Which of the actions presented in scenario 4 is NOT compliant with the requirements of ISO/IEC 27001?

Scenario 4: TradeB. a commercial bank that has just entered the market, accepts deposits from its clients and offers basic financial services and loans for investments. TradeB has decided to implement an information security management system (ISMS) based on ISO/IEC 27001 Having no experience of a management [^system implementation, TradeB’s top management contracted two experts to direct and manage the ISMS implementation project.

First, the project team analyzed the 93 controls of ISO/IEC 27001 Annex A and listed only the security controls deemed applicable to the company and their objectives Based on this analysis, they drafted the Statement of Applicability. Afterward, they conducted a risk assessment, during which they identified assets, such as hardware, software, and networks, as well as threats and vulnerabilities,

assessed potential consequences and likelihood, and determined the level of risks based on three nonnumerical categories (low, medium, and high). They evaluated the risks based on the risk evaluation criteria and decided to treat only the high risk category They also decided to focus primarily on the unauthorized use of administrator rights and system interruptions due to several hardware failures by establishing a new version of the access control policy, implementing controls to manage and control user access, and implementing a control for ICT readiness for business continuity

Lastly, they drafted a risk assessment report, in which they wrote that if after the implementation of these security controls the level of risk is below the acceptable level, the risks will be accepted

Which of the actions presented in scenario 4 is NOT compliant with the requirements of ISO/IEC 27001?
A . Trade B selected only ISO/IEC 27001 controls deemed applicable to the company
B . The Statement of Applicability was drafted before conducting the risk assessment
C . The external experts selected security controls and drafted the Statement of Applicability

Answer: B

Explanation:

According to ISO/IEC 27001:2022, clause 6.1.3, the Statement of Applicability (SoA) is a document that identifies the controls that are applicable to the organization’s ISMS and explains why they are selected or not. The SoA is based on the results of the risk assessment and risk treatment, which are the previous steps in the risk management process. Therefore, the SoA should be drafted after conducting the risk assessment, not before. Drafting the SoA before the risk assessment may lead to inappropriate or incomplete selection of controls, as the organization may not have a clear understanding of its information security risks and their impact.

Reference: ISO/IEC 27001:2022, clause 6.1.3; PECB ISO/IEC 27001 Lead Implementer Course, Module 5, slide 18.