What is ISO 27001 Clause 4.4 in ISO 27001?
Clause 4.4 requires establishing and maintaining an Information Security Management System. This system must include processes and their interactions. It must integrate into daily business tools like SharePoint or Jira. This ensures security is a continuous documented process rather than a one-off project.
Auditor’s Eye: The Shortcut Trap
Using black box SaaS tools for Clause 4.4 creates a disconnected system. Auditors often see organisations with green ticks on a dashboard but no internal knowledge. We look for evidence of the ISMS within your own document repositories. Relying on external platforms obscures your actual security maturity. True compliance requires processes that live where your staff work every day.
| Requirement | ISO 27001:2013 | ISO 27001:2022 |
|---|---|---|
| Establish ISMS | Mandatory | Mandatory |
| Process Focus | General requirement | Increased emphasis on process interaction |
| Continuous Improvement | Required via Clause 10 | Explicitly integrated into Clause 4.4 |
How to Implement ISO 27001 Clause 4.4 (Step-by-Step)
Establish the ISMS by mapping your internal processes within SharePoint. Use Confluence to document how security activities interact. Assign responsibilities using Jira workflows. This integrated approach embeds security into your culture. It is a documented process, not a software purchase.
Step 1: Process Mapping
List all security processes needed for the ISMS. Store this list in a version-controlled SharePoint document. Identify which business unit owns each process. Ensure this list reflects your actual operations.
Step 2: Defining Interactions
Determine how one security activity influences another. For example, risk assessments must feed into the treatment plan. Document these links using a Confluence matrix. This proves the system functions as a unified whole.
Step 3: Continuous Operation
Set up Jira projects to track security tasks. Use workflows to ensure consistent execution. This creates a manual record of ISMS operation. It provides the evidence auditors require for certification.
ISO 27001 Clause 4.4 Audit Evidence Checklist
Auditors look for manual records of system operation. Use these items to prove your ISMS exists within your organisation.
- Process maps stored in your internal wiki or Confluence.
- Interaction diagrams showing data flow between security activities.
- SharePoint logs showing regular updates to ISMS documentation.
- Jira task history showing completion of security processes.
- Management review minutes signed by senior leadership.
Relational Mapping
Clause 4.4 acts as the container for all other clauses. It consumes the context from Clause 4.1. It addresses the needs identified in Clause 4.2. It executes the scope defined in Clause 4.3. All operational controls in Annex A must fit into this management system.
Auditor Interview: Direct Management Ownership
Question: How do you know your security processes are working?
Answer: We track process performance using Jira dashboards and reports.
Question: Where are the interactions between your processes documented?
Answer: Our Confluence site contains a full interaction matrix.
Question: Does a third-party platform manage your ISMS records?
Answer: No. We maintain all records in our internal SharePoint site.
Common Non-Conformities
| Failure Mode | Cause | Auditor Finding |
|---|---|---|
| Automated Complacency | Relying on a SaaS platform’s green tick. | Major NC: No evidence of internal procedural knowledge. |
| Siloed Processes | Security activities do not interact. | Minor NC: System fails to function as a whole. |
| Lack of Improvement | No records of process updates. | Minor NC: Failure to meet continuous improvement requirements. |
Frequently Asked Questions
What is the bottom line for Clause 4.4?
The bottom line is that Clause 4.4 mandates the creation of the ISMS. You must establish, implement, and improve the system continuously. It must include all necessary processes. Use your existing organisational tools to maintain these records for audit purposes. This ensures security is not just a theory.
How do processes interact in an ISMS?
Processes interact when the output of one activity triggers another. For example, an internal audit finding triggers a corrective action in Jira. Document these triggers in your internal wiki. This proves the system works as a unified whole. It shows the auditor that your system is mature.
How does Clause 4.4 prevent “Black Box” compliance?
Clause 4.4 requires a documented management system. Managing this in SharePoint or Confluence keeps data visible to staff. SaaS platforms often hide the actual work behind an interface. Auditors prefer integrated tools because they show genuine management oversight. This approach embeds security into daily business-as-usual operations.