Corrective actions play a significant role in the implementation of your ISO 27001 certification. A substantial component of the certification process consists of identifying and treating risks. With each risk identified, you need to assess how it will be treated and often perform corrective actions to minimize or avoid said risk. Corrective action consists of improvements to an organization's information security practices taken to eliminate causes of nonconformities or risks. The corrective action that follows a nonconformity is a crucial part of the ISMS improvement process that must be evidenced along with other relevant consequences of nonconformity. Even after you have earned your ISO 27001 certificate, you must still undergo continuous audits, performance reviews, and maintenance on your ISMS. This is to ensure continuous success and maximum effectiveness. Even further, new risks may arise, so it is essential to monitor and make changes to your ISMS regularly. For this reason, corrective actions are imperative, so it is crucial to realize how best to perform them.
The protocol for corrective actions is detailed in ISO 27001 clause 10.1. This clause lays out the process for organizations to follow to meet the standard of the continuous improvement requirement outlined in clause 10.2. As specified in the clause, a simple process approach includes:
- Identify the nonconformity
- React; correct and control the nonconformity and deal with the consequences
- Evaluate if there is a root cause that should be addressed
- Review the effectiveness of any changes or interventions
- Make changes to the ISMS as needed
For maximum effectiveness, ensure that work done throughout the process is accurately documented. Depending on your organization, this may require sign-off and approval procedures to consider within the process.
It may seem as though many processes required by ISO 27001 are mere formalities with no real practical use. Many may view corrective actions this way, but they serve a real and beneficial purpose in your company if performed correctly. The technology sector is changing every day, filled with new developments and advancements, in addition to new cybersecurity threats, competitors, and market changes. For any organization to survive these fluctuations, it must make continuous improvements in its operations. These improvements are corrective actions, and you have probably been performing them without knowing. Performing improvements on a daily basis is a necessity to keeping your operations efficient and effective, allowing you to identify and correct problems as they present themselves. Not only does this allow you to solve the issues and bounce back from them quickly but making a note of nonconformities can help you to spot weaknesses in your operations that should be improved for long-term success.
ISO 27001 requires corrective actions to be handled in a specific way, ensuring that your organization explicitly states where nonconformities are to be reported, who needs to review them and make a decision, who is responsible for eliminating said conformity, and more. This method makes performing corrective actions extremely transparent, ensuring that the entire organization is aware of changes and how to implement them. It is crucial that should a nonconformity arise, it has already been determined who is responsible for resolving the problem and how they will do it. This system guarantees a swift and effective corrective action is taken for each nonconformity.
Initiating Corrective Actions
For corrective actions to be as effective as possible, you must understand how to initiate them properly. First and foremost, you must understand who in your organization can raise a corrective action. The answer is – anyone! Anyone in your company can present a corrective action, including any partners or suppliers who have an impact on your ISMS. A corrective action can be raised in response to various operations in any aspect of the company, which is why anyone can raise them. They may be raised as a result of an internal audit report, because of the results of testing, or simply because someone found a better way to write a policy. With more team members available to offer insights and identify nonconformities, you will have more corrective actions to take, which is good! The more improvements you have to make means that your ISMS will be significantly improved and optimized. It’s also important to note that corrective actions can be big or small. While one may be to rewrite a policy, a corrective action could also require an entire business strategy to be redefined in order to meet objectives.
There is also documentation that must be done to initiate corrective actions. While tedious, documenting these changes and decisions is an excellent way to track improvements and analyze their effectiveness. You will need to obtain two primary required documents: the corrective action procedure and corrective actions. The corrective action procedure defines the basic rules for resolving corrective actions. This will determine how your organization will raise corrective actions, where to document them, who has to make appropriate decisions, and how to control the execution of actions. The second document is the corrective action document which is the physical record of nonconformities and the decisions and activities made to resolve them.
You have a few options when it comes to documenting your corrective actions. First, you will need to decide where to document them. Some companies use specially designed paper forms for corrective actions called CARS. While this may seem convenient, they are not very practical. More often than not, the papers get misplaced, and no one knows where to find them, rendering them useless. A better solution is to utilize a help desk or task management tool, which your company likely already has. All you need to do is add another category for corrective actions, and you're good to go! Not only is this an efficient and practical means of documentation, but it is compliant with ISO 27001 as well. Another helpful practice is to merge corrective actions with other management systems. Rather than using three separate databases for your information security, use one. Using the same procedure, system, and database dramatically simplifies the corrective action processes and seamlessly integrates them with other operations. You may also want to consider writing the corrective action procedure. While it is not required by ISO 27001, it is a helpful practice in familiarizing your organization with protocols.
The Final Decision
In the final step of implementing corrective actions, you must make a decision. Each time a corrective action is raised, someone has to decide whether to take action or not. While you will likely want to take corrective action, sometimes it doesn't make sense to. Typically, this decision will be left to the head of the department where the nonconformity is located. Should they decide that action must be taken, they will also determine who is responsible for the corrective action and the deadline for execution. This process may seem cumbersome, but it's likely that you are already doing it without realizing it. The corrective action process merely systemizes how you make improvements in your company, which every organization must do to grow and succeed. Even better, your organization probably already utilizes ISO-compliant technology suited for these actions, so implementing the corrective action process is quick and straightforward. Through efficient use of corrective actions, you are actively improving your company and your ISMS. The ongoing improvement of your operations and systems is the key to resilience and success, so it's time to take action.