A. I will check the other data centres are treated as external providers, even though they are part of the same telecommunication group. This is appropriate because clause 8.1.4 of ISO 27001:2022 requires the organisation to ensure that externally provided processes, products or services that are relevant to the information security management system are controlled. Externally provided processes, products or services are those that are provided by any external party, regardless of the degree of its relationship with the organisation. Therefore, the other data centres within the same telecommunication group should be treated as external providers and subject to the same controls as any other external provider12
B. I will ensure external providers have a documented process in place to notify the organisation of any risks arising from the use of its products or services. This is appropriate because clause 8.1.4 of ISO 27001:2022 requires the organisation to implement appropriate contractual requirements related to information security with external providers. One of the contractual requirements could be the obligation of the external provider to notify the organisation of any risks arising from the use of its products or services, such as security incidents, vulnerabilities, or changes that could affect the information security of the organisation. The external provider should have a documented process in place to ensure that such notification is timely, accurate, and complete12
E. I will ensure the organisation is regularly monitoring, reviewing and evaluating external provider performance. This is appropriate because clause 8.1.4 of ISO 27001:2022 requires the organisation to monitor, review and evaluate the performance and effectiveness of the externally provided processes, products or services. The organisation should have a process in place to measure and verify the conformity and suitability of the external provider’s deliverables and activities, and to provide feedback and improvement actions as necessary. The organisation should also maintain records of the monitoring, review and evaluation results12
F. I will ensure the organisation has determined the need to communicate with external providers regarding the ISMS. This is appropriate because clause 7.4.2 of ISO 27001:2022 requires the organisation to determine the need for internal and external communications relevant to the information security management system, including the communication with external providers. The organisation should define the purpose, content, frequency, methods, and responsibilities for such communication, and ensure that it is consistent with the information security policy and objectives. The organisation should also retain documented information of the communication as evidence of its implementation12
The following activities are not appropriate for the assessment of external providers according to ISO 27001:2022:
C. I will ensure that the organisation has a reserve external provider for each process it has identified as critical to preservation of the confidentiality, integrity and accessibility of its information. This is not appropriate because ISO 27001:2022 does not require the organisation to have a reserve external provider for each critical process. The organisation may choose to have a contingency plan or a backup solution in case of failure or disruption of the external provider, but this is not a mandatory requirement. The organisation should assess the risks and opportunities associated with the external provider and determine the appropriate treatment options, which may or may not include having a reserve external provider12
D. I will limit my audit activity to externally provided processes as there is no need to audit externally provided products or services. This is not appropriate because clause 8.1.4 of ISO 27001:2022 requires the organisation to control the externally provided processes, products or services that are relevant to the information security management system. Externally provided products or services may include software, hardware, data, or cloud services that could affect the information security of the organisation. Therefore, the audit activity should cover both externally provided processes and products or services, as applicable12
G. I will ensure that top management have assigned roles and responsibilities for those providing external ISMS processes as well as internal ISMS processes. This is not appropriate because clause 5.3 of ISO 27001:2022 requires the top management to assign the roles and responsibilities for the information security management system within the organisation, not for the external providers. The external providers are responsible for assigning their own roles and responsibilities for the processes, products or services they provide to the organisation. The organisation should ensure that the external providers have adequate competence and awareness for their roles and responsibilities, and that they are contractually bound to comply with the information security requirements of the organisation12
H. I will ensure that the organisation ranks its external providers and allocates the majority of its work to those providers who are rated the highest. This is not appropriate because ISO 27001:2022 does not require the organisation to rank its external providers or to allocate its work based on such ranking. The organisation may choose to evaluate and compare the performance and effectiveness of its external providers, but this is not a mandatory requirement. The organisation should select and use its external providers based on the information security criteria and objectives that are relevant to the organisation12
References:
1: ISO/IEC 27001:2022 Lead Auditor (Information Security Management Systems) Course by CQI and IRCA Certified Training 1 2: ISO/IEC 27001 Lead Auditor Training Course by PECB 2
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