How do we…
How do we get the top management commitment and resources an ISO 27001 project needs?
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The short answer
- Recommendation
- Take one approval paper to top management before the risk assessment starts: the scope, the policy direction and the resources, with a named sponsor and ISMS manager. Minute the decision, then keep top management in the monthly reports, the objectives and the management review.
- Reasoning
- The pack's first rule is that top management approves the scope, the policy and the resources before the project starts, and the next phase does not begin until that evidence exists. An ISMS is a management system: approvals, objectives, resources and the review belong to top management. An auditor who finds nobody at the top able to describe the objectives or the last review's decisions will doubt the commitment, whatever the paperwork says.
- Considerations
- Top management means the board or a committee it has delegated to, the management board in a two-tier structure, or executive management where there is no board.
- Effort and cost figures are the pack's defaults for an organisation of 100 to 300 people. Replace them with your own estimates and real quotes before the paper goes up.
- Internal effort is usually larger than every external cost together, so budget it as time released from other work.
- The standard's text is paywalled. The duties here come from the pack and public guides, so confirm what evidence your certification body accepts.
The decision, step by step
Select any step for the reasoning behind it and where the pack covers it.
- Start
- Step
- Decision
- Outcome
- Loop back
Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.
Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.
Read as text
The same flow written out: each step, its reasoning and where the pack covers it. 19 steps.
Start
We need top management behind our ISO 27001 project
The pack's first rule is that top management approves the scope, the policy and the resources before the project starts. This is the first gate, and the next phase does not begin until its evidence exists. Auditors test it later by asking top management, not the ISMS manager.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanThe rules (rule IS-01)
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPhase 1 — Decide and scope (3 weeks)
Decision
Can you say in one paragraph why you want the certificate?
The reason sets the scope and the date: which customers, tenders or regulators will read the certificate, and by when. The pack says to ask the sponsor to write one paragraph and not to start without it. If you cannot write it, answer no.
- Yes: Is there an executive sponsor who can secure people and money?
- No, or not known: Ask the sponsor to write the reason down
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanInputs
Step
Ask the sponsor to write the reason down
Without a stated reason the scope has no test to pass and the date has no basis. If a customer, tender or regulator has set a deadline, write it down too and plan back from it, then tell top management at the first gate whether the plan meets it.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanInputs
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPurpose
Decision
Is there an executive sponsor who can secure people and money?
The sponsor secures people and money, clears blockers, takes decisions to top management and decides when the Stage 2 date moves. The pack's default effort is one to two hours a month plus the approvals at each gate. If nobody holds this role, answer no.
- Yes: Name the ISMS manager and the control owners, with their time
- No, or not known: Name a sponsor with authority over the budget
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanRoles and effort
Step
Name a sponsor with authority over the budget
Ask the person who can release money and people to take the role, or ask top management to appoint one. A project run only from the security team has nobody to settle a clash over time or cost.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanRoles and effort
Step
Name the ISMS manager and the control owners, with their time
Name people, not roles, in the plan. The pack's defaults are half to full time for the ISMS manager for the length of the project, and one to three days a month for each control owner while controls are being put in place. In a small organisation one person may hold two roles.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanRoles and effort
Step
Cost the project from quotes and your own effort estimate
Cost the scope you have drafted, because audit days and effort follow its size. Internal effort is usually larger than every external cost together. Budget it as time released from other work or the project slips. Indicative quotes from at least two accredited certification bodies are enough at this point (“How do we choose a certification body and agree our audit dates?” covers choosing one). Ask for days per stage, and include the surveillance audits in years two and three, because the certificate lapses without them.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanWhat it costs
- P08-A02 ISO 27001 Implementation Methodology & Project PlanLimitations
Decision
Is the scope drafted and tested against the services customers buy?
Top management approves the scope, so it must exist as a draft that names the organisation, locations, services, interfaces and any exclusion with its reason. If you have not drafted it, or are not sure it passes the tests, answer no.
- Yes: Cost the project from quotes and your own effort estimate
- No, or not known: Draft the scope first
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanTests a scope should pass
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPhase 1 — Decide and scope (3 weeks)
Step
Draft the scope first
The scope decides the size of everything else, so settle it before you ask for resources. A scope that is too wide multiplies the work. One that is too narrow produces a certificate customers do not value.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanScoping decisions
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPrinciples
Step
Take one approval paper to top management
Put three decisions in it: the scope with what it leaves out; the direction of the policy, a half-page saying what the policy will commit to (“How do we write an information security policy and objectives that stand up to an ISO 27001 audit?” covers the wording); and the people, time and money. Add the plan's gates and the forecast date, and say plainly if the forecast misses a customer's deadline. Ask for a decision at the meeting, not a note of interest.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPhase 1 — Decide and scope (3 weeks)
- P08-A02 ISO 27001 Implementation Methodology & Project PlanThe rules (rule IS-01)
Decision
Did top management approve the scope, policy direction and resources?
All three are needed before the risk work starts. The direction of the policy is the half-page of commitments, not the finished policy. If only some were approved, or the approval is not minuted, the next phase should not start. Answer no for a partial or unrecorded approval.
- Yes: Agree what top management does after the start
- No, or not known: Change the ask: add resource, narrow the scope or move the date
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPhase 1 — Decide and scope (3 weeks)
- P08-A02 ISO 27001 Implementation Methodology & Project PlanEvidence to have ready
Step
Change the ask: add resource, narrow the scope or move the date
If top management will not approve as asked, the choices the pack gives when a plan does not fit its date are to add resource, narrow the scope or move the date. Narrow the scope only where the smaller scope still passes the scope tests. A scope cut only to leave out what is not ready fails them.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanDecision logic
- P08-A02 ISO 27001 Implementation Methodology & Project PlanTests a scope should pass
Step
Agree what top management does after the start
Approval at the start is not enough. Top management receives the monthly readiness figures from the start of implementation, sets the objectives, accepts the residual risk and holds the management review. The auditor will ask them about these directly. Top management also tells the organisation, in its own name, why security matters, and backs managers who put it ahead of a deadline.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPrinciples
- P08-A02 ISO 27001 Implementation Methodology & Project PlanMeasuring readiness
- P08-A09 Management Review Meeting PackWho attends
Decision
Will top management sit in the management review themselves?
The review is theirs, not the security team's. Delegation to a deputy is recorded in the minutes, and a review attended only by the security team is not a management review. If attendance is uncertain, answer no.
- Yes: Keep the records of commitment as you go
- No, or not known: Put the review and the objectives on top management's own agenda
In the pack
- P08-A09 Management Review Meeting PackWho attends
- P08-A09 Management Review Meeting PackPurpose and audience
Step
Put the review and the objectives on top management's own agenda
Ask the sponsor to chair or sponsor the review, and give top management the decisions to take: resources, scope, policy and objectives, and risks accepted. Send the papers in advance so the meeting decides rather than notes.
In the pack
- P08-A09 Management Review Meeting PackKeeping it a decision meeting
- P08-A02 ISO 27001 Implementation Methodology & Project PlanRoles and effort
Step
Keep the records of commitment as you go
Keep the dated approval, the budget decision, the named roles and the review minutes. Test it by asking a member of top management what the objectives are and what the last review decided. The pack lists the lack of an answer as a common reason a first audit goes wrong.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanEvidence to have ready
- P08-A02 ISO 27001 Implementation Methodology & Project PlanCommon failure modes
Decision
Will top management look at a revised request?
If they will not approve, find out what they would approve. If they will look again, take the revised paper back. If they will not, the project cannot start honestly. If you are not sure, answer no.
- Yes: Take one approval paper to top management (back to an earlier step)
- No, or not known: Top management has not committed: do not start the project
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanThe rules (rule IS-01)
Outcome
Top management has not committed: do not start the project
Do not start the risk assessment, and do not tell customers a certificate is coming or that the project is under way. Take the reason to the sponsor, record what top management would approve and why not the rest, and come back when something changes.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanThe rules (rule IS-01)
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPhase 1 — Decide and scope (3 weeks)
Outcome
Commitment and resources approved: start the risk assessment
With the approval dated and minuted, the next phase can begin. The risk method comes first, before anyone scores a risk.
In the pack
- P08-A02 ISO 27001 Implementation Methodology & Project PlanPhase 2 — Assess risk (5 weeks)
Practical checklist
- Write one paragraph on why you want the certificate and who will read it.
- Name an executive sponsor, an ISMS manager and the control owners, and agree the time each has.
- Draft the scope and test it against the services customers buy.
- Build the cost from at least two quotes plus the internal effort, including the later surveillance audits.
- Take scope, policy direction and resources to top management and have the decision minuted.
- Put the monthly readiness figures, the objectives and the management review on top management's own agenda.
Evidence to have ready
- The minute or signed record of approval, dated before the risk assessment started.
- The budget approval and the named roles with their agreed time.
- Management review minutes showing who attended and what they decided.
- Leadership messages on security sent in an executive's name.
Assumptions
- You have decided to certify against ISO/IEC 27001:2022, or you are asking top management to take that decision.
- There is at least one senior person who can secure people and money, or the sponsor role can be given to one.
- Role effort, audit days and cost ranges are the CISO Times pack's defaults for an organisation of 100 to 300 people, and your own figures may differ.
Not covered here
- Drawing the scope itself. That is “How do we set the scope of our ISMS?”.
- Working out the date and the full cost. That is “When will certification realistically happen, and what will it cost?”.
- Writing the policy and objectives top management approves. That is “How do we write an information security policy and objectives that stand up to an ISO 27001 audit?”.
- Running the management review that top management holds. That is “How do we run a management review that actually decides things?”.
Related questions
- How do we set the scope of our ISMS?
- When will certification realistically happen, and what will it cost?
- How do we write an information security policy and objectives that stand up to an ISO 27001 audit?
- How do we set up an ISO 27001 risk assessment and treatment method that stands up to an audit?
- How do we decide whether our own people, a consultant or both do the ISO 27001 implementation work?