ISO 27001:2022 Clause 7.4 Communication

The organization shall determine the need for internal and external communications relevant to the information security management system including:
a) on what to communicate;
b) when to communicate;
c) with whom to communicate;
d) how to communicate.

The organization shall determine the need for internal and external communications relevant to the information security management system

Determining the needs for internal and external communications relevant to the Information Security Management System (ISMS) involves understanding the context of the organization and identifying stakeholders, their information security requirements, and the communication channels necessary to meet those needs. Effective internal and external communications are crucial components of a well-functioning Information Security Management System (ISMS). The specific communications needed by an organization will depend on its context, industry, and stakeholders. Here are examples of internal and external communications relevant to ISMS:

Internal Communications:

1. Information Security Policy Distribution: Internal communication of the organization’s Information Security Policy to all employees, ensuring they are aware of the organization’s commitment to information security.
2. Roles and Responsibilities: Clear communication of roles and responsibilities related to information security, ensuring that employees understand their individual contributions to the ISMS.
3. Training and Awareness Programs: Internal communication about ongoing training and awareness programs to educate employees on information security best practices, policies, and procedures.
4. Incident Reporting Procedures: Communication of incident reporting procedures, ensuring that employees are aware of how to report security incidents and breaches promptly.
5. Change Management Communication: Communication regarding changes to information security policies, procedures, or systems to keep employees informed and aligned with evolving security requirements.
6. Security Awareness Campaigns: Periodic communication campaigns to raise awareness about specific security threats, social engineering tactics, or other relevant topics among employees.
7. Results of Internal Audits: Communication of the results of internal audits, highlighting areas of improvement and corrective actions taken to address identified weaknesses.
8. Updates on Security Measures: Regular updates on implemented security measures, technological enhancements, or changes in security controls to keep employees informed.
9. Policy Compliance Checks: Periodic communication to remind employees of the importance of complying with information security policies and conducting internal checks for compliance.
10. Employee Recognition Programs: Recognition and communication of employees who demonstrate exemplary commitment to information security, fostering a positive security culture.

External Communications:

1. Customer and Supplier Communications: Communication with customers and suppliers regarding the organization’s commitment to information security, often through contractual agreements, SLAs, or periodic security reviews.
2. Regulatory Reporting: Communication with relevant regulatory bodies, including reporting security incidents, compliance status, or adherence to specific industry standards.
3. Public Relations in Case of Incidents: External communication plans for managing public relations and reputational damage in the event of a significant security incident, including press releases or public statements.
4. Third-Party Security Assessments: Communication with third-party auditors or assessors conducting security assessments, ensuring transparency about security practices and controls.
5. Updates to Customers and Partners: Communication with customers and business partners about significant changes to the organization’s information security practices that may impact them.
6. Industry Collaboration and Sharing: Collaboration and communication with industry peers or relevant communities to share insights, best practices, and threat intelligence for collective security improvement.
7. Public Disclosures: Communication with the public, clients, or stakeholders in the case of data breaches or incidents that impact their privacy or security.
8. Security Certifications and Compliance: Communication of achieved security certifications or compliance with industry standards to enhance the organization’s reputation and build trust with external stakeholders.
9. Community Outreach Programs: Communication about information security initiatives in the community, demonstrating corporate social responsibility and commitment to cybersecurity.
10. Participation in Industry Forums: Communication and participation in industry forums, conferences, or working groups related to information security to stay informed and contribute to the broader security community.

Remember that communication should be tailored to the specific needs of the organization, considering its industry, size, and regulatory environment. Regular reviews and updates to communication plans ensure that they remain effective in addressing the organization’s evolving information security needs.Here’s a step-by-step guide on how an organization can determine these communication needs:

• Identify Stakeholders: Determine the internal and external stakeholders who have an interest or influence over the organization’s information security. This may include employees, management, customers, suppliers, regulatory bodies, and other relevant parties.
• Review Applicable Laws and Regulations: Identify and understand the legal and regulatory requirements related to information security in the organization’s industry and location. Determine the communication obligations specified by these requirements.
• Define Information Security Policy: Clearly articulate the organization’s Information Security Policy. The policy should be communicated to all stakeholders to ensure a shared understanding of the organization’s commitment to information security.
• Risk Assessment and Treatment: Conduct a risk assessment to identify and evaluate information security risks. Develop a risk treatment plan. Determine the appropriate channels and frequency for communicating risk-related information to relevant stakeholders.
• Roles and Responsibilities: Clearly define roles and responsibilities related to information security. Communicate these roles internally to ensure that employees understand their responsibilities for maintaining information security.
• Training and Awareness Programs: Identify the need for training and awareness programs to ensure that employees are informed about information security policies, procedures, and best practices.
• Incident Response Communication: Develop a communication plan for internal stakeholders in the event of an information security incident. Define roles and responsibilities for incident reporting and communication.
• Customer and Supplier Communication: Determine how information security commitments will be communicated to customers and suppliers. This may involve contractual agreements, service-level agreements (SLAs), or other formal communication mechanisms.
• Regulatory Reporting: Establish processes for communicating with regulatory bodies as required by applicable laws and regulations. This may include reporting security incidents or compliance status.
• Public Relations and Reputation Management: Consider communication strategies for managing the organization’s reputation in the event of a security incident. Define how and when information will be communicated to the public or media.
• Select Appropriate Channels: Identify the most effective communication channels for reaching different stakeholders. This may include email, intranet, newsletters, training sessions, meetings, and other communication tools.
• Establish Monitoring Mechanisms: Implement mechanisms to monitor the effectiveness of internal and external communication efforts. This may involve feedback surveys, audits, or regular reviews of communication processes.
• Management Review: Periodically review the communication strategy and its effectiveness during management review meetings. Make adjustments based on lessons learned and changes in the organization’s context.
• Document Communication Plans: Clearly document communication plans, including the identified needs, stakeholders, channels, and responsibilities. Maintain records of communication efforts, especially those related to incidents or changes in the ISMS.

By systematically addressing these steps, an organization can establish a robust communication framework that ensures the effective flow of information relevant to the ISMS. Regular reviews and updates to the communication strategy help adapt to changes in the organization’s context and evolving information security requirements.

The organization shall determine on what to communicate; when to communicate; with whom to communicate; how to communicate.

This statement aligns with the principles of effective communication in the context of an Information Security Management System (ISMS). Determining what, when, with whom, and how to communicate is essential for fostering a strong security culture and ensuring that stakeholders are well-informed. Let’s break down each component:

1. What to Communicate:

• Information Security Policies: Clearly communicate the organization’s Information Security Policy, including its objectives, principles, and the commitment to maintaining a secure environment.
• Updates and Changes: Communicate any updates or changes to information security policies, procedures, or controls. This includes changes in response to emerging threats, technological advancements, or organizational changes.
• Security Awareness Messages: Regularly communicate security awareness messages, educating stakeholders about current threats, best practices, and their roles in maintaining information security.
• Incident Reports: Clearly communicate information about security incidents, including the nature of the incident, the impact, and the steps being taken to address and mitigate the situation.
• Compliance and Certifications: Communicate the organization’s commitment to compliance with relevant laws, regulations, and industry standards. Share information about certifications obtained and the ongoing adherence to best practices.
• Risk Assessment Results: Provide stakeholders with information about the results of risk assessments, including identified risks, their potential impact, and the strategies in place for risk mitigation.

2. When to Communicate:

• Regular Updates: Schedule regular updates and communications on information security matters to keep stakeholders informed about ongoing efforts, initiatives, and changes.
• Incident Response: Communicate promptly in the event of a security incident. Establish clear timelines for incident reporting and define when and how stakeholders will be updated throughout the incident response process.
• Policy Changes: Communicate changes to policies, procedures, or controls as soon as they are implemented, ensuring that stakeholders are aware of and can adapt to new requirements.
• Training Sessions: Schedule regular training sessions and awareness programs to ensure that employees stay informed about the latest security practices.
• Management Reviews: Communicate the results of management reviews related to the ISMS, including insights gained, areas for improvement, and strategies for enhancing information security.

3. With Whom to Communicate:

• Internal Stakeholders: Communicate with all internal stakeholders, including employees, management, and relevant departments, to ensure a shared understanding of information security practices.
• External Stakeholders: Tailor communications for external stakeholders, such as customers, suppliers, regulatory bodies, and partners. Establish clear lines of communication to address their specific concerns and expectations.
• Third-Party Auditors: Communicate openly with third-party auditors or assessors during audits and assessments. Provide the necessary information to demonstrate compliance with information security standards.
• Regulatory Agencies: Establish communication channels with regulatory agencies to ensure timely reporting and compliance with legal and regulatory requirements.
• Media and Public: In the event of a significant security incident, communicate transparently with the media and the public. Provide accurate and timely information to manage reputational damage.

4. How to Communicate:

• Clear and Accessible Documentation: Document information security policies, procedures, and guidelines in a clear and accessible format. Ensure that stakeholders can easily access and understand the information.
• Training Programs: Use various training methods, such as in-person sessions, e-learning modules, and workshops, to effectively communicate information security principles to employees.
• Email and Intranet: Utilize email and intranet platforms for regular communication updates, policy changes, and important announcements.
• Meetings and Workshops: Conduct meetings and workshops to discuss information security matters, answer questions, and address concerns in a face-to-face or virtual setting.
• Incident Notifications: Establish clear protocols for incident notification, including who should be notified, how notifications will be delivered, and the frequency of updates during incident response.
• Reports and Dashboards: Develop reports and dashboards to communicate key information security metrics and performance indicators to management and relevant stakeholders.
• Feedback Mechanisms: Implement feedback mechanisms, such as suggestion boxes, surveys, or dedicated communication channels, to gather input from stakeholders and address their concerns.
• Crisis Communication Plans: Develop crisis communication plans that outline how to communicate effectively during a security crisis. Define spokespersons, key messages, and communication channels.
• Visual Aids and Infographics: Use visual aids, infographics, and other visual communication tools to simplify complex information and enhance understanding.
• Secure Communication Channels: Ensure that communication channels used for sensitive information, such as incident reporting or legal compliance matters, are secure and protected.

Remember to tailor your communication strategies based on the culture of your organization, the preferences of your stakeholders, and the specific requirements of your industry. Regularly review and update your communication plans to adapt to changing circumstances and emerging threats.

Example of Communication Procedure for Information Security Management System (ISMS)

Objective: The objective of this procedure is to establish a systematic process for determining internal and external communication related to the Information Security Management System (ISMS), ensuring that stakeholders are informed, aware, and engaged in maintaining information security.

Scope: This procedure applies to all employees, contractors, third parties, and relevant stakeholders who have access to the organization’s information assets.

1. Identification of Communication Needs:

1.1 Stakeholder Analysis: Identify and list all internal and external stakeholders with an interest or influence on the organization’s information security.

1.2 Information Security Objectives: Review and define information security objectives in alignment with the organization’s overall goals. Identify key messages and information that need to be communicated to support these objectives.

1.3 Legal and Regulatory Requirements: Conduct a review of legal and regulatory requirements related to information security communication. Identify specific obligations regarding the reporting and communication of security incidents.

2. Determination of What to Communicate:

2.1 Information Security Policies: Clearly articulate the organization’s Information Security Policy. Define the key messages that need to be communicated to internal stakeholders to ensure a shared understanding of the policy.

2.2 Policy Changes and Updates: Establish a process for communicating changes to information security policies and procedures. Define when and how updates will be communicated to ensure timely awareness.

2.3 Risk Management Information: Develop communication strategies for sharing information related to risk assessments, identified risks, and risk treatment plans. Ensure stakeholders are aware of the organization’s risk management efforts.

2.4 Incident Response Procedures: Clearly communicate incident response procedures, including how incidents should be reported and the communication plan during and after a security incident.

2.5 Training and Awareness Programs: Determine key messages for training and awareness programs. Define the topics, frequency, and methods for communicating security awareness to employees.

3. Determining When to Communicate:

3.1 Regular Updates: Establish a schedule for regular information security updates. Define the frequency and channels for routine communication to keep stakeholders informed.

3.2 Incident Response Timelines:Define timelines for incident reporting and communication during different phases of incident response. Ensure timely updates to stakeholders throughout the incident lifecycle.

3.3 Policy Changes and Updates: Clearly outline when updates to information security policies and procedures will be communicated. Consider immediate communication for critical changes.

3.4 Training and Awareness Programs: Establish a schedule for recurring training sessions and awareness campaigns. Consider periodic updates based on emerging threats or changes in the threat landscape.

4. Identifying With Whom to Communicate:

4.1 Internal Stakeholders: Clearly define internal stakeholders and their roles in information security communication. Identify communication channels tailored to different internal audiences.

4.2 External Stakeholders: Identify external stakeholders, including customers, suppliers, regulatory bodies, and partners. Determine specific communication plans and channels for each external group.

4.3 Third-Party Auditors: Establish communication protocols for engaging with third-party auditors or assessors. Clearly define the information to be communicated during audits and assessments.

4.4 Regulatory Agencies: Define communication channels and contact points for engaging with regulatory agencies. Establish procedures for reporting security incidents as required by law.

5. Determining How to Communicate:

5.1 Clear and Accessible Documentation: Ensure that information security policies, procedures, and guidelines are documented in a clear and accessible format. Consider using a combination of written, visual, and interactive materials.

5.2 Training Programs: Utilize various training methods, including in-person sessions, e-learning modules, and workshops, to effectively communicate information security principles to employees.

5.3 Email and Intranet: Leverage email and intranet platforms for regular communication updates, policy changes, and important announcements. Ensure that information is easily accessible to all employees.

5.4 Meetings and Workshops: Conduct regular meetings and workshops to discuss information security matters, answer questions, and address concerns in a collaborative setting.

5.5 Incident Notifications: Establish clear protocols for incident notification, including the use of secure communication channels. Define how stakeholders will be informed and updated during incident response.

5.6 Reports and Dashboards: Develop reports and dashboards to communicate key information security metrics and performance indicators to management and relevant stakeholders.

5.7 Feedback Mechanisms: Implement feedback mechanisms, such as suggestion boxes, surveys, or dedicated communication channels, to gather input from stakeholders and address their concerns.

5.8 Crisis Communication Plans:Develop crisis communication plans that outline how to communicate effectively during a security crisis. Define spokespersons, key messages, and communication channels.

6. Monitoring and Review:

6.1 Continuous Improvement: Regularly review and update the communication plan to adapt to changing circumstances, emerging threats, and stakeholder feedback. Ensure continuous improvement in communication effectiveness.

6.2 Management Reviews: Include communication effectiveness as part of management reviews of the ISMS. Use feedback and performance metrics to refine communication strategies.

Communication Matrix for ISMS

A communication matrix is a useful tool for planning and organizing communication within an Information Security Management System (ISMS). It helps identify the key messages, target audiences, communication methods, and timing for various communication activities. Here’s an example of a simplified communication matrix for an ISMS.

Communication Activity	Key Message	Target Audience	Communication Method	Timing	Responsible Party
1. Information Security Policy Communication	Introduction of the Information Security Policy and its importance	All Employees	Email, Intranet Announcement	Annually	Information Security Officer
2. Policy Changes and Updates	Notification of changes to information security policies and procedures	All Employees	Email, Intranet Announcement	As needed	Information Security Officer
3. Security Awareness Training	Importance of information security and employee responsibilities	All Employees	Training Sessions, E-Learning	Annually	Training Department
4. Incident Response Communication	Reporting procedures and updates during security incidents	All Employees	Email, Intranet, Meetings	Immediate (during incidents)	Incident Response Team
5. Risk Assessment Results	Communication of risk assessment outcomes and risk treatment plans	Management, Relevant Departments	Meetings, Reports	Biannually	Risk Management Team
6. Internal Audits and Assessments	Results of internal audits and security assessments	Management, Internal Audit Team	Meetings, Reports	Quarterly	Internal Audit Team
7. Third-Party Audits	Communication with third-party auditors during external assessments	Management, External Auditors	Meetings, Reports	Annually	Information Security Officer
8. Regulatory Compliance Updates	Updates on changes to legal and regulatory requirements	Compliance Officer, Relevant Departments	Email, Meetings	As needed	Compliance Officer
9. Security Incident Reports to Regulatory Bodies	Reporting security incidents to regulatory agencies	Compliance Officer	Formal Reports, Email	Immediately (as required by law)	Compliance Officer
10. Customer and Supplier Communication	Assurance of information security practices to customers and suppliers	Customers, Suppliers	Letters, Certifications	Annually	Information Security Officer
11. Continuous Improvement Initiatives	Communication about ongoing efforts to improve the ISMS	All Employees	Newsletters, Meetings	Quarterly	Information Security Officer
12. Crisis Communication Plan Activation	Communication plan activation during significant security incidents	All Employees	Email, Intranet, Press Releases	Immediately (during crises)	Crisis Communication Team
13. Security Metrics and Dashboards	Reporting key security metrics to management	Management	Dashboards, Reports	Monthly	Information Security Officer
14. Employee Recognition Programs	Recognition of employees contributing to information security	All Employees	Announcements, Meetings	Annually	Human Resources, Information Security Officer

Internal and External Communication Program for ISMS

1. Objectives:

• Clearly define the objectives of the communication program. Examples include:
  • Ensure all employees understand and adhere to information security policies.
  • Keep stakeholders informed about changes to the ISMS.
  • Foster a positive security culture within the organization.
  • Enhance transparency in incident reporting and resolution.

2. Stakeholder Analysis:

• Identify and categorize internal and external stakeholders. Examples include employees, management, customers, suppliers, regulatory bodies, and third-party auditors.

3. Key Messages:

• Define key messages that need to be communicated to different stakeholder groups. Examples include:
  • Importance of information security in daily operations.
  • Updates to information security policies and procedures.
  • Results of risk assessments and risk treatment plans.
  • Incident reporting procedures and communication during incidents.

4. Communication Channels:

• Identify appropriate communication channels for each stakeholder group. Examples include:
  • Email and Intranet for internal communication.
  • Formal letters and certificates for external stakeholders.
  • Meetings and workshops for face-to-face communication.

5. Communication Methods:

• Specify the methods for delivering key messages. Examples include:
  • Regular email updates for policy changes and awareness campaigns.
  • In-person training sessions for employees.
  • Secure channels for incident reporting and updates.

6. Communication Schedule:

• Establish a communication schedule for routine and periodic updates. Examples include:
  • Quarterly newsletters summarizing ISMS achievements and updates.
  • Monthly security awareness campaigns.
  • Immediate communication during security incidents.

7. Responsibility Matrix:

• Clearly define roles and responsibilities for communication activities. Examples include:
  • Information Security Officer: Overall coordination of the program.
  • Human Resources: Employee training and awareness programs.
  • Compliance Officer: Ensuring communication aligns with legal requirements.
  • Incident Response Team: Communication during and after security incidents.

8. Feedback Mechanisms:

• Establish mechanisms for stakeholders to provide feedback. Examples include:
  • Anonymous suggestion boxes for employees.
  • Periodic surveys to assess the effectiveness of training programs.
  • Dedicated communication channels for incident feedback.

9. Training and Awareness Programs:

• Develop a comprehensive training program for employees. Examples include:
  • Annual security awareness training sessions.
  • Simulated phishing exercises to test employee awareness.
  • Tailored training for different departments based on their roles.

10. Incident Communication Plan:

• Develop a detailed plan for communicating during security incidents. Examples include:
  • Immediate notification to the Incident Response Team.
  • Regular updates to employees and other stakeholders.
  • Post-incident communication to discuss lessons learned and preventive measures.

11. Documentation and Record Keeping:

• Establish a system for documenting all communication activities. Examples include:
  • Maintain records of policy change notifications.
  • Document feedback received from stakeholders.
  • Archive communication plans and incident reports.

12. Regulatory Compliance:

• Ensure that the communication program aligns with legal and regulatory requirements. Examples include:
  • Timely reporting to regulatory bodies as required.
  • Communicating changes in compliance measures to stakeholders.
  • Regular audits to verify compliance with communication obligations.

13. Continuous Improvement:

• Implement a continuous improvement process for the communication program. Examples include:
  • Regular reviews of the program’s effectiveness.
  • Adjustments based on stakeholder feedback and evolving security needs.
  • Incorporation of new communication technologies or methods.

14. Crisis Communication Plan:

• Develop a detailed plan for communication during a crisis or major security incident. Examples include:
  • Designate spokespersons for external communication.
  • Define key messages to be communicated to the public and media.
  • Establish protocols for responding to media inquiries.

15. Performance Metrics:

• Define key performance indicators (KPIs) for measuring the success of the communication program. Examples include:
  • Employee participation rates in training programs.
  • Incident reporting timeliness and accuracy.
  • Stakeholder satisfaction with communication effectiveness.

Notes:

• Regularly review and update the communication program to adapt to changing circumstances, emerging threats, and organizational developments.
• Conduct periodic drills and exercises to test the effectiveness of incident communication plans.
• Collaborate with relevant departments, such as Human Resources, IT, and Compliance, to ensure a holistic and coordinated approach.