ISO 27001: Role of Top Management and Its Importance
Involvement from top management is critical to the design and effectiveness of any information security program. The definition of “top management” can vary from organization depending on size and structure, but in general, “top management” should involve members of the senior executive team responsible for making strategic decisions within the organization.
The intent of involving top management within the information security program is to ensure that enterprise governance is aligned with the information security governance framework. Components of a well-designed information security governance program include leadership, structure, and processes designed to protect an organization’s information security assets. Effective information security governance requires that top management have clear expectations about what to expect from the information security program, how to evaluate the organization’s risk posture, and how to define information security objectives that are in alignment with the strategic direction and goals of the organization.
Top management’s involvement with the information security program includes ensuring that the intended outcomes of the information security program are achieved, which could include the following:
- Alignment with business strategy to meet the organization’s strategic objectives
- A risk management program that identifies and mitigates the impacts to an organization’s resources and assets
- Effective and efficient resource management
- Timely and useful metrics reporting
- Value-added information security initiatives
Security is ultimately the responsibility of all employees within an organization; however, the most successful information security programs demonstrate effective leadership from top management by setting a “tone at the top” and championing the importance of information security through well-designed policy and direction. The result can be an organization with information security ingrained as part of its culture.
The ISO/IEC 27001 standard requires that organizations demonstrate leadership and commitment from top management as outlined in Clauses 5 (Leadership) and 9.3 (Management review). The focus within Clause 5 is on the design the information security management system (ISMS) which requires involvement from top management and includes the establishment of the information security policy and an organizational structure where the responsibilities and roles relevant to information security are defined and communicated. The focus within Clause 9.3 is to establish procedures for top management to be continually involved in the evaluation of the ISMS to ensure its effectiveness.
The members of top management that are involved with the leadership of the ISMS should consider the scope of the ISMS. Involvement from top management can vary by organization, but the scope of the ISMS should be considered when determining who from top management will be involved from a leadership and commitment standpoint. Typically, organizations begin by selecting a committee responsible for overseeing the design, operation, maintenance, and improvement of the ISMS. The committee should include members from top management and members from the information security team.
An organization that is able to successfully implement the requirements of Clause 5 will establish a ISMS program with the oversight, support, and direction of top management; an information security policy that includes information security objectives and is appropriate to the organization; and an organizational structure that incorporates information security with upstream channels so that information security performance is effectively reported to top management.
In addition to involving top management in the design of the ISMS, they are required to review and evaluate the performance of the ISMS on a continual basis. The frequent involvement of top management during the evaluation phase of the ISMS is a critical requirement. The intent is to provide regular feedback on the performance of the ISMS so that changes in the environment or processes not performing as expected are identified promptly so that corrective action can be successfully implemented.
An organization that can successfully implement the requirements of Clause 9.3 will be able to consistently and continually evaluate the operation of the ISMS, with input from top management to ensure the intent and objectives of the ISMS are being achieved and that the improvements are implemented where necessary.