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Step 6 · ISO/IEC 27005:2022, Clauses 9 and 10

ISO 27005 risk monitoring and review: keeping the assessment alive

A risk assessment starts ageing the moment it is validated: systems change, so do threats, and not all planned controls are delivered on time. Clauses 9 and 10 of the standard deal with what happens afterwards: repeating the assessment at the right time, carrying out the plan, keeping records, communicating, monitoring.

Updated on · 6 min read

Clauses
9, Operation; 10, Leveraging related ISMS processes
Participants
CISO, risk owners, management, internal audit
Deliverables
Up-to-date assessments, evidence, indicators, review minutes
Guide chapters
  1. Applying ISO 27005
  2. Context and risk criteria
  3. Identify risks
  4. Analyse risks
  5. Evaluate risks
  6. Treat risks
  7. Monitor and review
  8. ISO 27001 and ISO 31000
  9. ISO 27005 and EBIOS RM
  10. Glossary

In brief

  1. Clause 9 deals with operation: performing risk assessment and risk treatment over time. It addresses clauses 8.2 and 8.3 of ISO/IEC 27001.

  2. ISO/IEC 27001 requires the assessment to be repeated at planned intervals and when significant changes are proposed or occur.

  3. Clause 10 connects risk management with the other processes of the management system: context, leadership, communication and consultation (10.3), documented information (10.4), monitoring and review, management review, corrective action, continual improvement.

  4. Monitoring means tracking three things: progress of the plan, effectiveness of controls and signals that change a risk.

  5. Without a written record, a decision does not exist for the auditor: criteria, assessment results, plan and acceptances are retained.

When to repeat the risk assessment

ISO/IEC 27001 (clause 8.2) requires risk assessments to be performed at planned intervals, or when significant changes are proposed or occur, taking account of the established criteria. The standard sets no frequency: planning it is up to you. A widespread practice is a full review once a year, aligned with the management review, with targeted updates in between.

Diagram of risk monitoring and review. In the centre, a loop: assess, treat, monitor, review. On the left, the triggers for an update: new system or project, change of supplier, incident or near miss, new threat in the sector, new obligation, reorganisation. On the right, what is tracked: progress of the treatment plan, effectiveness of controls, signals related to the scenarios. At the bottom, the records to keep: criteria, assessment results, treatment plan, acceptances of residual risks.
Two rhythms and a set of triggers: the planned review, the event-driven update, and what you watch in between.
Triggers for an off-schedule update
ChangeExampleWhat to review
New system, new projectAn online tool goes live, a new connected machineIdentification and analysis on the scope concerned
Change at a third partyNew supplier, change of hosting providerScenarios that go through that third party, contractual requirements
Incident or near missIntrusion attempt detected, error narrowly avoidedLikelihood of neighbouring scenarios, effectiveness of controls
Change in the threatWave of attacks targeting the sectorLikelihood, treatment priorities
New obligationNew regulation, new contractRequirements of interested parties, consequence scale
Organisational changeMerger, new site, departure of a risk ownerScope, owners, sometimes the criteria

This is where the two cycles presented in the introduction come back: the strategic cycle reviews the context and the criteria, the operational cycle updates the scenarios and the levels.

Carry out the plan and check that controls work

ISO/IEC 27001 (clause 8.3) requires the treatment plan to be implemented and its results retained. A risk does not go down on the day the plan is approved, but on the day the control is in place and working.

  • Track progress. Each action has a person responsible, a deadline and a status. Delays go up to the risk owner, who decides: chase, reallocate resources or temporarily accept the risk at its initial level.
  • Check effectiveness. A backup is tested by a restore, network separation by an attempt to cross it, awareness by an exercise. A recurring check turns this verification into routine.
  • Update the level of risk. Once the control has been verified, the risk moves from its initial level to the expected residual level, and not before.
  • Watch the signals. Logs, alerts, incident reports, agency bulletins: these are what tell you a scenario is becoming more likely.

Document: what to retain

Subclause 10.4 of the standard deals with documented information. ISO/IEC 27001 requires documented information to be retained about the assessment process (6.1.2), about the treatment process (6.1.3), about the results of assessments (8.2) and about the results of treatment (8.3).

The records expected
DocumentContentISO/IEC 27001 requirement
Risk management procedureMethod, criteria, scales, roles, frequency6.1.2 and 6.1.3
Risk registerScenarios, owners, levels, justification of ratings8.2
Statement of applicabilityControls adopted, justification, implementation status, exclusions6.1.3 d)
Treatment planActions, people responsible, deadlines, expected residual risks6.1.3 e), 8.3
Acceptance decisionsWho accepted which residual risk, when, for how long6.1.3 f)

Communicate and consult

Subclause 10.3 deals with communication and consultation. In ISO 31000, this is an activity that accompanies every step of the process, not a final debrief. It has two functions: gathering what those who live with the risks know, and getting the decisions understood by those who will have to apply them.

  • With the business, during identification and analysis: they are the ones who know the real consequences.
  • With management, at evaluation and acceptance: it arbitrates and takes responsibility.
  • With technical teams, during treatment: they say what is feasible and how long it takes.
  • With third parties, when a risk goes through them: suppliers, customers, sometimes authorities.

Clause 10 also ties risk management to the rest of the management system: management review, handling of nonconformities, continual improvement. If you are building an ISMS, our article on the information security management system shows how these pieces fit together.

Running example: one year later at Mécanique Vauclair

Frequently asked questions

How often should the risk assessment be repeated?

Neither ISO/IEC 27005 nor ISO/IEC 27001 sets a frequency. ISO/IEC 27001 requires assessments to be performed at planned intervals and when significant changes are proposed or occur. A full annual review, supplemented by updates when a system, a supplier or the threat changes, is a widespread practice.

Which documents will an ISO 27001 auditor ask for about risks?

The description of the assessment and treatment process with its criteria, the results of the assessments, the statement of applicability, the treatment plan and the evidence that the risk owners approved the plan and accepted the residual risks. ISO/IEC 27001 requires documented information on each of these points.

What should you do when a control in the plan is late?

Tell the risk owner. Until the control is in place, the risk stays at its initial level. The owner then decides to reallocate resources, put a temporary control in place or temporarily accept the risk, and that decision is recorded.

What is the difference between monitoring and review?

Monitoring is continuous: you track the progress of the plan, the effectiveness of controls and the signals that change a risk. Review is a planned appointment: you re-examine the context, the criteria, the risks and the acceptance decisions, and decide on adjustments.

Sources

This chapter summarises and rephrases the official publications below. If in doubt, the official text prevails.

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