ISO 27001:2022 Clause 8: Operation

ISO27001-2022 Clause 8 Operation

The Definitive Governance Requirement.

Clause 8 mandates that you execute the plans you designed in Clause 6. It is the transition from “Theory” to “Practice.” You have analysed the risks and promised the controls; Clause 8 requires you to operationalise those promises. If Clause 6 is the architect’s blueprint, Clause 8 is the construction site.

The Mandate

The standard does not award certification for good intentions. It awards it for operational reality. Clause 8 is the engine room of the ISMS, requiring you to implement, control, and maintain the processes needed to meet your security requirements.

It comprises three non-negotiable statutes:

  1. Clause 8.1 (Operational Planning and Control): You must plan, implement, and control the processes needed to meet information security requirements. This includes controlling changes and outsourced processes.
  2. Clause 8.2 (Information Security Risk Assessment): You must perform risk assessments at planned intervals or when significant changes occur. The Risk Register is not a static document; it is a living database.
  3. Clause 8.3 (Information Security Risk Treatment): You must implement the Risk Treatment Plan. You must apply the controls and retain evidence of the results.

The Verdict: Many organizations fail here because they treat the Risk Assessment as a “One-and-Done” exercise for the auditor. Clause 8 dictates that it is a cyclical, operational necessity.

The Implementation Strategy

You must demonstrate control over your environment. Chaos is a non-conformance.

  1. The “Gatekeeper” Protocol (8.1): Establish criteria for your operations. No code goes to production without a security scan. No vendor is onboarded without a risk review. You need “Go/No-Go” gates.
  2. The Schedule (8.2): Put the Risk Assessment in the calendar. Do not wait for the audit. Schedule it quarterly or bi-annually.
  3. The Project Plan (8.3): Treat risk remediation as a project. Assign owners, set deadlines, and track progress. An “Open” risk with no due date is an accepted liability.
  4. Change Management: You cannot change the environment without assessing the risk. Integrating security into your Change Advisory Board (CAB) is mandatory.

The Auditor’s Trap

[The Auditor’s View] The most common Major Non-Conformance here is “The Reality Gap.” In Clause 6, you documented a perfect plan to patch servers every 30 days. In Clause 8, I check the logs, and the last patch was 90 days ago. If the operational reality does not match the documented plan, you have failed Clause 8.1. You are out of control.

Required Evidence

Clause 8 is where the rubber meets the road. The auditor wants to see the artifacts of work done.

  • Operational Plans & Criteria: Documents defining security requirements for projects.
  • Change Logs: Evidence of approved and reviewed changes.
  • Risk Assessment Reports: Dated evidence of the recurring assessment (8.2).
  • Risk Treatment Plan Updates: Proof that risks are being closed out (8.3).
  • Outsourcing Contracts: Evidence of security controls applied to third parties.

Strategic Acceleration

Managing the operational lifecycle of hundreds of risks and changes requires a system, not a spreadsheet.

The Operational Framework connects your planning to your execution. It ensures that when you assess a risk, it automatically triggers the treatment workflow, creating the audit trail Clause 8 demands.

The Next Move: Deploy the Operational Framework