ISMS implementation project guidance checklist




This checklist is appended to a SecAware guideline on implementing an ISMS, elaborating clause-by-clause on ISO/IEC 27001 - essentially, our version of ISO/IEC 27003.  It offers pragmatic guidance for information security managers and CISOs - nothing too obscure or complex.

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Project definition, justification, scoping and planning

⬚  Study the standards, in depth: complete lead implementer training if possible.

⬚  Study the business, in depth, to understand its objectives, strategies, culture, governance arrangements, existing information risk and security management etc.

⬚  If the organisation has a defined, structured approach for this phase, use it!

⬚  Build a business case that identifies and promotes the business benefits of the ISMS.

⬚  Look beyond ‘security’ and ‘compliance’ e.g. helping management to manage business risks, supporting/enabling other business initiatives and strategies.

⬚  Identify, explore and elaborate on a broad set of business objectives relating to: information risk and security management; information, cyber, manual and automated security controls; compliance and assurance; resilience; good practice, maturity; efficiency, cost-effectiveness etc.

⬚  Clarify relative priorities for the objectives e.g. by ranking them all or grouping them into categories such as ‘essential’, ‘important’, ‘nice-to-have’ and perhaps ‘to be avoided’.

⬚  Be honest about the organisational/governance changes ahead, including the potential disruption, costs and timescales.

⬚  Be realistic about resourcing, priorities and capabilities.

⬚Build-in more than enough slack/contingency to allow for unforeseen difficulties.

⬚  Offer a do-nothing straw man plus other options as appropriate e.g. distinguish essential from important from optional objectives, compare costs and benefits of differing ISMS scopes.


Project approval

⬚  Don’t expect the business case to sell itself, no matter how exciting and positive it seems.

⬚  Hawk it around management, informing them, gathering feedback and amending the proposal.

⬚  Identify, explore and address genuine concerns, especially blockers.

⬚  Look for opportunities to align with corporate strategies and other initiatives.

⬚  Refine the objectives and project proposal, adding explicit details where clarity is needed or helps e.g. metrics.

⬚  While awaiting approval, continue working on the planning and ideally progressing the essential aspects such as information risk assessment.

⬚  Be crystal clear about those essentials and only compromise in other areas, even if that means the project is refused or deferred.


Implementation activities

⬚  Aim low, strike high: focus intensely on those essentials, progressing other objectives at lower priority/urgency if resources allow.

⬚  Where possible, re-use existing content, policies, procedures, controls etc., adapting as necessary.

⬚  Collaborate closely with related teams/functions/organisations/individuals.

⬚  Work to up-skill the core team through training, mentoring and experience on the job.

⬚  Start operating elements of the ISMS as soon as practicable, practising and refining them and ideally accounting for the benefits gained (financial or otherwise).

⬚  Look for early wins and promote them: positive feedback is invaluable for motivation and energy.


Project management, oversight, progress reporting and project risk management

⬚  If the organisation has a project management method/approach, use it!

⬚  Work with experienced programme and project managers.

⬚  Establish suitable governance arrangements (e.g. structure, reporting, metrics, approvals) for the project as that will evolve into the ISMS governance in due course.

⬚  Play snakes-and-ladders: identify and address risks/issues/setbacks, seizing and promoting opportunities to advance.

⬚  Watch the critical path and anything that does or might consume your contingencies, like a hawk.

⬚  Beware stress and burnout: don’t exceed reasonable workloads for long periods, including yours.

⬚  Work hard on clear communications and effective relationships: these will outlast the implementation phase.


Certification and other assurance activities

⬚  Treat certification as an opportunity to improve, more than a hurdle to clear.

⬚  Take time to clarify objectives, identify suppliers and contract with certification bodies.

⬚  Specify experienced and competent certification auditors, anticipating less aggravation and more value-add.

⬚  Line up certification prerequisites such as completed ISMS documentation, records of activities, ISMS internal audits etc.

⬚  Line up management to see the purpose and value of assurance regarding the ISMS, information risk and security management, compliance etc.

⬚  Line up marketing to promote the certification, enhancing corporate brands, opening new business opportunities etc.

⬚  Liaise between the team, management and the certification body closely in the run-up to certification, maintaining alignment and expectations.

⬚  Look beyond the award itself: there is always more to be done, more planning required e.g. integrating other management systems.


Transition to business-as-usual

⬚  Plan for a gradual, sequential/piecemeal ISMS build-and-implementation, rather than a big bang.

⬚  Start using those policies, procedures, metrics, reports etc. as soon as they are available: it inevitably takes time to discover and smooth-off the rough edges, and integrate them all into a coherent, self-sustaining management system, so they constitute ‘improvement opportunities’.

⬚  Keep up the communications within and without the team, squeezing more value from metrics through motivational feedback, direction and reprioritisation.

⬚  Become ever more business- and externally-focused as the ISMS settles into a routine, without neglecting the team and individual needs.


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That's it so far ... but your comments and especially improvement suggestions are very welcome. What aspects have I neglected or misrepresented? What would you add or change, based on your experience? 

The checklist can be downloaded as a PDF or as part of the Pragmatic ISMS implementation guideline.



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