Monthly Archives: January 2014

Anti-spam for the CISO

We had a flurry of spam messages get through the mail scrubbers.  The natural response is that the cyber security team should deal.

But, despite vendors selling to the CISO, is spam a CISO issue?

These people think it is

But I am not sure.

Why it is:

  • Er, it’s IT and it needs to be stopped.  Securely

Why it is not

  • Spam, per se, does not affect the integrity of your systems
  • Spam, per se, does not affect the availability of your systems
  • Spam, per se, does not affect the confidentiality of your systems

The effect of someone clicking on  a dodgy link might well be a compromise to your information.  The disclosure of personal details might be a security incident.

But the anti-spam engine not working:  is that really a CISO matter?

ISO 27001 Grinds On

What’s the first step?  

  • Create the manual
  • Create the scope
  • Create the SOA

Write the policies.  There has to be a minimum set.  Here are ones that worked.

  • Information security policy
  • Acceptable use policy
  • Clear desk policy
  • Data policy
  • Password policy
  • Management committee terms of reference
  • System and Asset security procedure
  • Risk assessment procedure
  • Information classification procedure
  • Incident reporting procedure
  • Audit procedure
  • Legislation procedure

And then it’s just the evidence

 

 

Beware the Cloud Subpoena

Cloud’s great, it’s easy and it’s secure … right?

Well, probably, ish. One of the issues that we need to consider is that a competitor could subpoena your cloud service provider to hand your data over to them.  Perhaps your competitor thinks you are breaking a law in their country. Perhaps your competitor can bribe their country’s courts.

Many companies use Salesforce to store highly confidential information. This information is non privileged and is discoverable. Rule 26 of the federal rules of procedure could be used to disclose information to competitors. 

Salesforce say that they will comply with any legal request … 

if we are required to disclose your information by subpoena or in any other due process of law by a properly authorized government agency we would have no other choice but to fully comply

You need to check your contract to see if Salesforce will tell you about it.  Normally they will.

Here’s what facebook do 

http://www.zdnet.com/blog/facebook/heres-what-facebook-sends-the-cops-in-response-to-a-subpoena/11528

The likelihood of a competitor requesting your data is probably pretty low:  most other companies have the same risk.  The first time it happens, I suspect Salesforce’s business model falls. It’s high impact though.

To mitigate this risk:

  • Decide if you can accept the risk of a competitor getting a court order to disclose your data
  • Determine if there is anything in the contract where Salesforce will give you the opportunity to challenge the request.  

The financial advantages outweigh the risks … so continue to use it, but monitor.

IT workers who distrust authority … click on dodgy links

Fascinating research from the dudes at Cambridge

http://bit.ly/KDXTPp

Shows that people who know about IT and distrust authority are the ones to target in your phishing scam … that’s all the sys admins, then.

 

The penetration tester’s low hanging fruit

Once again I commissioned a CHECK penetration test.  Once again we found the usual suspects.

  • Patching not up to date
  • Cross site scripting
  • Weak protocols (FTP, but inside the data centre)
  • Weak cyphers in SSL
  • Weak cyphers in the iLo card
  • SNMP v2
  • Unused protocols open

I could have written the report myself and saved £10K.

 

 

ISO 27001 Why Bother?

It’s a right royal pain to get audited.  So why bother?

Here are some reasons why your business should invest:

  • Certificate on the wall.  Certification is bid candy and supports the bid process.  It helps provide credibility in the company to stakeholders.
  • Customer perception.  Some customers audit the company; having a set of policies and formal certification helps the audit process.
  • Raise the bar internally.  Forcing external certification helps to ensure that some of the basic information security controls are present.  While a 27001-compliant framework could be followed, having an external audit helps to encourage senior management support.
  • Raise the bar with suppliers. Formal certification is a useful lever to ensure that suppliers comply with good security practice, particularly where the contract is weak in this area.
  • Reputation protection. If something goes wrong and information is inappropriately compromised ISO 27001 certification can be one of the mitigation factors to demonstrate proper governance was in place.

All parties recognise that compliance is not security and that simply obtaining certification does not mean that all risks are managed or that information systems are secure.  The position taken is that certification is a small step in the overall information security strategy.

The costs

The company does not have a dedicated budget to secure information systems; its business priorities are not to secure information systems and senior management do not see information security as a top business risk.  The company management has agreed to this certification budget:

  • Annual external audit    £5,000
  • Internal resource             Half FTE
  • Management time          One meeting every two months

ISO 27001 The Horror Show

Lots of movement in the ISO 27001 : 2013 controls, with some new ones.

Fortunately, most of the changes don’t require anyone to actually do anything.

Unfortunately some work is required and some policies will need to be changed.

Here is a list of horrors in the show.

Section Title Text Old Reference Change
5 Information security policies 5 Policy singular
5.1 Management direction for information security Objective: To provide management direction and support for information security in accordance with business requirements and relevant laws and regulations. 5.1
5.1.1 Policies for information security Control A set of policies for information security shall be defined, approved by management, published and communicated to employees and relevant external parties. 5.1.1
5.1.2 Review of the policies for information security Control The policies for information security shall be reviewed at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy and effectiveness. 5.1.2
6 Organization of information security 6
6.1 Internal organization Objective: To establish a management framework to initiate and control the implementation and operation of information security within the organization. 6.1
6.1.1 Information security roles and responsibilities Control All information security responsibilities shall be defined and allocated. 8.1.1
6.1.2 Segregation of duties Control Conflicting duties and areas of responsibility shall be segregated to reduce opportunities for unauthorized or unintentional modification or misuse of the organization’s assets. 10.1.3
6.1.3 Contact with authorities Control Appropriate contacts with relevant authorities shall be maintained. 6.1.6
6.1.4 Contact with special interest groups Control Appropriate contacts with special interest groups or other specialist security forums and professional associations shall be maintained. 6.1.7
6.1.5 Information security in project management Control Information security shall be addressed in project management, regardless of the type of the project. New
6.2 Mobile devices and teleworking Objective: To ensure the security of teleworking and use of mobile devices. 11.7
6.2.1 Mobile device policy Control A policy and supporting security measures shall be adopted to manage the risks introduced by using mobile devices. 11.7.1
6.2.2 Teleworking Control A policy and supporting security measures shall be implemented to protect information accessed, processed or stored at teleworking sites. 11.7.2
7 Human resource security 8
7.1 Prior to employment Objective: To ensure that employees and contractors understand their responsibilities and are suitable for the roles for which they are considered. 8.1
7.1.1 Screening Control Background verification checks on all candidates for employment shall be carried out in accordance with relevant laws, regulations and ethics and shall be proportional to the business requirements, the classification of the information to be accessed and the perceived risks. 8.1.2
7.1.2 Terms and conditions of employment Control The contractual agreements with employees and contractors shall state their and the organization’s responsibilities for information security. 8.1.3
7.2 During employment Objective: To ensure that employees and contractors are aware of and fulfil their information security responsibilities. 8.2
7.2.1 Management responsibilities Control Management shall require all employees and contractors to apply information security in accordance with the established policies and procedures of the organization. 8.2.1
7.2.2 Information security awareness, education and training Control All employees of the organization and, where relevant, contractors shall receive appropriate awareness education and training and regular updates in organizational policies and procedures, as relevant for their job function. 8.2.2
7.2.3 Disciplinary process Control There shall be a formal and communicated disciplinary process in place to take action against employees who have committed an information security breach. 8.2.3
7.3 Termination and change of employment Objective: To protect the organization’s interests as part of the process of changing or terminating employment. 8.3
7.3.1 Termination or change of employment responsibilities Control Information security responsibilities and duties that remain valid after termination or change of employment shall be defined, communicated to the employee or contractor and enforced.
8 Asset management 7
8.1 Responsibility for assets Objective: To identify organizational assets and define appropriate protection responsibilities. 7.1
8.1.1 Inventory of assets Control Assets associated with information and information processing facilities shall be identified and an inventory of these assets shall be drawn up and maintained. 7.1.1
8.1.2 Ownership of assets Control Assets maintained in the inventory shall be owned. 7.1.2
8.1.3 Acceptable use of assets Control Rules for the acceptable use of information and of assets associated with information and information processing facilities shall be identified, documented and implemented. 7.1.3
8.1.4 Return of assets Control All employees and external party users shall return all of the organizational assets in their possession upon termination of their employment, contract or agreement. 8.3.2
8.2 Information classification Objective: To ensure that information receives an appropriate level of protection in accordance with its importance to the organization. 7.2
8.2.1 Classification of information Control Information shall be classified in terms of legal requirements, value, criticality and sensitivity to unauthorised disclosure or modification. 7.2.1
8.2.2 Labelling of information Control An appropriate set of procedures for information labelling shall be developed and implemented in accordance with the information classification scheme adopted by the organization. 7.2.2 Separated
8.2.3 Handling of assets Control Procedures for handling assets shall be developed and implemented in accordance with the information classification scheme adopted by the organization. 7.2.2 Separated
8.3 Media handling Objective: To prevent unauthorized disclosure, modification, removal or destruction of information stored on media. 10.7
8.3.1 Management of removable media Control Procedures shall be implemented for the management of removable media in accordance with the classification scheme adopted by the organization. 10.7.1
8.3.2 Disposal of media Control Media shall be disposed of securely when no longer required, using formal procedures. 10.7.2
8.3.3 Physical media transfer Control Media containing information shall be protected against unauthorized access, misuse or corruption during transportation. 10.8.3
9 Access control 11
9.1 Business requirements of access control Objective: To limit access to information and information processing facilities. 11.1
9.1.1 Access control policy Control An access control policy shall be established, documented and reviewed based on business and information security requirements. 11.1.1
9.1.2 Access to networks and network services Control Users shall only be provided with access to the network and network services that they have been specifically authorized to use. 11.4.1
9.2 User access management Objective: To ensure authorized user access and to prevent unauthorized access to systems and services. 11.2
9.2.1 User registration and de-registration Control A formal user registration and de-registration process shall be implemented to enable assignment of access rights. 11.2.1 Expanded
9.2.2 User access provisioning Control A formal user access provisioning process shall be implemented to assign or revoke access rights for all user types to all systems and services. 11.2.1 Expanded
9.2.3 Management of privileged access rights Control The allocation and use of privileged access rights shall be restricted and controlled. 11.2.2
9.2.4 Management of secret authentication information of users Control The allocation of secret authentication information shall be controlled through a formal management process. 11.2.3
9.2.5 Review of user access rights Control Asset owners shall review users’ access rights at regular intervals. 11.2.4
9.2.6 Removal or adjustment of access rights Control The access rights of all employees and external party users to information and information processing facilities shall be removed upon termination of their employment, contract or agreement, or adjusted upon change. 8.3.3
9.3 User responsibilities Objective: To make users accountable for safeguarding their authentication information. 11.3
9.3.1 Use of secret authentication information Control Users shall be required to follow the organization’s practices in the use of secret authentication information. 11.3.1
9.4 System and application access control Objective: To prevent unauthorized access to systems and applications. 11.5
9.4.1 Information access restriction Control Access to information and application system functions shall be restricted in accordance with the access control policy. 11.6
9.4.2 Secure log-on procedures Control Where required by the access control policy, access to systems and applications shall be controlled by a secure log-on procedure. 11.5.1
9.4.3 Password management system Control Password management systems shall be interactive and shall ensure quality passwords. 11.5.3
9.4.4 Use of privileged utility programs Control The use of utility programs that might be capable of overriding system and application controls shall be restricted and tightly controlled. 11.5.4
9.4.5 Access control to program source code Control Access to program source code shall be restricted. 12.4.3
10 Cryptography 12.3 New level 1 control
10.1 Cryptographic controls Objective: To ensure proper and effective use of cryptography to protect the confidentiality, authenticity and/or integrity of information. 12.3
10.1.1 Policy on the use of cryptographic controls Control A policy on the use of cryptographic controls for protection of information shall be developed and implemented. 12.3.1
10.1.2 Key management Control A policy on the use, protection and lifetime of cryptographic keys shall be developed and implemented through their whole lifecycle. 12.3.2
11 Physical and environmental security 9
11.1 Secure areas Objective: To prevent unauthorized physical access, damage and interference to the organization’s information and information processing facilities. 9.1
11.1.1 Physical security perimeter Control Security perimeters shall be defined and used to protect areas that contain either sensitive or critical information and information processing facilities. 9.1.1
11.1.2 Physical entry controls Control Secure areas shall be protected by appropriate entry controls to ensure that only authorized personnel are allowed access. 9.1.2
11.1.3 Securing offices, rooms and facilities Control Physical security for offices, rooms and facilities shall be designed and applied. 9.1.3
11.1.4 Protecting against external and environmental threats Control Physical protection against natural disasters, malicious attack or accidents shall be designed and applied. 9.1.4
11.1.5 Working in secure areas Control Procedures for working in secure areas shall be designed and applied. 9.1.5
11.1.6 Delivery and loading areas Control Access points such as delivery and loading areas and other points where unauthorized persons could enter the premises shall be controlled and, if possible, isolated from information processing facilities to avoid unauthorized access. 9.1.6
11.2 Equipment Objective: To prevent loss, damage, theft or compromise of assets and interruption to the organization’s operations. 9.2
11.2.1 Equipment siting and protection Control Equipment shall be sited and protected to reduce the risks from environmental threats and hazards, and opportunities for unauthorized access. 9.2.1
11.2.2 Supporting utilities Control Equipment shall be protected from power failures and other disruptions caused by failures in supporting utilities. 9.2.2
11.2.3 Cabling security Control Power and telecommunications cabling carrying data or supporting information services shall be protected from interception, interference or damage. 9.2.3
11.2.4 Equipment maintenance Control Equipment shall be correctly maintained to ensure its continued availability and integrity. 9.2.4
11.2.5 Removal of assets Control Equipment, information or software shall not be taken off-site without prior authorization. 9.2.7
11.2.6 Security of equipment and assets off-premises Control Security shall be applied to off-site assets taking into account the different risks of working outside the organization’s premises. 9.2.5
11.2.7 Secure disposal or reuse of equipment Control All items of equipment containing storage media shall be verified to ensure that any sensitive data and licensed software has been removed or securely overwritten prior to disposal or re-use. 9.2.6
11.2.8 Unattended user equipment Control Users shall ensure that unattended equipment has appropriate protection. 11.3.2
11.2.9 Clear desk and clear screen policy Control A clear desk policy for papers and removable storage media and a clear screen policy for information processing facilities shall be adopted. 11.3.3
12 Operations security 10
12.1 Operational procedures and responsibilities Objective: To ensure correct and secure operations of information processing facilities. 10.1
12.1.1 Documented operating procedures Control Operating procedures shall be documented and made available to all users who need them. 10.1.1
12.1.2 Change management Control Changes to the organization, business processes, information processing facilities and systems that affect information security shall be controlled. 10.1.2
12.1.3 Capacity management Control The use of resources shall be monitored, tuned and projections made of future capacity requirements to ensure the required system performance. 10.3.1
12.1.4 Separation of development, testing and operational environments Control Development, testing, and operational environments shall be separated to reduce the risks of unauthorized access or changes to the operational environment. 10.1.4
12.2 Protection from malware Objective: To ensure that information and information processing facilities are protected against malware. 10.4
12.2.1 Controls against malware Control Detection, prevention and recovery controls to protect against malware shall be implemented, combined with appropriate user awareness. 10.4.1
12.3 Backup Objective: To protect against loss of data. 10.5
12.3.1 Information backup Control Backup copies of information, software and system images shall be taken and tested regularly in accordance with an agreed backup policy. 10.5.1
12.4 Logging and monitoring Objective: To record events and generate evidence. 10.1
12.4.1 Event logging Control Event logs recording user activities, exceptions, faults and information security events shall be produced, kept and regularly reviewed. 10.10.1
12.4.2 Protection of log information Control Logging facilities and log information shall be protected against tampering and unauthorized access. 10.10.3
12.4.3 Administrator and operator logs Control System administrator and system operator activities shall be logged and the logs protected and regularly reviewed. 10.10.4
12.4.4 Clock synchronisation Control The clocks of all relevant information processing systems within an organization or security domain shall be synchronised to a single reference time source. 10.10.6
12.5 Control of operational software Objective: To ensure the integrity of operational systems. 12.4 New level 2
12.5.1 Installation of software on operational systems Control Procedures shall be implemented to control the installation of software on operational systems. 10.4.1
12.6 Technical vulnerability management Objective: To prevent exploitation of technical vulnerabilities. 12.6
12.6.1 Management of technical vulnerabilities Control Information about technical vulnerabilities of information systems being used shall be obtained in a timely fashion, the organization’s exposure to such vulnerabilities evaluated and appropriate measures taken to address the associated risk. 12.6.1
12.6.2 Restrictions on software installation Control Rules governing the installation of software by users shall be established and implemented. 12.5.3 New control
12.7 Information systems audit considerations Objective: To minimise the impact of audit activities on operational systems. 15.3
12.7.1 Information systems audit controls Control Audit requirements and activities involving verification of operational systems shall be carefully planned and agreed to minimise disruptions to business processes. 15.3.1
13 Communications security New level 1 control
13.1 Network security management Objective: To ensure the protection of information in networks and its supporting information processing facilities. 10.6
13.1.1 Network controls Control Networks shall be managed and controlled to protect information in systems and applications. 10.6.1
13.1.2 Security of network services Control Security mechanisms, service levels and management requirements of all network services shall be identified and included in network services agreements, whether these services are provided in-house or outsourced. 10.6.2
13.1.3 Segregation in networks Control Groups of information services, users and information systems shall be segregated on networks. 11.4.5
13.2 Information transfer Objective: To maintain the security of information transferred within an organization and with any external entity. 10.8
13.2.1 Information transfer policies and procedures Control Formal transfer policies, procedures and controls shall be in place to protect the transfer of information through the use of all types of communication facilities. 10.8.1
13.2.2 Agreements on information transfer Control Agreements shall address the secure transfer of business information between the organization and external parties. 10.8.2
13.2.3 Electronic messaging Control Information involved in electronic messaging shall be appropriately protected. 10.8.4
13.2.4 Confidentiality or nondisclosure agreements Control Requirements for confidentiality or non-disclosure agreements reflecting the organization’s needs for the protection of information shall be identified, regularly reviewed and documented. 6.1.5
14 System acquisition, development and maintenance 12
14.1 Security requirements of information systems Objective: To ensure that information security is an integral part of information systems across the entire lifecycle. This also includes the requirements for information systems which provide services over public networks. 12.1
14.1.1 Information security requirements analysis and specification Control The information security related requirements shall be included in the requirements for new information systems or enhancements to existing information systems. 12.1.1
14.1.2 Securing application services on public networks Control Information involved in application services passing over public networks shall be protected from fraudulent activity, contract dispute and unauthorized disclosure and modification. New
14.1.3 Protecting application services transactions Control Information involved in application service transactions shall be protected to prevent incomplete transmission, mis-routing, unauthorized message alteration, unauthorized disclosure, unauthorized message duplication or replay. New
14.2 Security in development and support processes Objective: To ensure that information security is designed and implemented within the development lifecycle of information systems. 12.5
14.2.1 Secure development policy Control Rules for the development of software and systems shall be established and applied to developments within the organization. New
14.2.2 System change control procedures Control Changes to systems within the development lifecycle shall be controlled by the use of formal change control procedures. 12.5.1
14.2.3 Technical review of applications after operating platform changes Control When operating platforms are changed, business critical applications shall be reviewed and tested to ensure there is no adverse impact on organizational operations or security. 12.5.2
14.2.4 Restrictions on changes to software packages Control Modifications to software packages shall be discouraged, limited to necessary changes and all changes shall be strictly controlled. 12.5.3
14.2.5 Secure system engineering principles Control Principles for engineering secure systems shall be established, documented, maintained and applied to any information system implementation efforts. New
14.2.6 Secure development environment Control Organizations shall establish and appropriately protect secure development environments for system development and integration efforts that cover the entire system development lifecycle. New
14.2.7 Outsourced development Control The organization shall supervise and monitor the activity of outsourced system development. 12.5.5
14.2.8 System security testing Control Testing of security functionality shall be carried out during development. New
14.2.9 System acceptance testing Control Acceptance testing programs and related criteria shall be established for new information systems, upgrades and new versions. New
14.3 Test data Objective: To ensure the protection of data used for testing. New
14.3.1 Protection of test data Control Test data shall be selected carefully, protected and controlled. 12.4.2
15 Supplier relationships
15.1 Information security in supplier relationships Objective: To ensure protection of the organization’s assets that is accessible by suppliers. New
15.1.1 Information security policy for supplier relationships Control Information security requirements for mitigating the risks associated with supplier’s access to the organization’s assets shall be agreed with the supplier and documented. New
15.1.2 Addressing security within supplier agreements Control All relevant information security requirements shall be established and agreed with each supplier that may access, process, store, communicate, or provide IT infrastructure components for, the organization’s information. New
15.1.3 Information and communication technology supply chain Control Agreements with suppliers shall include requirements to address the information security risks associated with information and communications technology services and product supply chain. New
15.2 Supplier service delivery management Objective: To maintain an agreed level of information security and service delivery in line with supplier agreements. 10.2
15.2.1 Monitoring and review of supplier services Control Organizations shall regularly monitor, review and audit supplier service delivery. 10.2.2
15.2.2 Managing changes to supplier services Control Changes to the provision of services by suppliers, including maintaining and improving existing information security policies, procedures and controls, shall be managed, taking account of the criticality of business information, systems and processes involved and re-assessment of risks. 10.2.3
16 Information security incident management 13
16.1 Management of information security incidents and improvements Objective: To ensure a consistent and effective approach to the management of information security incidents, including communication on security events and weaknesses. 13.2
16.1.1 Responsibilities and procedures Control Management responsibilities and procedures shall be established to ensure a quick, effective and orderly response to information security incidents. 13.2.1
16.1.2 Reporting information security events Control Information security events shall be reported through appropriate management channels as quickly as possible. 13.1.1
16.1.3 Reporting information security weaknesses Control Employees and contractors using the organization’s information systems and services shall be required to note and report any observed or suspected information security weaknesses in systems or services. 13.1.2
16.1.4 Assessment of and decision on information security events Control Information security events shall be assessed and it shall be decided if they are to be classified as information security incidents. New
16.1.5 Response to information security incidents Control Information security incidents shall be responded to in accordance with the documented procedures. New
16.1.6 Learning from information security incidents Control Knowledge gained from analysing and resolving information security incidents shall be used to reduce the likelihood or impact of future incidents. 13.2.2
16.1.7 Collection of evidence Control The organization shall define and apply procedures for the identification, collection, acquisition and preservation of information, which can serve as evidence. 13.2.3
17 Information security aspects of business continuity management 14
17.1 Information security continuity Objective: Information security continuity shall be embedded in the organization’s business continuity management systems. 14.1
17.1.1 Planning information security continuity Control The organization shall determine its requirements for information security and the continuity of information security management in adverse situations, e.g. during a crisis or disaster. New
17.1.2 Implementing information security continuity Control The organization shall establish, document, implement and maintain processes, procedures and controls to ensure the required level of continuity for information security during an adverse situation. 14.1.3
17.1.3 Verify, review and evaluate information security continuity Control The organization shall verify the established and implemented information security continuity controls at regular intervals in order to ensure that they are valid and effective during adverse situations. 14.1.5
17.2 Redundancies Objective: To ensure availability of information processing facilities. New
17.2.1 Availability of information processing facilities Control Information processing facilities shall be implemented with redundancy sufficient to meet availability requirements. New
18 Compliance 15
18.1 Compliance with legal and contractual requirements Objective: To avoid breaches of legal, statutory, regulatory or contractual obligations related to information security and of any security requirements. 15.1
18.1.1 Identification of applicable legislation and contractual requirements Control All relevant legislative statutory, regulatory, contractual requirements and the organization’s approach to meet these requirements shall be explicitly identified, documented and kept up to date for each information system and the organization. 15.1.1
18.1.2 Intellectual property rights Control Appropriate procedures shall be implemented to ensure compliance with legislative, regulatory and contractual requirements related to intellectual property rights and use of proprietary software products. 15.1.2
18.1.3 Protection of records Control Records shall be protected from loss, destruction, falsification, unauthorized access and unauthorized release, in accordance with legislatory, regulatory, contractual and business requirements. 15.1.3
18.1.4 Privacy and protection of personally identifiable information Control Privacy and protection of personally identifiable information shall be ensured as required in relevant legislation and regulation where applicable. 15.1.4
18.1.5 Regulation of cryptographic controls Control Cryptographic controls shall be used in compliance with all relevant agreements, legislation and regulations. 15.1.6
18.2 Information security reviews Objective: To ensure that information security is implemented and operated in accordance with the organizational policies and procedures. New
18.2.1 Independent review of information security Control The organization’s approach to managing information security and its implementation (i.e. control objectives, controls, policies, processes and procedures for information security) shall be reviewed independently at planned intervals or when significant changes occur. 6.1.8
18.2.2 Compliance with security policies and standards Control Managers shall regularly review the compliance of information processing and procedures within their area of responsibility with the appropriate security policies, standards and any other security requirements. 15.2.1
18.2.3 Technical compliance review Control Information systems shall be regularly reviewed for compliance with the organization’s information security policies and standards. 15.2.2