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ISO 27001
An ISO 27001 programme plan: who does what, and which decisions come first.
The certification guide explains the audit stages and the cycle. This page is the project view: the order of work inside your company, the people who carry it, the artefacts each phase leaves behind, and the decisions that stall a programme when nobody owns them.
Back to ISO 27001 services01 · First ten decisions
The first ten decisions leadership has to make
Most delays trace back to one of these being left open.
- Why we are certifying, in one sentence a buyer would recognise.
- What is in scope: which products, sites, teams and systems.
- Who owns the ISMS day to day, with time set aside for it.
- Who the executive sponsor is, and how often they will meet the owner.
- Which risk method we will use, and who approves risk acceptance.
- How much risk we are willing to accept, in words the team can apply.
- Build or buy: in-house effort, outside help, or a compliance tool, or a mix.
- Which certification body, and that it is accredited for ISO 27001.
- Who performs the internal audit, given that they must be objective.
- What budget covers fixes the gap analysis will reveal.
02 · The phases
Five phases from decision to audit
Each phase ends with artefacts you can point to.
Mobilise
Turn the decision into a funded project with owners.
- What happens
- Agree the ten decisions above
- Name the ISMS owner and sponsor
- Brief the team leads whose areas are in scope
- You get
- Project charter
- Draft scope
- Owner list
- Good practice
- A sponsor who attends the first steering meeting
- Scope tied to what buyers actually buy
- Watch for
- Starting work before an owner has time for it
Understand
Learn the context, the gaps and the risks.
- What happens
- Context and interested parties
- Gap analysis against clauses and Annex A
- Asset inventory and risk assessment
- You get
- Context register
- Gap report
- Risk register
- Scope statement
- Good practice
- Asset owners score their own risks
- Record controls you already run
- Watch for
- Copying a template risk register
Decide and document
Choose controls and write what you will do.
- What happens
- Risk treatment plan
- Statement of Applicability
- Policy and procedure set
- Objectives and measures
- You get
- Treatment plan
- SoA
- Approved policies
- Objectives
- Good practice
- Describe how you work, not an ideal company
- Approval by the right level
- Watch for
- Writing documents nobody will follow
Operate
Run the controls long enough to have records.
- What happens
- Close the gaps by priority
- Train staff
- Collect evidence as it is produced
- Handle incidents and changes through the new process
- You get
- Control evidence
- Training records
- Metrics
- Good practice
- Evidence collected as you go, not at the end
- Watch for
- Controls switched on the week before the audit
Check and present
Audit yourself, review as leadership, then face the certification body.
- What happens
- Internal audit
- Corrective actions
- Management review
- Stage 1 and Stage 2 with the certification body
- You get
- Internal audit report
- Corrective action log
- Review minutes
- Good practice
- Leave time to fix internal audit findings
- Watch for
- A management review that is only a slide deck
For what happens inside Stage 1 and Stage 2 and after them, see the certification guide. This roadmap stops where the certification body begins.
03 · Who does what
Roles by phase
R does the work, A answers for it, C is consulted, I is informed.
| Phase | Executive sponsor | ISMS owner | Risk and control owners | Engineering and IT | HR and legal | Internal auditor |
|---|---|---|---|---|---|---|
| Mobilise | A | R | I | I | I | I |
| Understand | C | A | R | R | C | I |
| Decide and document | A (policy, risk acceptance) | R | R | C | C | I |
| Operate | I | A | R | R | R | I |
| Check and present | R (management review) | A | C | C | C | R (internal audit) |
Two lines matter most. The sponsor must own risk acceptance and the management review; delegating those empties them. The internal auditor must not audit their own work, so in a small company it is often an outside party or a colleague from a different area.
04 · Typical blockers
What usually stalls a programme
Not technology. Time, ownership and scope.
- An owner with no time. The ISMS becomes the fifth job of a busy engineering lead and quietly stops.
- Scope that keeps moving. Every new product added mid-project resets risk work and evidence.
- Waiting on policy approval. Drafts sit unsigned because nobody booked the sponsor's time.
- Tool first, process second. A platform bought before decisions are made fills with unused templates.
- HR and legal brought in late. Screening, contracts and disciplinary process are people controls, and they take time to change.
- Evidence collected at the end. Gaps in records cannot be fixed retrospectively.
Sources: ISO/IEC 27001:2022 clauses 4 to 10 (public titles only; the standard's text is not reproduced); ISO/IEC 17021-1 for the role of the certification body.
Roadmap questions
Who should be the ISMS owner?
Someone with authority to get things done and time to do it.
Often a security lead, head of engineering or operations manager. Seniority helps because the role chases other teams. What fails is a title without protected time.
Should we buy a compliance tool before starting?
Decide scope and method first, then pick tools to fit.
Tools help with evidence collection and tracking. They do not make the ten decisions for you, and a tool's default templates can pull you towards documents that do not match how you work.
Can phases overlap?
Yes, and they usually do.
Fixing an obvious gap does not need to wait for the full risk register. Keep the sequence of decisions intact: scope before risk, risk before control choice.
When should we book the certification body?
Early, once scope is clear.
Certification bodies plan audits ahead. Contacting them once scope is stable lets you agree audit dates that fit your operate phase, and confirm they hold accreditation for ISO 27001.
Related guides
Start with the right ten decisions.
An ISO 27001 gap analysis gives you the scope, the gaps and a plan your team can own.