ISO/IEC 27001 OPERATIONAL PACKAGE

ISMS Scope · Statement of Applicability · Annex A Mapping · Internal Audit · Management Review


Document ID CERG-PLN-ISO-001
Version 1.0
Status Approved
Classification Public
Owner Governance Pillar Leader
Parent Policy CERG-POL-001 - Cybersecurity Policy
Parent Documents CERG-GOV-CB-001 · CERG-GOV-CMX-001 · CERG-GOV-CAT-001
Supporting Documents CERG-GOV-MAT-001 · CERG-PRC-AUD-001 · CERG-PRC-RM-001 · CERG-PRC-CHG-001 · CERG-STD-AM-001 · CERG-STD-DG-001
Review Cycle Annual / Per ISO audit cycle / On material ISMS scope change
Frameworks ISO/IEC 27001:2022 · ISO/IEC 27002:2022 · NIST CSF 2.0 · NIST 800-53r5
Regulations Cross-cutting; supports customer assurance and certification readiness
Environments ISMS scope selected by the organization; CERG-managed controls and evidence supporting that scope

Table of Contents

  1. Purpose and Scope
  2. ISMS Boundary
  3. ISO 27001 Operating Model
  4. Statement of Applicability
  5. Annex A Mapping
  6. Risk Assessment and Treatment Interface
  7. Internal Audit Program
  8. Management Review Package
  9. Certification and External Audit Interface
  10. Evidence Library
  11. Metrics
  12. Roles and Responsibilities
  13. Regulatory and Framework Alignment Summary
  14. Document Control

1. Purpose and Scope

CERG already aligns many artifacts to ISO/IEC 27001 and ISO/IEC 27002. Alignment is not the same thing as operating an Information Security Management System. An ISO-ready program needs an ISMS scope, a Statement of Applicability, risk treatment linkage, internal audit, management review, corrective actions, and evidence organized for assessors.

This operational package turns the CERG library into an ISO-operable system. It is designed for organizations seeking formal certification, customer-assurance readiness, or disciplined internal operation against ISO/IEC 27001 without immediate certification.

ISO Is a Management System, Not a Control Checklist

Annex A matters, but certification succeeds or fails on the management system: scope, risk treatment, evidence, internal audit, corrective action, and management review. A control may be technically strong and still fail ISO if the organization cannot show why it is in scope, who owns it, how it is reviewed, and what happens when it fails.


2. ISMS Boundary

The ISMS scope statement defines what the ISO program covers. It is approved by the CISO and reviewed at least annually.

Minimum scope fields:

Field Description
Scope Name Name of the ISMS scope.
Business Processes Processes included in the ISMS.
Locations Physical and logical locations included.
Systems and Assets Asset classes and key systems included.
Data Classes Highest data classification processed.
Exclusions Areas not in scope and rationale.
Interfaces Dependencies on third parties, shared services, and adjacent programs.
Regulatory Drivers Customer, contractual, or regulatory reasons for the scope.
Scope Owner Accountable owner.
Approval Date Date approved by the CISO or delegated authority.

A scope exclusion is valid only when it is truthful, documented, and does not hide a control failure. Exclusions are reviewed during internal audit and management review.


3. ISO 27001 Operating Model

ISO Function CERG Mechanism
Context and scope ISMS scope record in this package.
Leadership and policy CERG-POL-001 and CISO governance.
Risk assessment CERG-PRC-RM-001 scoring and risk register.
Risk treatment Risk treatment plans, exceptions, and control ownership.
Controls CERG-GOV-CB-001 and subordinate standards.
Competence and awareness evidence Evidence from the enterprise awareness program where applicable, not owned by CERG.
Communication Governance reporting and management review package.
Documented information CERG-GOV-CAT-001 and evidence library.
Performance evaluation CERG-GOV-MTR-001, CERG-GOV-MAT-001, and internal audit.
Internal audit CERG-PRC-AUD-001 plus the ISO internal audit schedule.
Management review Section 8 of this package.
Nonconformity and corrective action Audit finding workflow and risk register linkage.

4. Statement of Applicability

The Statement of Applicability (SoA) is the authoritative ISO control decision record. It states which Annex A controls apply, why they apply, which CERG artifacts implement them, and whether any control is excluded.

Minimum SoA fields:

Field Description
Annex A Control ID ISO/IEC 27001:2022 Annex A control reference.
Control Title Official or shortened control name.
Applicability Applicable / Not Applicable.
Applicability Rationale Why the control applies or does not apply.
Implementation Status Implemented / Partially Implemented / Planned / Not Implemented.
CERG Control Source CERG artifact and section implementing the control.
Evidence Source Evidence library folder, report, or record.
Control Owner Canonical CERG role or business owner.
Risks Linked Risk-register IDs, if applicable.
Last Reviewed Review date.

A Bad SoA Is Worse Than No SoA

A copied SoA that says every control applies and everything is implemented tells the auditor the program has not done real scoping. A useful SoA makes decisions visible: what applies, what does not, why, who owns it, and what evidence proves the claim.


5. Annex A Mapping

The mapping below is the starting spine. The maintained SoA provides row-level detail.

Annex A Theme CERG Implementation Sources
Organizational controls CERG-POL-001, CERG-GOV-OM-001, CERG-GOV-CB-001, CERG-GOV-RAC-001, CERG-PRC-RM-001, CERG-PRC-AUD-001, CERG-PRC-TPRM-001
People controls Enterprise HR and awareness programs supply evidence; CERG records interfaces where controls affect privileged access, exceptions, and training-dependent control claims.
Physical controls Enterprise physical security supplies evidence; CERG records physical dependencies for data centers, OT, and backup media where applicable.
Technological controls CERG-STD-IT-001, CERG-STD-OT-001, CERG-STD-AC-001, CERG-STD-CFG-001, CERG-STD-LM-001, CERG-STD-RES-001, CERG-STD-CR-001, CERG-STD-SDL-001, CERG-STD-DG-001, CERG-STD-MSG-001, CERG-STD-AI-001

Controls owned outside CERG are not ignored. They are listed in the SoA with the external evidence owner and the CERG dependency clearly stated.


6. Risk Assessment and Treatment Interface

ISO risk treatment uses the CERG risk register rather than a parallel ISO-only risk log. ISO-specific risk requirements are met by ensuring each ISMS-scope risk includes:

  • risk statement;
  • asset or process scope;
  • likelihood, impact, and rating;
  • selected treatment;
  • treatment owner;
  • target date;
  • linked Annex A controls;
  • linked SoA row;
  • residual risk decision;
  • approver;
  • review date.

Risk treatment decisions that leave a control gap use CERG-PRC-RM-001 exception or acceptance workflow.


7. Internal Audit Program

The ISO internal audit program uses CERG-PRC-AUD-001 and adds ISO-specific scope and independence rules.

Minimum audit schedule:

Audit Area Minimum Cadence
ISMS scope and context Annual
SoA accuracy Annual
Risk assessment and treatment Annual
Evidence library and documented information Annual
Selected Annex A controls Risk-based rotation; all applicable themes covered over the certification cycle
Corrective action closure Quarterly until closed

Internal auditors must be independent of the control operation being audited. In small organizations, independence may mean cross-pillar review, external reviewer support, or documented CISO-approved independence constraints.


8. Management Review Package

Management review is held at least annually and before certification or surveillance audits.

Management review package contents:

  1. ISMS scope changes.
  2. Internal audit results.
  3. External audit findings.
  4. Risk posture and material risk changes.
  5. SoA changes and exclusions.
  6. Control performance metrics.
  7. Corrective action status.
  8. Supplier and third-party security issues.
  9. Incident and continuity lessons.
  10. Resource constraints and improvement needs.
  11. Decisions and assigned actions.

Management review minutes are retained as evidence. Decisions that create work become tracked actions, risk-register entries, or cataloged document updates.


9. Certification and External Audit Interface

For certification readiness, Governance maintains an audit pack:

  • ISMS scope statement;
  • information security policy;
  • SoA;
  • risk assessment and treatment records;
  • internal audit schedule and results;
  • management review records;
  • corrective action register;
  • evidence index mapped to Annex A;
  • document catalog and version record;
  • list of exclusions and interfaces owned outside CERG.

External auditor requests are handled through CERG-PRC-AUD-001. Auditor observations that indicate control weakness become findings or risks, not side emails.


10. Evidence Library

Evidence is organized by ISO requirement and by CERG control source.

Folder / Index Contents
01 Scope and Context Scope statement, boundaries, exclusions, interested parties.
02 Policy and Governance Policy, operating model, RACI, catalog.
03 Risk Assessment and Treatment Risk methodology, register extracts, treatment plans, acceptances.
04 Statement of Applicability SoA, change history, rationale records.
05 Annex A Evidence Control evidence indexed by Annex A control.
06 Internal Audit Audit plans, test sheets, findings, corrective actions.
07 Management Review Agendas, decks, minutes, decisions, action register.
08 External Audit Auditor requests, evidence provided, findings, responses.
09 Corrective Actions Nonconformities, root cause, action plans, closure evidence.

11. Metrics

Metric Purpose
Applicable Annex A controls with current owner Measures SoA ownership quality.
Applicable Annex A controls with current evidence Measures audit readiness.
SoA rows reviewed on schedule Measures SoA hygiene.
Open ISO nonconformities by age Measures corrective-action performance.
Internal audits completed on schedule Measures audit program execution.
Risk treatments overdue in ISMS scope Measures risk-treatment discipline.
Management review actions overdue Measures leadership follow-through.
External audit repeat findings Measures systemic weakness.

12. Roles and Responsibilities

Roles below are canonical role names from CERG-GOV-OM-001 §6.1.

Role ISO Responsibility
Governance Pillar Leader Accountable owner for this package, ISMS governance, SoA maintenance, internal audit coordination, and management review package.
Policy & Standards Manager Maintains documented information and updates CERG artifacts that implement ISO controls.
Evidence Librarian Maintains ISO evidence library and audit pack.
Risk Pillar Leader Ensures ISO risk assessment and treatment use the CERG risk process.
Risk Register Owner Maintains risk-register entries, treatments, acceptances, and review dates for ISMS-scope risks.
Engineering Pillar Leader Owns implementation evidence for technical controls.
Vendor Risk Analyst Supplies third-party evidence and supplier-risk inputs.
SOX ITGC Lead Coordinates reusable evidence where ISO and SOX overlap.
CMMC / Federal Compliance Manager Coordinates reusable evidence where ISO and CUI/CMMC overlap.
NERC-CIP Compliance Manager Coordinates reusable evidence where ISO and CIP overlap.
Chief Information Security Officer (CISO) Approves ISMS scope, accepts material residual risk, and chairs or delegates management review.

13. Regulatory and Framework Alignment Summary

Framework Reference Where in This Package
ISO/IEC 27001:2022 Clauses 4 through 10 Sections 2 through 10
ISO/IEC 27001:2022 Annex A Sections 4, 5, 10
ISO/IEC 27002:2022 Control implementation guidance Sections 4, 5, 10
NIST CSF 2.0 GOVERN Sections 2, 3, 8, 11
NIST 800-53r5 Crosswalk source for controls Sections 5, 10
Customer assurance ISO evidence pack Sections 9, 10

14. Document Control

Field Value
Document ID CERG-PLN-ISO-001
Version 1.0
Status Approved
Effective Date 2026-05-22
Classification Public
Owner Governance Pillar Leader
Approved By CISO
Parent Policy CERG-POL-001 - Cybersecurity Policy
Review Cycle Annual; per ISO audit cycle; and on material ISMS scope change
Next Scheduled Review 2027-05-22
Frameworks ISO/IEC 27001:2022; ISO/IEC 27002:2022; NIST CSF 2.0; NIST 800-53r5
Regulations Cross-cutting; supports customer assurance and certification readiness
Environments ISMS scope selected by the organization; CERG-managed controls and evidence supporting that scope

Revision History

Version Date Author Change Summary
1.0 Draft 2026-05-22 Cyber Governance Initial release. Establishes ISMS scope requirements, ISO operating model, Statement of Applicability structure, Annex A mapping, risk-treatment interface, internal audit program, management review package, certification audit interface, evidence library, metrics, and canonical role responsibilities.

Review Triggers

  • Material ISMS scope change
  • ISO certification, surveillance, or recertification audit
  • Material SoA change or control exclusion
  • Major internal audit finding or external nonconformity
  • Management review direction
  • Direction from the CISO

Cyber Governance owns this package. The Governance Pillar Leader is responsible for initiating reviews, managing the revision cycle, and obtaining CISO approval for all changes.

Document ID Relationship
Cybersecurity Policy CERG-POL-001 Parent policy
Unified Control Baseline CERG-GOV-CB-001 Control source for ISO mapping
Compliance Matrix CERG-GOV-CMX-001 Framework crosswalk source
Document Catalog and Naming Convention CERG-GOV-CAT-001 Registers this artifact and the ISO domain
Maturity Self-Assessment and Scorecard CERG-GOV-MAT-001 Maturity evidence and measurement
Audit and Evidence Management Procedure CERG-PRC-AUD-001 Evidence and audit process
Risk Register and Exception Process CERG-PRC-RM-001 Risk treatment and acceptance process
Security Change Management Procedure CERG-PRC-CHG-001 Change-control evidence and corrective action support
Asset Management and Inventory Standard CERG-STD-AM-001 Asset and scope evidence
Data Governance and Classification Standard CERG-STD-DG-001 Information classification and handling evidence

Source: plans/CERG-PLN-ISO-001_ISO_IEC_27001_Operational_Package.md · Download .md · View on GitHub