Preparing for ISO/IEC 27001:2022
| Title | Preparing for ISO/IEC 27001:2022 |
| Doc# | DOC-COMPL-003 |
| Version | 1.1 |
| Date | 05-03-2025 |
ISO/IEC 27001:2022 certification-readiness is the board mandate that came out of the TSR-INC-2025-031 breach. This note sets out what certification-readiness involves for Tessera and the CISO’s part in it. Certification is earned in two stages: a Stage 1 documentation review and a Stage 2 substantive audit, after which the certification body issues (or declines) the certificate. “Readiness” means being able to evidence the management system and its controls — not just describe them.
What the CISO is accountable for
Operating the ISMS. Owning the management system — the scope, policies, risk assessment and treatment, and the review cycles — and keeping it current against ISO/IEC 27001:2022.
Risk assessment and treatment. Running the risk method (DOC-RISK-002), maintaining the risk register (DOC-SEC-001) and the Statement of Applicability (DOC-SEC-003), and making sure every selected Annex A control has a credible status and evidence.
Awareness and training. Ensuring the workforce understands its obligations and that training is completed and recorded (DOC-EDU-001).
Internal audit and management review. Running internal audit independently of the audited areas, and chairing the annual management review that considers audit results, incidents, risk changes and feedback.
Incident management. Operating the incident response and NDB processes, and feeding post-incident reviews back into the controls and the register.
Continual improvement. Converting incidents, nonconformities and audit findings into corrective actions with owners and dates, and tracking them to closure.
Regulatory and contractual compliance. Ensuring Tessera meets its Privacy Act / APP / NDB obligations and its contractual security commitments, with GDPR and sector schemes applied only where clients bring them into scope.
Liaison with the certification body. Acting as the point of contact for the external auditors, providing accurate evidence and not over-claiming implementation status.
Where Tessera is in the process
Tessera already holds ISO/IEC 27001 certification and SOC 2 Type II, so the management system exists; the work now is the 2022 transition and closing the gaps surfaced by the breach. The SoA records which controls are implemented, partially implemented or in progress, and the corrective actions from TSR-INC-2025-031 — static-key elimination, control-plane / data-plane segmentation, secret scanning, and detection retuning — are the priority items before Stage 2.
TEACHING NOTE: Certification-readiness turns on evidence, not assertion. An Annex A control marked “Implemented” in the SoA is a claim; the Stage 2 audit tests whether the claim holds. The areas most exposed to that test at Tessera are the access and offboarding controls (A.5.15, A.5.18, A.6.5, A.8.2, A.8.3) and the segmentation control (A.8.22), all of which depend on the timeliness and completeness of access revocation and the segmentation remediation.