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The CISO Decision Brief

What it means in practice

Legal, statutory, regulatory and contractual requirements relevant to information security, and the organisation’s approach to meeting them, must be identified, documented and kept up to date.

This is the control that gives clause 4.2’s interested-party requirements an operational home, and for an organisation carrying more than one regime it is the one that stops obligations being tracked in separate places by separate people.

“Kept up to date” is the requirement that decays fastest. A register built once will not survive the arrival of a new regime, the transposition of a directive into national law, or a change of contract with a large customer.

The second half — the organisation’s approach to meeting them — is what makes it more than a list. A register naming an obligation with no statement of how it is met, and by which control, leaves the question open at exactly the point somebody needs the answer. The cross-reference between obligations and controls is also what makes it possible to see where one control is carrying several regimes.

How to put this in place

Laws, regulations and customer contracts can all set security duties. Missing one is easy unless somebody keeps the list.

  1. Identify the laws, regulations and contract requirements that apply to your activities.
  2. Record what each requires of you in a register.
  3. Name an owner and the controls that address each.
  4. Include security schedules from customer contracts.
  5. Review the register at least every 12 months and when a law or major contract changes.

Evidence an auditor usually looks for: the requirements register with owners and review dates, and examples of requirements traced to controls.

What is in the packs for this

Each one helps with this requirement.

  • Excel

    Annex A Control Implementation Library

    in ISO 27001 Implementation & Certification ReadinessIts row in the Control Library: what it is for, practical steps, what an auditor samples, the usual owner, common mistakes and whether it usually applies.
  • Excel

    Statement of Applicability Template

    in ISO 27001 Implementation & Certification ReadinessHas its own row on the Statement of Applicability sheet, where you record whether it applies, why and how far it is implemented.
  • Excel

    Mandatory ISMS Documentation Checklist

    in ISO 27001 Implementation & Certification ReadinessAnnex A Documents sheet: lists register of legal, statutory, regulatory and contractual requirements among the documents auditors commonly expect for this control.
  • Word

    Stage 1 and Stage 2 Audit Preparation Guide

    in ISO 27001 Implementation & Certification ReadinessListed among the commonly sampled controls, with what an auditor is likely to sample and the likely challenge.
  • Excel

    NIS2 Scope & Entity Classification Assessment

    in NIS2 Implementation & ReadinessIts Framework References list this control. Supported by: The whole workbook: NIS2 identified as a legal requirement, and how it applies, recorded.
  • Excel

    NIS2 Article 21 Measure-to-Control Mapping Library

    in NIS2 Implementation & ReadinessIts Framework References list this control. Supported by: The whole library: the legal requirements of Article 21 identified and recorded, each with an owner.
  • Excel

    EU Incident Notification Timeline Matrix (NIS2, DORA, GDPR)

    in Regulatory Incident Notification & ReportingIts Framework References list this control. Supported by: The matrix as a whole: each legal and regulatory reporting requirement, with its trigger, deadline and content.
  • Word

    Reportability Decision Model

    in Regulatory Incident Notification & ReportingIts Framework References list this control. Supported by: The applicability profile and the three legal tests.
  • Excel

    US Incident Notification Timeline Matrix (HIPAA, SEC, NYDFS and State Law)

    in Regulatory Incident Notification & ReportingIts Framework References list this control. Supported by: The matrix as a whole: each legal and regulatory reporting requirement, with its trigger, deadline and content.
  • Excel

    Unified Control Framework Mapping Workbook

    in Security Control AssuranceIts Framework References list this control. Supported by: NIS2 Article 21(2), ISO 27001 Annex A, NIST CSF 2.0 and DORA Chapter II sheets, and the contracts column: the requirement sets you answer for, identified and recorded.
  • Excel

    DORA Proportionality & Scope Assessment

    in DORA ICT Risk & Resilience ReadinessIts Framework References list this control. Supported by: The whole workbook: the legal requirements that apply to the entity, identified and recorded.
  • Excel

    DORA Article-to-Control Mapping Library

    in DORA ICT Risk & Resilience ReadinessIts Framework References list this control. Supported by: The whole library: the legal and regulatory requirements that apply to the entity identified and recorded, each with an owner.
  • Excel

    EU AI Act Role & Risk Classification Worksheet

    in AI Security Governance & Acceptable UseIts Framework References list this control. Supported by: The whole workbook: the legal and contractual requirements of the AI Act, read and recorded for each use.
  • Excel

    HIPAA Applicability Assessment

    in HIPAA Security Rule ReadinessIts Framework References list this control. Supported by: The whole workbook: the legal requirement identified, its role decided and the decision recorded.