You are performing an ISO 27001 ISMS surveillance audit at a residential nursing home, ABC Healthcare Services. ABC uses a healthcare mobile app designed and maintained by a supplier, WeCare, to monitor residents’ well-being. During the audit, you learn that 90% erf the residents’ family members regularly receive medical device advertisements from WeCare, by email and SMS once a week. The service agreement between ABC and WeCare prohibits the supplier from using residents’ personal data. ABC has received many complaints from residents and their family members.

You are performing an ISO 27001 ISMS surveillance audit at a residential nursing home, ABC Healthcare Services. ABC uses a healthcare mobile app designed and maintained by a supplier, WeCare, to monitor residents’ well-being. During the audit, you learn that 90% erf the residents’ family members regularly receive medical device advertisements from WeCare, by email and SMS once a week. The service agreement between ABC and WeCare prohibits the supplier from using residents’ personal data. ABC has received many complaints from residents and their family members.

The Service Manager says that the complaints were investigated as an information security incident which found that they were justified. Corrective actions have been planned and implemented according to the nonconformity and corrective action management procedure.

You write a nonconformity "ABC failed to comply with information security control A.5.34 (Privacy and protection of PII) relating to the personal data of residents’ and their family members. A supplier, WeCare, used residents’ personal information to send advertisements to family members"

Select three options of the corrections and corrective actions listed that you would expect ABC to make in response to the nonconformity

A. ABC confirms that information security control A.5.34 is contained in the Statement of Applicability (SoA)

B. The Service Manager provides evidence of analysis of the cause of nonconformity and how the

ABC evaluates the effectiveness of implemented corrective actions

C. ABC instructs all staff to follow the signed healthcare service agreement with residents’ family members

D. ABC conducts a management review to take the feedback from residents’ family members into consideration

E. ABC needs to collect more evidence on how the organisation defines the management system scope and find out if they covered WeCare the medical device manufacturer

F. ABC identifies and checks compliance with all applicable legislation and contractual requirements involving third parties

G. The Service Manager implements the corrective actions and Customer Service Representatives evaluate the effectiveness of implemented corrective actions

H. ABC needs to collect more evidence on how information security risk assessment relates to the identified nonconformities before concluding actions on the nonconformity

Answer: B, F, G

Explanation:

According to the ISO/IEC 27001:2022 Lead Auditor (Information Security Management Systems) course, the following corrections and corrective actions are expected from ABC in response to the nonconformity:

B. The Service Manager provides evidence of analysis of the cause of nonconformity and how the ABC evaluates the effectiveness of implemented corrective actions. This is part of the requirement of clause 10.1 of ISO/IEC 27001:2022, which states that the organization shall determine the causes of nonconformities and evaluate the need for action to ensure that they do not recur or occur elsewhere12. The organization shall also evaluate the effectiveness of any corrective actions taken12.

F. ABC identifies and checks compliance with all applicable legislation and contractual requirements involving third parties. This is part of the requirement of clause 4.2 of ISO/IEC 27001:2022, which states that the organization shall determine the external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its information security management system12. This includes the legal and contractual requirements related to the information security aspects of the organization’s activities, products and services12.

G. The Service Manager implements the corrective actions and Customer Service Representatives evaluate the effectiveness of implemented corrective actions. This is part of the requirement of clause 10.1 of ISO/IEC 27001:2022, which states that the organization shall implement any action needed and retain documented information as evidence of the results of any action taken12. The organization shall also monitor, measure, analyze and evaluate the information security performance and the effectiveness of the information security management system12.

Reference: 1: ISO/IEC 27001:2022 Lead Auditor (Information Security Management Systems) course, CQI and IRCA Certified Training, 1

2: ISO/IEC 27001 Lead Auditor Training Course, PECB, 2

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