9. Performance evaluation
9.1 Monitoring, measurement, analysis and evaluation
Section titled “9.1 Monitoring, measurement, analysis and evaluation”| What is measured | How | When | Who |
|---|---|---|---|
| The objectives | KPI value recorded in each objective issue | Every ISMS security meeting | Owner of the objective |
| Progress of risk treatment | Open actions in the risk register | Every ISMS security meeting | Information Security Officer |
| Recurring checks | Recurring task issues closed in their period, with outcome | Every ISMS security meeting | Information Security Officer |
| Effectiveness of the ISMS as a whole | Internal audit and management review | Yearly | Internal auditor, Management |
Where a measurement can be automated (a report from GitLab, monitoring or a scanner), the meeting uses that report. Each meeting records its evaluation in its issue; that issue is the evidence.
9.2 Internal audit
Section titled “9.2 Internal audit”- An internal audit takes place every year, before the external audit, as a recurring task.
- The Internal auditor is an external person, so nobody audits their own work.
- The audit programme runs in three-year cycles. Every year the audit covers clauses 4 to 10 and the secure development controls (Annex A 8.25 to 8.31). The other Annex A controls are spread over the three years, so each control is audited at least once per cycle.
- The auditor works like a certification auditor: interviews with the role holders, checks of the evidence in GitLab, and a short audit report stored in the audit issue.
- Findings are classified the way certification bodies do:
Major non-conformity: a requirement that is essential to the standard is not met, for example no risk assessment, no objectives or no internal audit, or several minor non-conformities on the same topic.Minor non-conformity: a requirement is not met in an isolated case, for example two of twenty risks without a treatment plan.Observation: no problem yet, but it may become a non-conformity.Opportunity for improvement: a suggestion; we decide what to do with it.
- Non-conformities go to the non-conformity register and are handled as described in improvement.
9.3 Management review
Section titled “9.3 Management review”- Management reviews the ISMS once a year, after the internal audit, as a recurring task.
- The agenda covers the inputs the standard requires: actions from the previous review, changes in internal and external issues and in the needs of interested parties, the performance of the ISMS (non-conformities, measurement results, audit results, objectives), feedback from interested parties, the risk assessment and treatment, and opportunities for improvement.
- The outcome is decisions on improvements and on changes to the ISMS, including its resources and objectives. The minutes are kept in the review issue.
