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ISMS framework in ISO 27001

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This curriculum spans the full lifecycle of an ISO 27001 ISMS implementation and maintenance, comparable in breadth and operational detail to a multi-phase advisory engagement supporting organizations through governance setup, certification, and ongoing compliance.

Module 1: Establishing Governance Structure and Executive Sponsorship

  • Define roles and responsibilities for the Information Security Steering Committee, including representation from legal, IT, risk, and business units.
  • Secure formal sign-off from executive leadership on the ISMS scope, objectives, and resource allocation.
  • Develop a governance charter that outlines decision-making authority, escalation paths, and meeting cadence for security governance forums.
  • Align ISMS objectives with corporate risk appetite statements approved by the board or senior management.
  • Integrate ISMS reporting into existing enterprise risk and compliance dashboards used by executives.
  • Establish accountability for information asset ownership across business departments, including data classification responsibilities.
  • Document and socialize escalation procedures for material security incidents or control failures to executive stakeholders.
  • Conduct quarterly governance reviews to assess ISMS performance against strategic business goals.

Module 2: Defining Scope and Boundary of the ISMS

  • Map all business-critical systems, data flows, and third-party dependencies to determine inclusion within the ISMS boundary.
  • Document justifications for excluding specific departments, systems, or geographic locations from the ISMS scope.
  • Validate scope completeness with internal audit and external regulators during pre-certification assessments.
  • Define interface controls for systems operating outside the ISMS boundary but interacting with in-scope assets.
  • Update scope documentation when mergers, divestitures, or cloud migration impact the control environment.
  • Obtain written approval from the CISO and business unit heads on the final scope statement.
  • Ensure physical and logical boundaries are reflected in network diagrams and asset inventories.
  • Maintain a register of scope exclusions with risk acceptance rationale signed by risk owners.

Module 3: Risk Assessment and Treatment Planning

  • Select a risk assessment methodology (e.g., qualitative vs. quantitative) aligned with organizational risk culture and regulatory requirements.
  • Define and standardize risk criteria, including likelihood and impact scales, approved by the risk committee.
  • Conduct asset-based threat modeling for high-value systems using STRIDE or PASTA frameworks.
  • Facilitate cross-functional risk workshops with business process owners to identify and validate threats and vulnerabilities.
  • Document risk treatment decisions for each identified risk: mitigate, accept, transfer, or avoid.
  • Ensure risk treatment plans include specific owners, timelines, and required resources for implementation.
  • Integrate risk treatment progress tracking into project management tools used by IT and security teams.
  • Review and revalidate risk assessments annually or after significant changes to business processes or IT infrastructure.

Module 4: Statement of Applicability (SoA) Development

  • Review all 93 controls in ISO/IEC 27001 Annex A to determine applicability based on risk assessment outcomes.
  • Document justification for excluding any control, including risk treatment decisions and compensating controls.
  • Map each applicable control to responsible roles, existing policies, and technical implementations.
  • Align SoA content with regulatory requirements such as GDPR, HIPAA, or PCI-DSS where applicable.
  • Obtain formal sign-off on the SoA from the CISO and internal audit function.
  • Integrate SoA updates into change management processes to reflect new controls or decommissioned systems.
  • Use the SoA as a baseline for internal audit testing and external certification assessments.
  • Maintain version control and change history for the SoA to support compliance evidence retention.

Module 5: Policy Framework Design and Maintenance

  • Develop a tiered policy structure: high-level policies, standards, guidelines, and procedures aligned with ISO 27001 requirements.
  • Assign policy ownership to business or functional leaders with accountability for compliance and review cycles.
  • Define policy review intervals (e.g., annual) and integrate them into governance meeting agendas.
  • Ensure policies are accessible, searchable, and enforceable across global operations and remote work environments.
  • Map policy requirements to technical controls in identity management, endpoint security, and network infrastructure.
  • Integrate policy exception management with change control and risk acceptance processes.
  • Conduct policy awareness assessments to validate understanding among employees and contractors.
  • Automate policy distribution and attestation workflows using GRC or HR information systems.

Module 6: Internal Audit and Compliance Monitoring

  • Develop an annual audit plan based on risk ranking of business processes and control maturity.
  • Ensure auditors have no conflict of interest and are independent from the functions they assess.
  • Define audit checklists aligned with ISO 27001 control objectives and the organization’s SoA.
  • Conduct sample testing of control effectiveness, including user access reviews and change management logs.
  • Document audit findings with root cause analysis and assign corrective action owners with deadlines.
  • Track remediation progress using a centralized issue register with escalation for overdue items.
  • Report audit results to the Information Security Steering Committee and executive management.
  • Coordinate internal audit schedules with external certification audits to avoid duplication.

Module 7: Management Review and Continuous Improvement

  • Prepare management review inputs including audit results, security incidents, risk treatment status, and compliance metrics.
  • Schedule quarterly management review meetings with attendance from CISO, business leads, and risk officers.
  • Document decisions on resource allocation, policy changes, or scope adjustments from management reviews.
  • Track action items from management reviews using a formal register with closure verification.
  • Assess effectiveness of the ISMS using KPIs such as mean time to remediate findings or percentage of controls in place.
  • Update the risk assessment and SoA based on management review outcomes and emerging threats.
  • Integrate feedback from internal and external auditors into ISMS improvement initiatives.
  • Ensure minutes of management reviews are retained as evidence for certification audits.

Module 8: Third-Party and Supply Chain Risk Management

  • Classify third parties based on data access, criticality, and risk exposure to determine assessment depth.
  • Include ISO 27001 compliance requirements in procurement contracts and service level agreements.
  • Conduct due diligence reviews using standardized questionnaires aligned with ISO 27001 controls.
  • Require third parties with access to sensitive data to provide audit reports (e.g., SOC 2, ISO 27001 certificate).
  • Implement ongoing monitoring of third-party compliance through periodic reviews or automated tools.
  • Define incident notification and response coordination procedures with critical vendors.
  • Enforce segregation of duties and least privilege in third-party access to internal systems.
  • Conduct exit reviews when terminating third-party relationships to ensure data deletion and access revocation.

Module 9: Certification Audit Preparation and Execution

  • Select an accredited certification body and agree on audit scope, timeline, and evidence requirements.
  • Conduct a pre-certification gap assessment to validate control implementation and documentation completeness.
  • Compile evidence dossiers including policies, audit reports, training records, and risk treatment plans.
  • Assign evidence custodians to ensure timely response to auditor requests during on-site assessments.
  • Prepare staff for auditor interviews by conducting mock sessions focused on control ownership and procedures.
  • Address nonconformities raised during Stage 1 audit before proceeding to Stage 2.
  • Coordinate facility access, system demonstrations, and log reviews for auditors during on-site visits.
  • Develop a corrective action plan for any major or minor nonconformities identified in the Stage 2 audit.

Module 10: Maintaining Certification and Ongoing Governance

  • Schedule annual surveillance audits with the certification body and assign internal coordination leads.
  • Update ISMS documentation to reflect organizational changes, new systems, or revised risk profiles.
  • Reassess risks and adjust controls in response to emerging threats or changes in business operations.
  • Conduct internal audits at least annually to verify continued compliance with ISO 27001 requirements.
  • Perform management reviews at least annually, or more frequently if significant incidents occur.
  • Track and renew certification documentation before expiration, including payment and audit scheduling.
  • Integrate ISMS maintenance tasks into existing operational routines to reduce overhead.
  • Monitor changes to ISO 27001 standards or regulatory requirements that may impact the ISMS.