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ISO 27001 Compliance - Information Security Management

ISO 27001 certification requirements, security controls, audit procedures, information security management systems, and whistleblowing ISMS compliance.

ISO 27001 Compliance

How ISO/IEC 27001:2022 Information Security Management Systems (ISMS) requirements apply to whistleblowing platforms, and how Disclosurely supports your organization's ISO 27001 compliance journey.

What is ISO 27001?

Overview

ISO/IEC 27001 is the international standard for information security management systems (ISMS). It provides a systematic approach to managing sensitive company information, ensuring confidentiality, integrity, and availability.

Published by: International Organization for Standardization (ISO) and International Electrotechnical Commission (IEC) Current Version: ISO/IEC 27001:2022 (published October 2022) Previous Version: ISO/IEC 27001:2013 (still valid during transition period)

Key Principles:

  • Risk-based approach to information security
  • Leadership commitment and accountability
  • Continual improvement through Plan-Do-Check-Act (PDCA) cycle
  • Context-aware security management
  • Documented policies, procedures, and controls

Why ISO 27001 Matters for Whistleblowing

Whistleblowing systems handle some of the most sensitive information in an organization:

  • Confidential reporter identities requiring highest protection
  • Sensitive allegations about misconduct, fraud, or safety issues
  • Investigation evidence that may include personal, financial, or proprietary data
  • Legal and reputational risks if information is compromised

ISO 27001 Benefits:

  • Demonstrates commitment to information security to stakeholders
  • Reduces risk of data breaches and security incidents
  • Builds trust with whistleblowers (essential for effective reporting)
  • Supports compliance with GDPR, SOX, and other regulations
  • Provides competitive advantage in procurement
  • Improves overall security posture

ISO 27001:2022 Structure

Clauses 4-10: Management System Requirements

Mandatory requirements for establishing, implementing, maintaining, and continually improving an ISMS:

Clause 4: Context of the Organization

  • Understand organization and stakeholders
  • Define ISMS scope
  • Establish ISMS

Clause 5: Leadership

  • Top management commitment
  • Information security policy
  • Roles and responsibilities

Clause 6: Planning

  • Risk assessment and treatment
  • Information security objectives
  • Planning to achieve objectives

Clause 7: Support

  • Resources, competence, awareness
  • Communication
  • Documented information

Clause 8: Operation

  • Operational planning and control
  • Information security risk assessment and treatment

Clause 9: Performance Evaluation

  • Monitoring, measurement, analysis, evaluation
  • Internal audit
  • Management review

Clause 10: Improvement

  • Nonconformity and corrective action
  • Continual improvement

Annex A: Security Controls

93 controls across 4 domains (ISO 27001:2022):

Organizational Controls (37 controls)

  • Policies, organization structure, human resources, supplier relationships

People Controls (8 controls)

  • Before, during, and after employment security measures

Physical Controls (14 controls)

  • Secure areas, equipment security, physical access control

Technological Controls (34 controls)

  • Access control, cryptography, network security, system security, etc.

Note: Controls are selected based on risk assessment. Not all controls required for all organizations.

ISO 27001 Requirements for Whistleblowing Systems

Risk Assessment (Clause 6.1.2)

Information Security Risks in Whistleblowing:

Confidentiality Risks:

  • Unauthorized disclosure of reporter identity
  • Breach of investigation confidentiality
  • Insider access to sensitive reports
  • External attack (hacking, phishing)

Integrity Risks:

  • Tampering with report content or evidence
  • Unauthorized modification of investigation records
  • Manipulation of case status or outcomes
  • Falsification of audit trails

Availability Risks:

  • System downtime preventing report submission
  • Ransomware attack on whistleblowing database
  • Denial of service attacks
  • Data loss without backup

Risk Treatment Options:

  1. Avoid: Don't process certain types of high-risk data
  2. Reduce: Implement controls to mitigate risk (most common)
  3. Share: Insurance, outsourcing to certified provider (Disclosurely)
  4. Accept: Document decision to accept residual risk

Disclosurely's Approach: Reduce risk through comprehensive controls aligned with Annex A

Access Control (Annex A.5)

A.5.15 - Access Control

Whistleblowing systems require strict access control to protect confidentiality:

Disclosurely Implementation:

  • Role-based access control (RBAC): Investigators see only assigned cases
  • Least privilege principle: Users granted minimum necessary access
  • Multi-factor authentication (MFA): Additional security layer for sensitive access
  • Session management: Automatic logout after inactivity
  • Access logging: All access recorded in Audit Trail

A.5.16 - Identity Management

Managing user identities and access rights:

  • Unique user accounts (no shared credentials)
  • Regular access reviews (quarterly recommended)
  • Prompt removal of access when role changes or employment ends
  • Privileged access management for admin accounts

A.5.17 - Authentication Information

Securing credentials:

  • Strong password policies (enforced by system)
  • Secure storage (hashed and salted)
  • MFA for high-risk access
  • No hardcoded credentials in code

Cryptography (Annex A.5.33-5.34)

A.5.33 - Protection of Records

Whistleblowing records contain sensitive personal data requiring protection:

Disclosurely Encryption:

  • AES-256 encryption at rest: All report data encrypted in database
  • TLS 1.3 in transit: Encrypted communication between client and server
  • End-to-end encryption: Reports encrypted before leaving reporter's browser
  • Encrypted backups: All backups encrypted with separate key management
  • See Encryption for technical details

A.5.34 - Privacy and Protection of PII

Personal identifiable information (PII) protection:

  • Data minimization (collect only necessary information)
  • Purpose limitation (use only for investigations)
  • Retention limits (automated deletion after retention period)
  • Integration with GDPR Compliance

Security Monitoring and Logging (Annex A.8.15-8.16)

A.8.15 - Logging

Comprehensive logging essential for accountability and security:

Disclosurely Audit Trail:

  • User access to cases (who viewed what, when)
  • Case actions (status changes, assignments, notes)
  • Administrative actions (user management, configuration)
  • Authentication events (login, logout, failed attempts)
  • System events (errors, security incidents)
  • See Audit Trail for complete logging documentation

A.8.16 - Monitoring Activities

Proactive security monitoring:

  • Real-time alerting: Suspicious activities trigger alerts
  • Anomaly detection: Unusual access patterns flagged
  • Failed login monitoring: Multiple failed attempts investigated
  • Security event correlation: Patterns identified across logs
  • See Security Monitoring

Business Continuity (Annex A.5.29-5.30)

A.5.29 - Information Security During Disruption

Whistleblowing system must remain available even during incidents:

Disclosurely Resilience:

  • 99.9% uptime SLA: Redundant infrastructure
  • Disaster recovery plan: Recovery Time Objective (RTO) < 4 hours
  • Geographic redundancy: Data replicated across regions
  • Incident response plan: Documented procedures for security incidents
  • Backup and restore: Daily encrypted backups, tested quarterly

A.5.30 - ICT Readiness for Business Continuity

Technology preparedness:

  • Redundant systems and failover mechanisms
  • Regular disaster recovery testing
  • Documentation of recovery procedures
  • Alternative access methods if primary system unavailable

Supplier Relationships (Annex A.5.19-5.23)

A.5.19 - Information Security in Supplier Relationships

If you use Disclosurely as your whistleblowing provider:

Disclosurely as Supplier:

  • ISO 27001 certification (verify on Security Overview)
  • SOC 2 Type II report available
  • Data Processing Agreement (DPA) for GDPR compliance
  • Security questionnaire responses
  • Regular security assessments

A.5.20 - Addressing Information Security Within Supplier Agreements

Contractual security requirements:

  • Service Level Agreements (SLAs) for availability and security
  • Data protection obligations
  • Incident notification timelines
  • Audit rights (right to audit Disclosurely's controls)
  • Termination and data return provisions

A.5.21 - Managing Information Security in the ICT Supply Chain

Sub-processor management:

  • Disclosurely maintains list of sub-processors (cloud hosting, email delivery)
  • Each sub-processor vetted for security and compliance
  • Contractual protections flow down to sub-processors
  • Notification of sub-processor changes

Secure Development (Annex A.8.25-8.28)

A.8.25 - Secure Development Life Cycle

How Disclosurely develops secure software:

  • Security requirements defined at design phase
  • Threat modeling to identify risks
  • Secure coding standards followed
  • Code reviews (manual and automated)
  • Security testing throughout development

A.8.26 - Application Security Requirements

Security built into application:

  • Input validation to prevent injection attacks
  • Output encoding to prevent cross-site scripting (XSS)
  • Authentication and authorization enforced
  • Session management secure
  • Error handling doesn't leak sensitive information

A.8.28 - Secure Coding

Preventing common vulnerabilities:

  • OWASP Top 10 mitigations implemented
  • SQL injection prevention (parameterized queries)
  • Cross-site scripting (XSS) prevention
  • Cross-site request forgery (CSRF) protection
  • Sensitive data not logged or exposed

Vulnerability Management (Annex A.8.8)

A.8.8 - Management of Technical Vulnerabilities

Ongoing vulnerability management:

Disclosurely Process:

  1. Vulnerability Scanning: Automated weekly scans of infrastructure and applications
  2. Penetration Testing: Annual third-party penetration tests
  3. Patch Management: Security patches applied within 30 days (critical within 7 days)
  4. Vulnerability Disclosure: Security researchers can report vulnerabilities
  5. Remediation Tracking: Vulnerabilities tracked to closure

Supporting Your ISO 27001 Certification

Disclosurely as Control Evidence

If your organization is pursuing ISO 27001 certification, Disclosurely provides evidence for multiple Annex A controls:

Organizational Controls:

  • A.5.2: Information security roles and responsibilities (assign roles in Disclosurely)
  • A.5.10: Acceptable use of information (whistleblowing policy)
  • A.5.12: Classification of information (sensitive case classification)

Technological Controls:

  • A.8.1: User endpoint devices (secure access from any device)
  • A.8.2: Privileged access rights (admin role management)
  • A.8.3: Information access restriction (RBAC)
  • A.8.5: Secure authentication (MFA, strong passwords)
  • A.8.9: Configuration management (system configuration documented)
  • A.8.10: Information deletion (automated retention and deletion)
  • A.8.15: Logging (comprehensive audit trail)
  • A.8.24: Use of cryptography (encryption at rest and in transit)

Audit Evidence from Disclosurely:

  • Screenshots of access control configuration
  • Audit trail reports showing logging
  • Retention policy documentation
  • Encryption configuration
  • User role matrix
  • Security settings documentation

Statement of Applicability (SoA) Guidance

Statement of Applicability documents which Annex A controls apply to your organization and why.

For Whistleblowing System Scope:

Include Controls Related To:

  • Access control (who can access reports)
  • Cryptography (encryption of sensitive data)
  • Operations security (logging, monitoring)
  • Communications security (network protection)
  • System development (secure whistleblowing platform)
  • Supplier relationships (Disclosurely contract)
  • Incident management (breach response)

May Exclude:

  • Physical security (if Disclosurely is cloud-hosted, physical security is Disclosurely's responsibility)
  • Some organizational controls (if not applicable to whistleblowing scope)

Justification Example:

  • Control A.8.24 (Use of cryptography): Applicable. Report data contains sensitive personal information requiring encryption to maintain confidentiality. Implemented via AES-256 at rest, TLS 1.3 in transit.

Internal Audit Support

ISO 27001 requires annual internal audits (Clause 9.2).

Auditing Whistleblowing Controls:

Sample Audit Checklist:

  • Access control: Review user access rights, confirm least privilege
  • Authentication: Verify MFA enabled for privileged users
  • Logging: Confirm audit trail captures all required events
  • Encryption: Verify encryption enabled for data at rest and in transit
  • Retention: Check retention policies configured and automated deletion working
  • Backups: Confirm backups occurring and test restore
  • Incident response: Review any security incidents related to whistleblowing system
  • Supplier management: Review Disclosurely contract, verify certifications current

Disclosurely Support:

  • Documentation for auditors
  • Access to audit trail reports
  • Configuration screenshots
  • Security certificates (ISO 27001, SOC 2)

Management Review Input

ISO 27001 requires regular management review (Clause 9.3) to ensure ISMS effectiveness.

Whistleblowing System Metrics for Management Review:

  • Security incidents involving whistleblowing data (target: zero)
  • Failed login attempts and suspicious activity (trend analysis)
  • Audit trail completeness and retention
  • System availability and uptime
  • Compliance with access control policies
  • Results of penetration tests or security assessments
  • User training completion rates
  • Data subject rights requests handled

Generate Reports: Disclosurely compliance dashboard provides metrics

Implementation Best Practices

Step 1: Define Scope

Determine if whistleblowing system is in scope for your ISMS:

Whistleblowing In Scope If:

  • Processing sensitive information
  • Regulatory requirement (EU Directive, SOX)
  • Reputational risk if compromised
  • Board-level importance
  • Customer or partner requirement

Scope Definition:

  • "Disclosurely whistleblowing platform including all report submissions, investigations, and case management processes"
  • Boundaries: What's included/excluded
  • Interfaces: Integration with HR systems, case management, email

Step 2: Risk Assessment

Conduct information security risk assessment for whistleblowing system:

Identify Assets:

  • Report data (allegations, evidence, attachments)
  • Reporter identities (for confidential reports)
  • Investigation records
  • User credentials
  • System configuration

Identify Threats:

  • External attack (hacking, malware)
  • Insider threat (unauthorized access)
  • Accidental disclosure
  • System failure
  • Data loss

Assess Likelihood and Impact:

  • Rate each risk scenario
  • Determine risk level (low, medium, high, critical)
  • Prioritize for treatment

Select Controls: Choose Annex A controls to reduce risk

Step 3: Implement Controls

Deploy technical and organizational controls:

Technical Controls (Disclosurely provides):

  • Encryption, access control, MFA, logging, monitoring, backups

Organizational Controls (Your responsibility):

  • Whistleblowing policy
  • User training
  • Access review process
  • Incident response plan
  • Supplier management (Disclosurely contract)

Step 4: Document Everything

ISO 27001 requires documented information:

Required Documents:

  • ISMS scope
  • Information security policy
  • Risk assessment and treatment results
  • Statement of Applicability (SoA)
  • Control implementation evidence
  • Competence evidence (training records)
  • Monitoring and measurement results
  • Internal audit results
  • Management review results

Whistleblowing-Specific Documentation:

  • Whistleblowing policy (information security aspects)
  • Access control matrix (who can access what)
  • Encryption configuration
  • Retention policy
  • Incident response procedures for whistleblowing breaches
  • Data Processing Agreement with Disclosurely
  • Disclosurely security certifications

Step 5: Train Users

ISO 27001 Clause 7.2 - Competence:

All users must be trained on:

  • Information security policies
  • Their roles and responsibilities
  • How to use whistleblowing system securely
  • Recognizing security threats (phishing, social engineering)
  • Incident reporting procedures

Disclosurely Training Resources:

  • User guides for secure platform use
  • Best practices for investigators
  • Security awareness content
  • Role-specific training materials

Step 6: Monitor and Improve

Ongoing ISMS maintenance:

Continuous Monitoring:

  • Review security logs (Disclosurely audit trail)
  • Monitor failed login attempts
  • Track security incidents
  • Measure control effectiveness

Internal Audits (annual minimum):

  • Audit whistleblowing controls
  • Identify nonconformities
  • Implement corrective actions

Management Review (annual minimum):

  • Review ISMS performance
  • Decide on improvements
  • Allocate resources

Continual Improvement:

  • Lessons learned from incidents
  • Control enhancements
  • Process optimization

ISO 27001 Certification Process

Achieving Certification

If your organization seeks ISO 27001 certification:

Phase 1: Gap Analysis (1-2 months)

  • Assess current state vs. ISO 27001 requirements
  • Identify gaps
  • Develop implementation plan

Phase 2: ISMS Implementation (6-12 months)

  • Implement required controls
  • Document policies and procedures
  • Train staff
  • Operate ISMS for at least 3 months (best practice)

Phase 3: Internal Audit (1 month)

  • Conduct internal audit
  • Identify and correct nonconformities
  • Management review

Phase 4: Certification Audit (2-3 months)

  • Stage 1: Documentation review
  • Stage 2: On-site audit of implementation
  • Corrective actions if needed
  • Certificate issued if successful

Phase 5: Surveillance Audits (ongoing)

  • Annual surveillance audits
  • 3-year recertification audit

Certification Body Selection

Choose accredited certification body:

  • UKAS (UK), ANAB (US), DAkkS (Germany), COFRAC (France)
  • Experience auditing similar organizations
  • Reasonable audit fees
  • Availability and scheduling

Disclosurely Note: Disclosurely is ISO 27001 certified. You're leveraging a certified supplier.

Integration with Other Compliance Frameworks

ISO 27001 + GDPR

Complementary frameworks:

  • ISO 27001 focuses on information security management
  • GDPR focuses on personal data protection
  • Significant overlap in controls (encryption, access control, logging)

Synergies:

  • ISO 27001 risk assessment informs GDPR DPIA
  • ISO 27001 incident management supports GDPR breach notification
  • ISO 27001 access controls support GDPR data subject rights
  • See GDPR Compliance for integration details

ISO 27001 + SOX

For public companies:

  • SOX Section 301: Audit committee whistleblowing channel
  • SOX Section 404: Internal controls over financial reporting
  • ISO 27001 controls can support SOX compliance
  • Integrated control framework reduces duplication
  • See SOX Compliance

ISO 27001 + EU Whistleblowing Directive

Whistleblowing compliance:

  • EU Directive requires secure, confidential reporting channels
  • ISO 27001 provides security framework
  • Combined approach ensures both regulatory compliance and security
  • See EU Whistleblowing Directive

Common Challenges and Solutions

Challenge 1: Resource Constraints

Problem: ISO 27001 implementation requires time, people, budget

Solutions:

  • Use Disclosurely (certified supplier reduces your burden)
  • Start with narrower scope (whistleblowing only, expand later)
  • Leverage existing controls and documentation
  • Use ISO 27001 templates and tools
  • Consider consultant support for initial implementation

Challenge 2: Maintaining Documentation

Problem: Keeping ISMS documentation current as systems change

Solutions:

  • Document management system with version control
  • Assign document owners
  • Regular review schedule (annual minimum)
  • Link documentation to change management process
  • Keep documentation simple and practical (not unnecessarily complex)

Challenge 3: User Adoption and Training

Problem: Users don't follow security procedures

Solutions:

  • Make security easy (MFA built into login, encryption automatic)
  • Regular training and awareness campaigns
  • Explain "why" not just "what"
  • Leadership commitment and tone from the top
  • Recognize and reward good security behavior

Challenge 4: Demonstrating Continual Improvement

Problem: ISO 27001 requires continual improvement, not just maintaining status quo

Solutions:

  • Track security metrics and KPIs
  • Review security incidents for lessons learned
  • Stay current with emerging threats and vulnerabilities
  • Regularly assess new controls
  • Engage with security community and best practices
ISO 27001 Compliance - Information Security Management | Disclosurely Docs