As organisations increasingly rely on cloud services for critical operations, ensuring these services meet stringent information security requirements is essential. ISO 27001:2022 Annex A Control 5.23 introduces a framework for managing the security of cloud services throughout their lifecycle—from selection and implementation to eventual exit or migration.
What Is ISO 27001:2022 Annex A Control 5.23?
Annex A Control 5.23 provides guidance for managing the acquisition, use, and management of cloud services in line with an organisation’s information security needs. This control ensures that organisations, acting as cloud service customers, address the unique risks associated with cloud platforms.
Unlike general supplier relationships, cloud service agreements are often non-negotiable, requiring organisations to scrutinise these agreements carefully to ensure they align with security requirements.
Purpose of ISO 27001:2022 Annex A Control 5.23
The purpose of Annex A Control 5.23 is to enable organisations to mitigate risks associated with cloud services by:
- Defining security requirements for cloud services.
- Establishing roles and responsibilities for managing cloud platforms.
- Ensuring alignment between the organisation and the cloud service provider (CSP) on information security obligations.
- Preparing for secure termination or migration of cloud services.
This control serves as a preventative measure to address the unique challenges of cloud environments, such as shared responsibility, data jurisdiction, and dependency on external infrastructure.
Ownership of Annex A Control 5.23
Ownership of Annex A Control 5.23 should be distributed based on the organisation’s structure:
- Chief Technical Officer (CTO): Responsible for technical aspects of cloud service acquisition, implementation, and management.
- Chief Operating Officer (COO): Handles broader operational considerations, especially for non-ICT-specific cloud services.
The allocation of ownership depends on the scope of cloud service use within the organisation.
Implementing ISO 27001:2022 Annex A Control 5.23
To comply with Annex A Control 5.23, organisations must establish tailored policies for cloud service management. Below are the key steps for implementation:
1. Define Security Requirements for Cloud Services
- Specify relevant security requirements for cloud platforms, such as data encryption, access controls, and compliance with regulations.
- Identify how cloud services fit into the organisation’s broader information security framework.
2. Set Criteria for Selecting Cloud Providers
- Evaluate cloud service providers (CSPs) based on their ability to meet the organisation’s security and operational needs.
- Assess CSP certifications, such as ISO 27017 (cloud security) and ISO 27018 (data protection for cloud services).
3. Establish Roles and Responsibilities
- Clearly define which information security responsibilities are managed by the CSP and which are retained by the organisation.
- Assign internal roles for overseeing cloud security, monitoring CSP compliance, and managing incidents.
4. Develop Procedures for Cloud Service Use
- Create policies for accessing, monitoring, and managing cloud platforms across the organisation.
- Ensure procedures cover incident management, data handling, and system updates.
5. Monitor CSP Compliance
- Regularly review the CSP’s adherence to security obligations outlined in the agreement.
- Use audits or reporting mechanisms to ensure compliance with agreed-upon standards.
6. Plan for Secure Termination or Migration
- Develop a strategy for exiting cloud services, including data migration or deletion processes.
- Ensure the CSP provides support during transition periods to maintain continuity and security.
Key Considerations for Cloud Service Agreements
Unlike traditional supplier relationships, cloud service agreements are often rigid. To address this, organisations should ensure that these agreements include provisions for:
- Confidentiality and Data Integrity: The CSP must guarantee the confidentiality and integrity of your organisation’s data stored or processed on their platform.
- Service Availability: Specify uptime and availability requirements to ensure business continuity.
- Incident Response Support: Define the CSP’s role in identifying, mitigating, and reporting security incidents.
- Data Handling Standards: Ensure that data storage, processing, and transfer comply with jurisdictional and regulatory requirements.
Minimum Provisions for Cloud Service Agreements
Organisations should only proceed with a cloud service agreement if the following provisions are met:
- Tailored Security Measures: The CSP offers security features aligned with the organisation’s industry and operational requirements.
- Access Control: Cloud platforms meet the organisation’s broader access control policies.
- Threat Protection: The CSP provides anti-malware and proactive monitoring services.
- Jurisdictional Compliance: Data is stored and processed within approved regions or jurisdictions.
- Incident Support: The CSP commits to assisting during catastrophic failures or security incidents.
- Subcontractor Oversight: The CSP ensures that subcontractors meet the same security standards.
- Data Retrieval Support: The CSP supports lawful data retrieval requests, such as for regulatory or law enforcement purposes.
- Backup and Disaster Recovery (BUDR): The CSP implements a robust backup plan tailored to the organisation’s needs.
- Transition Support: The CSP provides assistance during service termination or migration.
- Supplementary Data Transfer: The CSP ensures secure transfer of configuration data and code owned by the organisation.
Supplementary Guidance for Cloud Services
Organisations should build close relationships with CSPs to enhance collaboration and security. Additional best practices include:
- Advance Notification: The CSP should inform the organisation about infrastructure or data storage changes that could impact security.
- Jurisdictional Updates: Notify the organisation if data is moved to a different legal jurisdiction.
- Subcontractor Transparency: Disclose the use of subcontractors and their security implications.
Supporting Annex A Controls
Annex A Control 5.23 aligns closely with the following controls:
- Annex A Control 5.21: Managing information security in the ICT supply chain.
- Annex A Control 5.22: Monitoring and managing supplier services.
These controls ensure cohesive management of supplier relationships, including cloud providers.
Changes from ISO 27001:2013
Annex A Control 5.23 is a new addition to ISO 27001:2022 and did not exist in the 2013 version. It reflects the growing reliance on cloud services and the unique challenges they present in managing information security.
Key areas introduced in this control include:
- Lifecycle Management: Addressing information security across the lifecycle of cloud services, from acquisition to termination.
- Tailored Policies: Encouraging organisations to develop topic-specific policies for cloud services rather than a one-size-fits-all approach.
- Shared Responsibility Model: Emphasising clarity in roles and responsibilities between the organisation and the CSP.
Best Practices for Implementing Annex A Control 5.23
To manage cloud services effectively, organisations should:
- Perform Risk Assessments: Evaluate potential risks associated with cloud services, such as data breaches, service outages, or regulatory non-compliance.
- Regularly Monitor CSP Compliance: Establish reporting and auditing mechanisms to verify that CSPs adhere to agreed-upon security standards.
- Develop Exit Strategies: Plan for secure termination or migration of cloud services to avoid disruptions and ensure data integrity.
- Enhance Staff Training: Train employees on the secure use of cloud platforms and incident response procedures.
How Harpe Can Help Implement ISO 27001:2022 Annex A Control 5.23
Managing cloud services in line with ISO 27001:2022 Annex A Control 5.23 can be complex. Harpe simplifies this process by providing tools to ensure compliance and enhance cloud service security.
- Cloud Service Management: Harpe.io helps track and document all cloud service agreements, ensuring compliance with security requirements.
- Compliance Monitoring: Automatically monitor CSP performance and adherence to your organisation’s information security policies.
- Incident Management Support: Streamline cloud-specific incident response processes to minimise downtime and secure data.
- Transition Planning: Plan and execute secure cloud service terminations or migrations with Harpe.io’s comprehensive tools.
Conclusion
ISO 27001:2022 Annex A Control 5.23 provides a vital framework for managing cloud services securely. By defining clear security requirements, monitoring CSP compliance, and planning for secure transitions, organisations can mitigate risks associated with cloud platforms while maintaining regulatory compliance.
With Harpe, managing cloud services becomes seamless, helping your organisation stay secure and ISO-compliant. Ready to optimise your cloud service management? Get started with Harpe today!
