 8.19 – Installation of Software on Operational Systems for ISO 27002 | None |
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