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The CISO Decision Brief

How do we…

How do we run a management review that actually decides things?

6 decision pointsThe pack behind this answer: ISO 27001 Implementation & Certification Readiness

Add to board memo

The short answer

Recommendation
Hold the review after the internal audit results are in, with the people who can commit resources in the room. Send a short pre-read in which every paper states the decision it wants, end every item with a decision, and record the review's results one by one with actions that leave with an owner and a date.
Reasoning
The certification body reads the minutes for three things: every input considered, decisions taken, and actions followed up. A meeting that noted everything passes the first test and fails the other two. 'No change' with a reason is a decision; 'noted' is not. The review belongs to top management, because they are the ones who can commit resources and change priorities. Audit results are an input, so a review held before the audit has to be held again. Without a completed review, a Stage 2 audit cannot pass (IS-06).
Considerations
  • The 12-month interval, the 10 and 5 working days for papers and pre-read, and the 3 and 10 working days after the meeting are the pack's defaults. Your own ISMS may set different ones.
  • In a small organisation, hold the review as an item of an existing management meeting, with its own minutes and the full agenda. The decisions are still recorded one by one.
  • Who may accept a given residual risk still follows your own risk acceptance rules. Sending a risk back for treatment is as valid a decision as accepting it.
  • If you are also under NIS2 or DORA, the review can feed the management body's oversight. Agree with legal or compliance whether it should report to the board or a board committee.

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. 20 steps.
  1. Start

    A management review is due

    It meets at the planned interval, and before the first certification after the first internal audit cycle and before Stage 1. An extra review follows a major incident, a major nonconformity or a significant change. The certification body reads the minutes for three things: every input considered, decisions taken, and actions followed up.

    In the pack

  2. Decision

    Are the internal audit results ready as an input?

    Audit results are one of the review's inputs. A review held before the audit has to be held again. The ISMS manager writes the programme summary before every management review. If you do not know whether it will be ready, treat the answer as no.

    In the pack

  3. Step

    Get the audit summary first, or move the date

    Ask for the programme summary, or reschedule the review until the audit results are in. Before the first certification, the review must come after the first full internal audit cycle.

    In the pack

  4. Decision

    Will people who can commit resources be in the room?

    The review belongs to top management, not the security team. That is the group that can commit resources and change priorities, such as an executive committee, or two or three directors in a small firm. A review attended only by the security team is not a management review. Deputies are recorded in the minutes, with their authority.

    In the pack

  5. Outcome

    Reschedule with top management present

    Ask the executive sponsor to secure the attendance. In a small organisation, hold the review as an item of an existing management meeting, with its own minutes and its full agenda. A meeting without the decision-makers can only note things.

    In the pack

  6. Step

    Ask each input owner for a short paper with a decision sought

    Ask every owner for the same shape: the figure, its trend, what it means, and the decision they want. One or two pages, trends not snapshots. In the pack's defaults, papers reach the ISMS manager 10 working days before and the pre-read goes out 5 working days before. A paper with no decision sought belongs in the appendix.

    In the pack

  7. Step

    Keep the standing agenda, with bad news first

    Past actions, what has changed inside and outside, what interested parties need, how security is performing, what interested parties are telling you, where the risks stand, where to improve, then decisions. Spend most of the time on performance, risks and decisions. Take overdue actions, repeat findings and risks outside appetite before anything that went well.

    In the pack

  8. Step

    Open by asking whether the pre-read has been read

    Nobody presents slides that repeat it. Each item starts with the decision sought. A review turns into a ritual when it is a presentation of the pre-read to people who have not read it.

    In the pack

  9. Decision

    Did this item end in a decision?

    'No change' is a decision: record it with the reason. 'Noted' is not a decision. A meeting that noted everything passes the certification body's first test, that inputs were considered, and fails the other two.

    In the pack

  10. Step

    Ask the chair for the decision before moving on

    Restate the decision sought and the options. If the meeting cannot decide, the decision is who will bring what back, and by when. That becomes an action with an owner and a date.

    In the pack

  11. Decision

    Is anyone asking for people, money or time?

    A request for resources comes to the meeting as options with costs: what it buys, what it costs, and what happens if it is refused. Without that, the meeting has nothing to decide between.

    In the pack

  12. Step

    Agree or refuse it, and state the consequence of a refusal

    Record the resources agreed or refused. A refusal is a valid decision, as long as its consequence is written down, so the next review can see what it cost.

    In the pack

  13. Decision

    Are risk owners asking management to accept residual risks?

    The risk item shows the top risks and their movement, risks outside appetite, treatment progress, and the residual risks put forward for acceptance.

    In the pack

  14. Step

    Accept each one, or send it back for treatment

    Decide each risk separately and record the decision. Sending a risk back for treatment is as valid as accepting it. Who may accept a given risk still follows your own risk acceptance rules; that is “Who can accept a risk, and does the answer change with its rating?”. Record the acceptance in your risk acceptance records after the meeting.

    In the pack

  15. Step

    Record the review's results one by one

    Does the ISMS still fit, is it enough, and does it work, one sentence each; improvements taken up or declined; changes to scope, policy, objectives or controls; resources; risks; in a certification year, go ahead with or move the next audit; and the next review's date. Ask one hard question: what would we do differently if we started again today?

    In the pack

  16. Step

    Read the actions back, each with an owner and a date

    Actions leave the room with an owner and a date, confirmed aloud at the end. One action log runs across reviews, carried forward until every action is closed.

    In the pack

  17. Step

    Issue the minutes, track the actions, update the documents

    In the pack's defaults, minutes go out within 3 working days and the changed documents are updated within 10 working days: scope, policy, objectives, Statement of Applicability, risk acceptances, audit programme. Track actions with the other ISMS gaps, review them monthly, and escalate overdue ones to the executive sponsor.

    In the pack

  18. Decision

    Could these minutes be swapped with the last review's?

    If the minutes of two reviews in a row could be swapped without anyone noticing, the review has become a ritual. Look at the decisions recorded, not at the agenda headings, which are meant to stay the same.

    In the pack

  19. Outcome

    Change the format before the certification body points it out

    Shorten the papers, cut the presentations, and make every paper end in a decision sought. Check the right people are attending rather than deputies.

    In the pack

  20. Outcome

    A review that decided: inputs, decisions and actions on record

    The minutes are the record the certification body reads at Stage 1 and Stage 2, and one of the blocking items: without a completed review, a Stage 2 audit cannot pass. The action log is the first paper of the next review.

    In the pack

Practical checklist

  1. Get the internal audit programme summary before the review, or move the date.
  2. Confirm that the people who can commit resources will attend, and record any deputies with their authority.
  3. Ask each input owner for a short paper: the figure, its trend, what it means and the decision sought.
  4. Keep the standing agenda (MR-1 to MR-7), and take overdue actions, repeat findings and risks outside appetite first.
  5. Open by checking the pre-read has been read, and end every item with a decision.
  6. Take resource requests as options with costs, and decide each residual risk put forward for acceptance.
  7. Record the results MD-1 to MD-7, and read back each action with its owner and date.
  8. Issue the minutes, update the documents the decisions changed, and track the actions monthly.

Evidence to have ready

  • The pre-read pack, with the papers for each input MR-1 to MR-7.
  • The minutes, showing attendance, each input considered and the decisions MD-1 to MD-7 recorded one by one.
  • The action log carried across reviews, with owners, due dates and evidence of closure.
  • The documents updated as a result: scope, policy, objectives, Statement of Applicability, risk acceptance records or audit programme.
  • The internal audit programme summary the review took as an input.

Assumptions

  • You run, or are building, an ISMS and hold a management review at planned intervals, at least every 12 months in the pack's default.
  • Timings shown are the defaults in the CISO Times management review pack. Your own ISMS may set different ones.

Not covered here