- Clause 4: Context of the organisation
- Identify internal and external issues and the needs of interested parties, such as SAMA, the National Cybersecurity Authority (NCA), customers and card schemes. Document the ISMS scope: the sites, processes, systems and teams it covers, and its interfaces with everything outside it.
- Clause 5: Leadership
- Top management approves the information security policy, assigns roles and authorities, and supplies the resources. Auditors interview leadership, not only the security team.
- Clause 6: Planning
- Define a repeatable risk assessment method, assess and treat risks, and produce the Statement of Applicability. Set measurable security objectives. Clause 6.3, new in 2022, requires changes to the ISMS to be carried out in a planned manner.
- Clause 7: Support
- Resources, competence, awareness, communication and documented information. Training records, role descriptions and document control live here.
- Clause 8: Operation
- Run the planned processes, repeat risk assessments at planned intervals and on significant change, execute the risk treatment plan, and control externally provided processes, products and services.
- Clause 9: Performance evaluation
- Monitor and measure what matters, run internal audits on a planned programme, and hold management reviews with defined inputs, decisions and actions.
- Clause 10: Improvement
- Handle nonconformities through correction, root-cause analysis and corrective action, and improve the ISMS continually.
- Annex A: Controls reference
- A list of 93 controls you compare with your risk treatment, so no necessary control is overlooked. Every requirement in clauses 4 to 10 is mandatory for conformity. An Annex A control can be excluded only with a documented justification.