Clause 6 Planning

Clause 6 Planning

Version: 3.0

Valid until: 2025-04-16

Classification: Low

Version Management


Version

Author(s)

Change(s)

Date approved

1.0

Stefan van Aalst

Edward Robinson

Initiation document

2022-05-20

1.1

Edward Robinson

Additions/changes as part of the periodic review and improvement.


Renamed to Clause 6 Planning from B04 Risk Management. 

2022-12-28

2.0Edward RobinsonAdditions/changes as part of the annual review.

Added link to the Risk & Controls matrix to the Administrations section as per recommendation of the internal auditor.
2023-05-15
3.0
Edward Robinson
Additions/changes as part of the annual review.

Updated links under 6.1.1 and Administrations. Added link to SIA tickets.

Purpose & background


anDREa B.V. (hereafter called anDREa) is committed to protecting the security of its business information in the face of incidents and unwanted events and  has implemented an Information Security Management System (ISMS) that is compliant with ISO/IEC/27001:2017, the international standard for information security.


The purpose of this document is to describe the planning for:

  • the ISMS

  • information risk assessment 

  • information security risk treatment and;

  • how to achieve the information security objectives.


This document will be updated at least annually and when significant change happens.

Objective


The objective of this control is:


  • To plan the risks and opportunities for the ISMS through risk assessment and risk treatment (6.1).

  • To plan for the achievement of information security objectives (6.2).

Scope

The scope of this document is according to Clause 4 Context of the organisation.

Availability

This document is:


  • required reading for:

    • all employees and contractors of anDREa.

  • available for all interested parties as appropriate.

Norm elements

6.1 Actions to address risks and opportunities

6.1.1 General 

“When planning for the information security management system, the organisation shall consider the issues referred to in 4.1 and the requirements referred to in 4.2 and determine the risks and opportunities that need to be addressed to:

  1. ensure the information security management system can achieve its intended outcome(s);

  2. prevent, or reduce, undesired effects; and

  3. achieve continual improvement.

The organisation shall plan:

  1. actions to address these risks and opportunities; and

  2. how to

    1. integrate and implement the actions into its information security management system processes; and

    2. evaluate the effectiveness of these actions.”


anDREa has established an Information Security Management Board (ISMB) who convenes monthly to discuss information security topics (ISMB meeting notes), perform checks and plan tasks and actions to maintain the ISMS (ISMB Action list) and to determine its effectiveness based on effectiveness criteria per policy. 

6.1.2 Information security risk assessment

“The organisation shall define and apply an information security risk assessment process that:

  1. establishes and maintains information security risk criteria that include:

    1. the risk acceptance criteria; and

    2. criteria for performing information security risk assessments;

  2. ensures that repeated information security risk assessments produce consistent, valid and comparable results;

  3. identifies the information security risks:

    1. apply the information security risk assessment process to identify risks associated with the loss of confidentiality, integrity and availability for information within the scope of the information security management system; and

    2. identify the risk owners;

  4. analyses the information security risks:

    1. assess the potential consequences that would result if the risks identified in 6.1.2 c) 1) were to materialise;

    2. assess the realistic likelihood of the occurrence of the risks identified in 6.1.2 c) 1); and

    3. determine the levels of risk;

  5. evaluates the information security risks:

    1. compare the results of risk analysis with the risk criteria established in 6.1.2 a); and

    2. prioritise the analysed risks for risk treatment.

The organisation shall retain documented information about the information security risk assessment process.”


anDREa’s risk assessment is based on the requirements of ISO 31000:2009. 

Baseline security criteria

  • Workspaces and other parts of myDRE must by default only be accessible by and only by authorised people and services

    • Role-based

    • Least-privilege

  • A compromised Workspace cannot spill over to other Workspaces or the core of myDRE

  • Active monitoring and logging must take place to:

    • Demonstrate the above.

    • Have early/fast warning.

    • Trace the cause of an incident.

  • Contingency plans must be in place in order to fast act upon incidents, this must include but should not be limited to:

    • Block a specific user.

    • Shut down a Workspace.

    • Shut down a Subscription.

    • Shut down myDRE.

For context please read anDREa’s Security Manifesto. 


anDREa has two types of risk assessment for information security:

  • The periodic integral risk assessment, in which dependencies and information security risks are determined with respect to the scope as defined in Clause 4 Context of the organisation. This risk assessment is carried out annually and risks are updated/added when changes occur.

  • The specific risk assessment, in which the objective is to identify the information security risks of a change.


Responsibilities


Who

Responsibility

Security Officer.

Coordinate periodic integral risk assessment and specific risk assessment.

Asset Responsibles.

Determine dependencies and vulnerabilities from their point of view.

All employees.

When necessary, the Security Officer will also involve other employees or external parties (stakeholders) in the risk/security impact assessment in order to achieve a better result.


Risk assessment procedure


  • Preparation

  • Dependency analysis

  • Risk assessment/Security Impact Assessment

  • Evaluation

  • Reporting

  • Risk treatment


The Security Officer is responsible for ensuring that all the steps mentioned are carried out correctly and recorded appropriately for the final report of the risk assessment. 


Stage 1: Preparation

1

The Security Officer establishes the scope and purpose of the risk/security impact assessment. It can be an annual integral risk assessment or a specific risk assessment with a defined scope.


In Zoho, a department is created for Security Impact Assessments (SIA). SIAs have their own ticket.

2

The Security Officer determines which aspects of the internal and external context of the organisation are relevant (Clause 4 Context of the organisation) and agrees this with management. 

3

The Security Officer registers (or updates) the overview with:

  • Processes, business assets, processing, data exchanges and their responsibles.


Stage 2: Dependency analysis

1

The Security Officer organises one or more meetings, in which the following persons participate:

  • Security Officer.

  • Asset Responsibles.

  • Process Responsibles.


The Security Officer determines whether the persons below are also necessary, in order to improve the quality of the result:

  • Employees who can provide valuable input.

  • Stakeholders. 

  • External experts.

2

During these meetings, the dependencies and risks within anDREa are detailed. It must be noted whether an application is critical. Moreover, risks should have a score on Confidentiality, Integrity, Availability, Cost and Auditability.

3

The Security Officer updates the overview of company asset dependencies.


Stage 3: Risk assessment

1

Preparation

The Security Officer arranges that at least the following officers can provide input: 

  • Security Officer.

  • Asset Responsibles.

  • Process Responsibles. 


If necessary, the Security Officer involves the following officials/persons:

  • Employees who can provide valuable input.

  • Stakeholders. 

  • External experts.


Providing input is preferably done by meetings.


2

During the workshops or interviews, risks are identified. The Security Officer registers the results. A risk responsible must be assigned to each risk. 

3

Under the Algemene Verordening Gegevensbescherming (AVG), a Data Protection Impact Assessment (DPIA) must be carried out for some changes. This concerns changes that may have an impact on the processing of privacy-sensitive information.


Stage 4: Evaluation

1

Based on the risk acceptance criteria (table below), the Security Officer proposes measures to mitigate risks. The Security Officer defines these measures with the appropriate personnel.


Risks can be dealt with in four ways: 

  1. Accept: no measures. 

  2. Mitigate: Take measures to reduce the probability/impact of the risk.

  3. Avoid: Avoiding the risk altogether.

  4. Deflect: By insuring or outsourcing. 

 

In most cases a risk will be mitigated or accepted. In the field "Why (not) accept?", indicate why you accept or do not accept a risk. In case a risk is avoided or deflected, describe this explicitly here.



Risk acceptance criteria

According to ISO 31000, risk acceptance criteria are established to determine when a risk is acceptable and should be retained, and when it is not acceptable and should be treated. 


anDREa considers the following risk acceptance criteria to be included: 

  • The likelihood or probability of the risk occurring.

  • The potential consequences or impact of the risk if it does occur, most notably on Availability, Integrity, Confidentiality and Auditability.

  • The costs and resources required to implement controls or treatments.

  • The effectiveness of controls or treatments to mitigate the risk.

  • The level of stakeholder acceptance or tolerance for the risk.


anDREa assigns the following classification to the above:

  • Low

  • Medium

  • High


Stage 5: Reporting

1

The Security Officer draws up Risk-Control Matrix.

2

The Management Board adopts the matrix, including the actions to mitigate risks proposed by the Security Officer in consultation with the risk owners. This gives permission for the risk treatment (see Stage 6). For all risks that are accepted, the Management Board must approve the residual risks.

3

The Security Officer discusses with the Management Board whether risks should be communicated to interested parties. If it is decided that this is necessary, it is established which risks are to be communicated to whom and how this is done.


Stage 6: Risk treatment

1

The actions to mitigate risks are included in the Information Security Management Board action list. The aim of these actions is to reduce the chance and/or the impact of a risk, so that the total risk level is lowered to an acceptable level. The Security Officer, possibly in consultation with the Management Board, assigns a Responsible to each action/task. The responsible person draws up a plan in a PBI or ticket. When prioritisation is necessary, for example in connection with available time or budget, this is done on the basis of the criteria below:

  • The level of a linked risk.

  • Achieving quick wins: A lot of results can be achieved with little effort.

  • Available budget.

  • Available staff deployment.

2

The Management Board adopts the plan.

3

The Security Officer periodically checks the progress of the PBI/actions together with the responsible(s). It may be that things change over time, such as the risk level or acceptance criteria, so that the plan has to be adjusted or cancelled. If anDREa decides to do this, it must be recorded in an updated risk assessment report. 

4

After a PBI/action/task has been completed, the new net risk level is determined after determining the effectiveness (evaluation). If this has not yet been done, it will be done in the next risk assessment.


6.1.3 Information security risk treatment

“The organisation shall define and apply an information security risk treatment process to:

  1. select appropriate information security risk treatment options, taking account of the risk assessment results;

  2. determine all controls that are necessary to implement the information security risk treatment option(s) chosen;

NOTE Organizations can design controls as required, or identify them from any source.

  1. compare the controls determined in 6.1.3 b) above with those in Annex A and verify that no necessary controls have been omitted;

NOTE 1 Annex A contains a comprehensive list of control objectives and controls. Users of this International Standard are directed to Annex A to ensure that no necessary controls are overlooked.

NOTE 2 Control objectives are implicitly included in the controls chosen. The control objectives and controls listed in Annex A are not exhaustive and additional control objectives and controls may be needed.

  1. produce a Statement of Applicability that contains the necessary controls (see 6.1.3 b) and c)) and justification for inclusions, whether they are implemented or not, and the justification for exclusions of controls from Annex A;

  2. formulate an information security risk treatment plan; and

  3. obtain risk owners’ approval of the information security risk treatment plan and acceptance of the residual information security risks.

The organisation shall retain documented information about the information security risk treatment process.”


anDREa recognizes that the ISO 27002:2017 standard forms a complete set of measures for the implementation of information security based on best practice and therefore all controls form a logical complete framework where each control supplement and strengthen each other. Since the myDRE delivers a Workspace capable to ingress, process, analyse, and egressing potentially highly (privacy) sensitive data and is not involved in the application of medical care itself, we feel that the ISO 27002 standard forms a better framework for the purpose of information security for myDRE than the NEN 7510 standard.

 

For this reason, the ISO 27002:2017 standard has been chosen for the selection and implementation of controls. This framework is identical to Annex A list of controls from the ISO 27001 standard, therefore by definition requirement 6.1.3c of the ISO 27001:2013 standard is fulfilled.

 

In order to have an overview of all applicable (and non-applicable) controls and justifications, anDREa has established a Statement of Applicability. Moreover, anDREa has created a list of information security risks. Risk treatment plans are discussed during the ISMB meetings and registered in tickets.


6.2 Information security objectives and planning to achieve them

“The organisation shall establish information security objectives at relevant functions and levels.

The information security objectives shall:

  1. be consistent with the information security policy;

  2. be measurable (if practicable);

  3. take into account applicable information security requirements, and results from risk assessment and risk treatment;

  4. be communicated; and

  5. be updated as appropriate.

The organisation shall retain documented information on the information security objectives.

When planning how to achieve its information security objectives, the organisation shall determine:

  1. what will be done;

  2. what resources will be required;

  3. who will be responsible;

  4. when it will be completed; and

  5. how the results will be evaluated.”


anDREa has established an information security policy as described in Clause 5 Leadership and maintains and information security objectives are stipulated by the Security Officer and management in the annual Security Management Report. The list of information security objectives will be updated when appropriate. Planning how to achieve information security objectives is part of the annual Security Management Reports and will be annually reviewed. 

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