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  • EU GDPR (2016)
  • ISO 27001:2022
  • NIS2
  • NIS2 Netherlands (Cbw, 2026)

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SV
Sam de Vries
sam.devries@tidewell-it.example

ISO 27001:2022

Adopted
Addressed: 80 Partially addressed: 22 Unaddressed: 14 Undecided: 5 Excluded: 2

123 requirements, 41 still gaps and nothing analysed yet. Start a guided gap analysis to see where you stand.

137 coverage proposals from other adopted frameworks can be reviewed and accepted here.

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ISO/IEC 27001:2022 reference control set (Annex A). 93 controls grouped into four themes: Organizational, People, Physical, Technological. The body text in this catalog consists of plain-language summaries authored for ISMS, not the verbatim text of the standard. Customers needing the authoritative control text should reference ISO/IEC 27002:2022 from their national standards body (NEN in NL, BSI in UK, ANSI in US, etc.).

Requirement bodies below are plain-language summaries authored by Compliance. For the verbatim text of the standard, reference the publication from your national standards body (NEN, BSI, ANSI, ...).

Management system (30)

4.1 Understanding the organisation and its context

Identify the internal and external issues that affect the organisation's ability to achieve the intended outcomes of its information security management system, and keep that understanding current.

4.2 Understanding the needs and expectations of interested parties

Determine which parties are relevant to the ISMS, what their information security requirements are, and which of those requirements will be addressed through the management system.

4.3 Determining the scope of the information security management system

Define and document the boundaries and applicability of the ISMS, taking account of the context, interested parties, interfaces, and dependencies with other organisations.

4.4 Information security management system

Establish, implement, maintain, and continually improve the ISMS, including the processes needed and their interactions, in line with this standard.

5.1 Leadership and commitment

Top management must demonstrate active leadership for the ISMS: setting direction, ensuring resources, integrating security into business processes, and holding people accountable for results.

5.2 Policy

Top management must establish an information security policy that fits the organisation's purpose, sets objectives or a framework for them, commits to meeting requirements and to continual improvement, and is communicated and available.

5.3 Organisational roles, responsibilities and authorities

Assign and communicate responsibility and authority for the ISMS, including who ensures it conforms to the standard and who reports on its performance to top management.

6.1.1 Actions to address risks and opportunities - general

When planning the ISMS, consider the context and interested-party requirements to determine the risks and opportunities that must be addressed to assure intended outcomes, prevent undesired effects, and drive improvement.

6.1.2 Information security risk assessment

Define and apply a repeatable risk assessment process with clear criteria, that identifies information security risks, their owners, and analyses and evaluates them to produce consistent, comparable results.

6.1.3 Information security risk treatment

Define a risk treatment process that selects appropriate options and controls, compares them against Annex A, produces a Statement of Applicability, formulates a treatment plan, and obtains risk owner approval and acceptance of residual risk.

6.2 Information security objectives and planning to achieve them

Set measurable information security objectives consistent with the policy, plan how to achieve them (what, resources, responsibility, timing, evaluation), and keep documented information about them.

6.3 Planning of changes

When the organisation determines a need to change the ISMS, carry out those changes in a planned manner rather than ad hoc.

7.1 Resources

Determine and provide the resources needed to establish, implement, maintain, and continually improve the ISMS.

7.2 Competence

Determine the competence needed for people whose work affects information security performance, ensure they are competent through education, training, or experience, and retain evidence of it.

7.3 Awareness

Ensure people doing work under the organisation's control are aware of the security policy, their contribution to the ISMS, and the implications of not conforming.

7.4 Communication

Determine the internal and external communications relevant to the ISMS: what to communicate, when, with whom, and how.

7.5.1 Documented information - general

The ISMS must include the documented information required by the standard plus whatever the organisation deems necessary for its effectiveness.

7.5.2 Creating and updating documented information

When creating or updating documented information, ensure appropriate identification, format, and review and approval for suitability and adequacy.

7.5.3 Control of documented information

Control documented information so it is available and suitable where needed and adequately protected, covering distribution, access, storage, version control, retention, and disposal, including documents of external origin.

8.1 Operational planning and control

Plan, implement, and control the processes needed to meet requirements and treat risks, keep documented information to give confidence processes ran as planned, and control planned and unintended changes.

8.2 Information security risk assessment (operational)

Perform information security risk assessments at planned intervals and when significant changes occur, using the defined criteria, and retain the results as documented information.

8.3 Information security risk treatment (operational)

Implement the risk treatment plan and retain documented information on the results of the treatment.

9.1 Monitoring, measurement, analysis and evaluation

Determine what needs monitoring and measuring, by which methods, and when, so the ISMS's security performance and effectiveness can be evaluated, and retain the evidence.

9.2.1 Internal audit - general

Conduct internal audits at planned intervals to confirm the ISMS conforms to the organisation's own requirements and the standard, and that it is effectively implemented and maintained.

9.2.2 Internal audit programme

Plan, establish, and maintain an audit programme, defining criteria and scope, selecting objective auditors, and reporting results to relevant management, with documented evidence retained.

9.3.1 Management review - general

Top management must review the ISMS at planned intervals to ensure it remains suitable, adequate, and effective.

9.3.2 Management review inputs

The management review must consider inputs such as prior action status, changes in context, interested-party needs, performance and audit results, feedback, risk assessment outcomes, and improvement opportunities.

9.3.3 Management review results

The results of the management review must include decisions on continual improvement and any changes needed to the ISMS, and be retained as documented information.

10.1 Continual improvement

Continually improve the suitability, adequacy, and effectiveness of the ISMS.

10.2 Nonconformity and corrective action

React to nonconformities, correct them, evaluate whether corrective action is needed to prevent recurrence, implement and review that action, and retain evidence of the nonconformity and the response.

Organizational (37)

A.5.1 Policies for information security

Establish and maintain a documented information security policy, supported by topic-specific policies, that defines management direction and the organisation's approach to information security. Review periodically and after significant changes.

A.5.2 Information security roles and responsibilities

Clearly define and assign who is responsible for which aspects of information security. Everyone with a stake should know what is expected of them and who to escalate to.

A.5.3 Segregation of duties

Split conflicting tasks across different people so no single person can both perform and conceal a fraud, error, or unauthorised action. Where organisation size makes this impractical, compensate with monitoring or review.

A.5.4 Management responsibilities

Management must actively require personnel and contractors to apply information security in line with policies and procedures, and must visibly support the security program.

A.5.5 Contact with authorities

Maintain documented contacts with relevant authorities (law enforcement, regulators, national CERTs) so the organisation can engage them quickly when an incident or legal matter requires it.

A.5.6 Contact with special interest groups

Maintain contact with security communities, industry groups, and professional bodies to stay current on threats, defences, and best practices.

A.5.7 Threat intelligence

Collect and analyse information about current and emerging information security threats relevant to the organisation, and use what you learn to inform defences.

A.5.8 Information security in project management

Build information security considerations into how projects are planned and run, so security requirements are addressed before delivery rather than retrofitted after.

A.5.9 Inventory of information and other associated assets

Maintain an inventory of information and information-processing assets, with each item having an identified owner accountable for it.

A.5.10 Acceptable use of information and other associated assets

Document and communicate rules for the acceptable use and handling of information and assets so users know what is and is not allowed.

A.5.11 Return of assets

Ensure personnel and external party users return all organisational assets in their possession on termination of employment, contract, or agreement.

A.5.12 Classification of information

Classify information by sensitivity and criticality so handling rules can apply consistently. The classification scheme should reflect legal, regulatory, and business needs.

A.5.13 Labelling of information

Apply labels to information (digital or physical) so its classification is visible and the right handling rules are applied automatically.

A.5.14 Information transfer

Establish rules and controls for transferring information inside the organisation and to external parties, covering electronic, physical, and verbal transfer.

A.5.15 Access control

Define and enforce rules that govern who gets access to which information and other assets, based on business and security requirements.

A.5.16 Identity management

Manage the full lifecycle of identities used by people and systems — creation, modification, removal — so each identity is tied to a real, accountable owner.

A.5.17 Authentication information

Manage authentication information (passwords, keys, tokens) securely throughout its lifecycle: allocation, storage, distribution, rotation, and revocation.

A.5.18 Access rights

Provision, review, modify, and revoke access rights in line with the organisation's access control policy. Reviews should happen periodically and on role change.

A.5.19 Information security in supplier relationships

Identify and document the information security risks associated with supplier relationships, and put processes in place to manage them.

A.5.20 Addressing information security within supplier agreements

Capture the organisation's information security expectations in contracts with suppliers, scaled to the type of access and relationship involved.

A.5.21 Managing information security in the ICT supply chain

Define and manage information security requirements specifically for the ICT supply chain (hardware, software, services) to address risks like tampered components and compromised vendors.

A.5.22 Monitoring, review and change management of supplier services

Regularly monitor, review, and audit supplier security practices and service delivery; manage changes to supplier services so security posture is not degraded over time.

A.5.23 Information security for use of cloud services

Establish processes for acquiring, using, managing, and exiting cloud services in line with the organisation's information security requirements.

A.5.24 Information security incident management planning and preparation

Plan and prepare for managing information security incidents — define roles, processes, communication paths, and decision-making authority before an incident occurs.

A.5.25 Assessment and decision on information security events

Assess reported information security events and decide whether each one should be classified as an incident, with documented criteria for that decision.

A.5.26 Response to information security incidents

Respond to information security incidents according to documented procedures, with appropriate escalation, containment, communication, and recovery steps.

A.5.27 Learning from information security incidents

After incidents, capture lessons learned and feed them back into policies, procedures, and controls to reduce the likelihood and impact of recurrence.

A.5.28 Collection of evidence

Establish procedures for identifying, collecting, acquiring, and preserving evidence related to information security events in a way that is defensible in disciplinary or legal proceedings.

A.5.29 Information security during disruption

Plan how information security is maintained during disruption (outages, crises, recovery) so security does not lapse when the organisation is under stress.

A.5.30 ICT readiness for business continuity

Plan, implement, maintain, and test the ICT readiness needed to meet business continuity objectives and recovery time/point requirements.

A.5.31 Legal, statutory, regulatory and contractual requirements

Identify, document, and keep up to date the legal, statutory, regulatory, and contractual requirements relevant to information security, along with the organisation's approach to meeting them.

A.5.32 Intellectual property rights

Implement procedures to ensure compliance with intellectual property rights — licensing, attribution, restrictions on use — for software and other protected material.

A.5.33 Protection of records

Protect records from loss, destruction, falsification, unauthorised access, and unauthorised release, in line with legal, regulatory, contractual, and business requirements.

A.5.34 Privacy and protection of PII

Identify and meet privacy and personally identifiable information (PII) protection requirements applicable to the organisation, including those imposed by law and regulation.

A.5.35 Independent review of information security

Independently review the organisation's approach to managing information security and its implementation at planned intervals or after significant changes.

A.5.36 Compliance with policies, rules and standards for information security

Verify that information security is being implemented and operated in accordance with the organisation's policies, rules, and applicable standards.

A.5.37 Documented operating procedures

Document operating procedures for information processing activities and make them available to those who need them, so consistent execution is possible across the team.

People (8)

A.6.1 Screening

Perform background verification checks on candidates for employment proportional to the role's access to information and risk, in line with applicable law.

A.6.2 Terms and conditions of employment

Employment contracts should state the employee's and the organisation's responsibilities for information security, so expectations are unambiguous from day one.

A.6.3 Information security awareness, education and training

Provide ongoing awareness, education, and training for all personnel (and relevant external parties) on the organisation's information security policies and their role in upholding them.

A.6.4 Disciplinary process

Establish a formal disciplinary process for personnel who have committed an information security breach, and communicate it so it acts as a deterrent.

A.6.5 Responsibilities after termination or change of employment

Define and enforce information security responsibilities that remain in effect after termination or change of role, and make sure they are communicated at the relevant moments.

A.6.6 Confidentiality or non-disclosure agreements

Use confidentiality or non-disclosure agreements that reflect the organisation's information protection needs, with personnel and relevant external parties, and review them periodically.

A.6.7 Remote working

Implement security measures specific to remote working to protect information accessed, processed, or stored outside the organisation's premises.

A.6.8 Information security event reporting

Provide a clear mechanism for personnel to report observed or suspected information security events promptly, without friction or fear of blame.

Physical (14)

A.7.1 Physical security perimeters

Define and use physical security perimeters to protect areas containing information and information processing facilities.

A.7.2 Physical entry

Protect secure areas with appropriate entry controls so only authorised people can enter, with records of who went where and when.

A.7.3 Securing offices, rooms and facilities

Design and apply physical security measures to offices, rooms, and facilities containing information and information processing assets.

A.7.4 Physical security monitoring

Continuously monitor physical premises for unauthorised access using appropriate detection mechanisms — alarms, surveillance, intrusion detection.

A.7.5 Protecting against physical and environmental threats

Design and implement protection against physical and environmental threats — fire, flood, earthquake, civil unrest — proportional to the risk and the value of the assets at stake.

A.7.6 Working in secure areas

Define and apply security measures for working in secure areas, including supervision of personnel and control of equipment brought in or taken out.

A.7.7 Clear desk and clear screen

Apply clear-desk and clear-screen rules to reduce the risk of unauthorised access to information left visible on desks or on unattended screens.

A.7.8 Equipment siting and protection

Site equipment so it is protected from environmental threats, opportunities for unauthorised observation, and physical interference.

A.7.9 Security of assets off-premises

Protect assets that are taken off-premises (laptops, devices, documents) with measures appropriate to the risks they face outside the secure perimeter.

A.7.10 Storage media

Manage storage media (USB drives, tapes, disks, removable media) throughout their lifecycle — acquisition, use, transport, disposal — with classification-appropriate protection.

A.7.11 Supporting utilities

Protect information processing facilities from disruption caused by failures in supporting utilities — power, cooling, water, telecommunications.

A.7.12 Cabling security

Protect power, data, and telecommunications cabling against interception, interference, or physical damage.

A.7.13 Equipment maintenance

Maintain equipment correctly to ensure continued availability and integrity of information, and protect information when equipment is being serviced (especially by external technicians).

A.7.14 Secure disposal or re-use of equipment

Verify that sensitive data and licensed software has been removed or securely overwritten before equipment is disposed of, sold, or re-used.

Technological (34)

A.8.1 User end point devices

Protect information stored on, processed by, or accessible from user endpoint devices (laptops, mobile devices, workstations) through configuration, policy, and centralised management.

A.8.2 Privileged access rights

Restrict, review, and monitor the allocation and use of privileged access rights — those that grant broader permissions than ordinary users — so they are used only when necessary.

A.8.3 Information access restriction

Restrict access to information and other assets in line with the access control policy, so people can only reach what they need for their role.

A.8.4 Access to source code

Restrict access to program source code, software libraries, and related artefacts to authorised personnel, and manage changes through documented processes.

A.8.5 Secure authentication

Implement secure authentication technologies and procedures appropriate to the sensitivity of what is being protected, including multi-factor authentication where warranted.

A.8.6 Capacity management

Monitor and adjust resource usage so the required system performance, capacity, and availability are sustained as demand evolves.

A.8.7 Protection against malware

Implement layered protection against malware — detection, prevention, recovery, and user awareness — to keep systems and information safe from malicious code.

A.8.8 Management of technical vulnerabilities

Identify, assess, and remediate technical vulnerabilities in systems and software in a timely way, with priority based on risk.

A.8.9 Configuration management

Establish and maintain secure configurations for hardware, software, services, and networks, and manage changes to those configurations under formal control.

A.8.10 Information deletion

Delete information stored in systems, devices, and other media when it is no longer required, using methods appropriate to its classification.

A.8.11 Data masking

Where appropriate, apply data masking techniques (anonymisation, pseudonymisation, tokenisation) to limit exposure of sensitive data — especially in non-production environments.

A.8.12 Data leakage prevention

Apply measures to detect and prevent the unauthorised disclosure or exfiltration of sensitive information from systems, networks, and endpoints.

A.8.13 Information backup

Maintain backups of information, software, and system images, and test restoration regularly to ensure recoverability after loss or corruption.

A.8.14 Redundancy of information processing facilities

Implement redundancy in information processing facilities sufficient to meet availability requirements set by the business.

A.8.15 Logging

Produce, store, and protect logs of events, exceptions, faults, and security-relevant activity, and make sure they are useful for investigation later.

A.8.16 Monitoring activities

Continuously monitor networks, systems, and applications for anomalous behaviour and potential security events, and act on what is detected.

A.8.17 Clock synchronization

Synchronise the clocks of all information processing systems to a reliable time source so logs and events can be correlated accurately across systems.

A.8.18 Use of privileged utility programs

Restrict and tightly control the use of utility programs that could override system or application controls, since they are a frequent vector for abuse.

A.8.19 Installation of software on operational systems

Implement procedures to control the installation of software on operational systems, including approval workflows and limits on who can install what.

A.8.20 Networks security

Manage and control networks to protect the information in systems and applications connected to them.

A.8.21 Security of network services

Define and document the security mechanisms, service levels, and management requirements of all network services, whether provided internally or externally.

A.8.22 Segregation of networks

Segregate networks into separate groups (by service, user community, sensitivity) and control traffic between them with rules appropriate to each segment.

A.8.23 Web filtering

Manage access to external websites to reduce exposure to malicious content and unwanted services.

A.8.24 Use of cryptography

Define and implement rules for the effective use of cryptography, including cryptographic key management, for protecting information confidentiality, integrity, and authenticity.

A.8.25 Secure development life cycle

Establish and apply rules for secure software and systems development across the entire development lifecycle, not just at security review gates.

A.8.26 Application security requirements

Identify, specify, and approve information security requirements for new or modified applications before development or acquisition begins.

A.8.27 Secure system architecture and engineering principles

Establish, document, and apply secure architecture and engineering principles to the design and implementation of information systems.

A.8.28 Secure coding

Apply secure coding principles and standards during software development to reduce the introduction of vulnerabilities.

A.8.29 Security testing in development and acceptance

Include security testing in development and acceptance processes so vulnerabilities are caught before software reaches production.

A.8.30 Outsourced development

When outsourcing software development, define and enforce the security requirements that apply to the development activity and its outputs, and verify they are met.

A.8.31 Separation of development, test and production environments

Keep development, test, and production environments separated to reduce the risk of unauthorised access or unintended changes affecting production.

A.8.32 Change management

Subject changes to information processing facilities and systems to formal change management processes that control the risk of unintended consequences.

A.8.33 Test information

Select and protect test data carefully; avoid using real personal data in non-production environments unless adequately masked or otherwise protected.

A.8.34 Protection of information systems during audit testing

Plan and agree audit tests of operational systems with management to minimise disruption to business processes during the test.

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