ISO/IEC TR 27008:2011 Information technology — Security techniques — Guidelines for auditors on information security controls
This standard (actually a “technical report”) on “technical auditing” complements ISO/IEC 27007. It concentrates on auditing the information security controls - or rather the “technical controls” (as in IT security or cybersecurity controls), whereas ’27007 concentrates on auditing the management system elements of the ISMS.
This standard provides guidance for all auditors regarding “information security management systems controls” [sic] selected through a risk-based approach (e.g. as presented in a statement of applicability) for information security management. It supports the information security risk management process and internal, external and third-party audits of an ISMS by explaining the relationship between the ISMS and its supporting controls. It provides guidance on how to verify the extent to which required “ISMS controls” are implemented. Furthermore, it supports any organization using ISO/IEC 27001 and ISO/IEC 27002 to satisfy assurance requirements, and as a strategic platform for information security governance.
Purpose and justification
Is applicable to all organizations, including public and private companies, government entities and not-for-profit organizations and organizations of all sizes regardless of the extent of their reliance on information;
Supports planning and execution of ISMS audits and the information security risk management process;
Further adds value and enhances the quality and benefit of the ISO27k standards
by closing the gap between reviewing the ISMS in theory and, when needed, verifying evidence of implemented ISMS controls (e.g
. in the ISO27k user organizations, assessing security elements of business processes, IT systems and IT operating environments);
Provides guidance for auditing information security controls based on the controls guidance in ISO/IEC 27002
Improves ISMS audits by optimizing the relationships between the ISMS processes and required controls (e.g. mechanisms to limit the harm caused by failures in the protection of information - erroneous financial statements, incorrect documents issued by an organization and intangibles such as reputation and image of the organization and privacy, skills and experience of people);
Supports an ISMS-based assurance and information security governance approach and audit thereof [?? That would appear to stray into the area of management systems auditing rather than information security controls or technical auditing];
Ensures effective and efficient use of audit resources.
Whereas ISO/IEC 27007 focuses on auditing the management system elements of an ISMS as described in ISO/IEC 27001, ISO/IEC TR 27008 focuses on checking some of the information security controls themselves, such as (for example) those as described in ISO/IEC 27002 and outlined in Annex A of ISO/IEC 27001.
’27008 “focuses on reviews of information security controls, including checking of technical compliance, against an information security implementation standard, which is established by the organization. It does not intend to provide any specific guidance on compliance checking regarding measurement, risk assessment or audit of an ISMS as specified in ISO/IEC 27004, 27005 or 27007 respectively.”
Technical compliance checking/auditing is explained as a process of examining “technical” security controls, interviewing those associated with the controls (managers, technicians, users etc.), and testing the controls. The methods should be familiar to experienced IT auditors.
“Technical controls”, while not explicitly defined in the standard, appear to be what are commonly known as IT security or cybersecurity controls, in other words a subset of the information security controls described in ISO/IEC 27001 and especially 27002.
Status of the standard
The standard was published in November 2011 as ISO/IEC TR 27008:2011, a “Type 2” Technical Report, rather than an International Standard (a curiosity of the ISO approach). Minor but numerous grammatical and technical errors in the standard, as well as its limited scope, may have hampered its adoption.
The standard is being revised to reflect the 2013 versions of ISO/IEC 27001 and 27002. It is currently at WD stage with substantial inputs received, and most comments accepted. A new title has been proposed: Guidelines for the assessment of information security controls.
While this standard is not intended to be used by accredited ISMS certification bodies, some people are concerned about its potential impact on ISO/IEC 27001 certification audits. Certification against ISO/IEC 27001 requires certification auditors to assess the organization’s ISMS as a whole for compliance with the standard, but not necessarily to delve into the information security controls themselves. They review the management system in much the same way that ISO 9000 auditors review an organization’s management system for quality assurance. Some of us feel that this leaves an assurance gap: it is conceivable for an organization to implement an ISMS ‘on paper’ but to ignore significant elements of its security policies, standards, procedures and guidelines in practice, perhaps arbitrarily declaring a narrow scope and minimal Statement of Applicability. Others insist that certification auditors do normally substantiate the existence of information security controls as well as the management system controls, at least to some extent (how much being a moot point). While compliance activities operating within a certified ISMS should address this, competently auditing the information security controls can provide greater confidence that theory matches reality, and might boost the credibility of ISO/IEC 27001 certificates. Unfortunately, such an approach would cause practical problems for those certification bodies suffering a shortage of competent IT auditors.
The mention of ‘technical compliance auditing’ in this standard always catches my beady eye. Personally, I wish the standard did not mention the keyword compliance at all, since it is generally misinterpreted to mean tick-and-bash audits in which the auditors’ prime objective is allegedly to search for and report noncompliance. That’s clearly a very negative style of auditing, with a very limited purpose. It fails to take account of the limited applicability of many requirements, for instance, leaves little if any room for interpretation of the requirements in the specific situations under review, and implies that compliance per se is sufficient whereas it seldom is in practice. In summary, compliance implies a low bar. We can and should do better than that in respect of protecting information assets. Competent IT auditors can certainly achieve much more than pointing a stick at noncompliance!
Frankly, there are much better guides to IT auditing, or indeed technical compliance auditing, than ISO/IEC TR 27008, such as the IT audit FAQ, COBIT and other materials from ISACA, and various other sources. I am pleased to see ISACA’s experts wading-in to the ISO/IEC project with similar comments concerning the scope, purpose and value of IT auditing, suggesting that ‘technical compliance testing’ isn’t actually auditing at all! At the same time, some national bodies are suggesting that ‘technical compliance testing’ (whatever that actually means - and personally I’m not certain that any of us really know) is what the standard should cover, even if that means dropping all references to audit.
Personally, I would prefer to see the standard cover auditing of information security controls, that being, to my mind, the entire spectrum including technical and non-technical (e.g. procedural, personnel, procurement, incident management, incident response, compliance, awareness, enforcement, reinforcement, physical, legal, business continuity, resilience, recovery, contingency and more) apart from the management system and governance aspects. It’s about time SC 27 came off the fence and acknowledged that information security goes well beyond ICT. With a few exceptions (e.g. business continuity, cloud), ISO/IEC 27002 does a fair job of describing the entire spectrum, and (since users could extend the scope of their audits as they see fit) would be a reasonable basis for the scope of an information security controls auditing standard. It could describe the audits, reviews and assessments that ought to be performed as an integral part of the operation of the ISMS, on a routine and ad hoc basis, for instance a rolling quarterly sequence of checks on the controls covering a different quarter each time, plus post-incident reviews and other ad hoc activities to find root causes of issues that should be addressed.