Risk Treatment Plan: Understanding The Importance Of Risk Treatment and Its Effectiveness

Introduction

An Ideal ISO 27001 Risk Treatment Plan; The single most important factor in any information security management system (ISMS) is a sound and effective risk treatment plan. This plan represents how an organization intends to manage the risks identified in the risk assessment. In practice, a risk treatment plan ensures that the organization is able to implement controls and take other actions to reduce or mitigate those risks as specified in ISO 27001 requirements. This blog post explains what an ISO 27001 risk treatment plan is, highlights its important elements, describes the main options (strategies) for risk treatment, and sets out how to develop, execute, and sustain an effective plan.

What Is An ISO 27001 Risk Treatment Plan? 

An ISO 27001 risk treatment plan is an in-depth document drawn up following the risk assessment. It "outlines how an organization will manage and treat risks identified in the risk assessment process. In other words, it takes the findings of a risk assessment into the realm of action. The document would generally include information regarding each identified risk as well as the selected mitigation strategy. This is considered as separate from the overall risk management plan: the risk management plan looks at the whole process (identification, assessment, treatment, monitoring), and the risk treatment plan aims specifically at their alleviation or control.

Under industry guidelines, a solid ISO 27001 risk treatment plan greatly increases the odds that denied controls will actually be implemented. DataGuard defines it as "an exhaustive account of controls implementation to decrease the possibility or consequence of risks". In practice, it is implemented after assessing and prioritizing risks. Usually, the plan ends with a Statement of Applicability (SoA), a mandatory document under ISO 27001 describing which controls (from Annex A or elsewhere) the organization will implement and why.

A well-structured risk treatment plan should align with the overall risk appetite and compliance objectives of the organization. The risk treatment plan assigns risks to owners, states deadlines, and mentions resources required for each mitigation action. In short, it serves as a blueprint toward implementing all security measures required to address identified risks. 

Key Components Of A Risk Treatment Plan

An exhaustive risk treatment plan should capture all crucial elements to ensure that the treatment process is clear and easily operationalized. Commonly included are:

• Risk overviews: A brief description of each identified risk or vulnerability (what could go wrong).
  
  

• Risk treatment: The response strategy or available option chosen for each risk (e.g. mitigation, avoidance, transfer, or acceptance) and controls or actions specifically planned.
  
  

• Risk owners: Individuals responsible for monitoring each risk. These owners are responsible for taking care of risk treatment.
  
  

• Action Owners: People designated to implement the mitigation actions or controls assigned to each risk.
  
  

• Timeline: Targets for completion of risk treatment activities, an aspect ensuring the plan remains on target. 
  
  

• Resources: All relevant human, technical, and financial resources needed to implement the selected treatments. 
  
  

• Success criteria: How success will be measured (such as reduced risk score, audit results, or other performance indicators). 

ISO 27001 Risk Treatment Options (Strategies)

When treating risks, ISO 27001 identifies four main risk treatment options (strategies) as the high-level approaches for the management of risks:

ISO 27001 provides four major options to deal with risks. Each one allows you to treat a risk by either avoiding it, mitigating (reducing) it, transferring it, or accepting it. In picking the most suitable option, the organization has to balance among risk impact, likelihood, cost, compliance and many other factors. Logically, most of the time risk reduction or mitigation is the most common option as it improves security by increasing the number of controls present. On the other hand, risks that are extremely costly to mitigate, or impossible to mitigate, may be accepted or transferred. Similarly, if a business process poses extreme risk, it may be best to avoid undertaking that activity altogether.

• Risk Avoidance: Eliminate the risk by not engaging in the risky activity or changing processes so the threat can no longer occur. For example, discontinuing a project that poses unacceptable security risk. This means avoiding any possibility of the risk by tightening processes, modifying business processes, or stopping activities that are highly risk-worthy, according to Scytale. While avoidance resolves the threat, it may impact the business operations.
  
  

• Risk Reduction (Mitigation): Reduce the likelihood or impact of the risk via implementing security controls or effecting changes. This is mostly adopted. Likely measures involved are implementing technical controls (e.g. encryption, access controls, firewalls) or improving processes (e.g. training, incident response plans). For instance, the use of multi-factor authentication cuts down risks related to unauthorized access. The organization continues to operate but with the risk reduced to an acceptable level and with greater safeguards.
  
  

• Risk Transfer (Sharing): Transferring the risks or part of the risk to a third party. Most commonly done through cyber insurance or outsourcing certain functions. For example, by purchasing cyber-insurance, an organization transfers the risk of any potential financial loss to the insurer. Similarly, outsourcing operational responsibilities that carry a risk may allow some sharing of that risk. Transfer does not reduce the risk per se but instead ensures that an external party absorbs part of the impact.
  
  

• Risk Acceptance: Accept the risk without adding any more controls due to low risk or the cost of mitigation outweighs the benefits. In such a case, the organizations "agree to tolerate the risk". For example, accepting minor vulnerabilities in non-critical systems because it would be too expensive to fix them versus the little gain. Accepted risks should still be documented and periodically reviewed since the risk landscape changes.

ISO 27001 Requirements For Risk Treatment

There are also changes and additions to the frameworks that reflect the importance of risk treatment. For instance, in the revision of ISO 27001:2022, under section 6.1.3 added states, "an organization must select appropriate risk treatment options." This essentially means that after assessing risks, the organization needs to deal with every single risk using the above listed options.

One interpretation is that the standard demands the organizations to take controls from Annex A as a baseline for treatment. Annex A comprises a few lists of security controls (93 controls in ISO/IEC 27001:2022 and divided into 4 domains), covering many of the standard information security risks. Annex A "includes the control objectives but the controls listed are not exhaustive," according to the standard. This signifies that organizations might, and actually required to, consider adding controls as dictated by the need; however, it signifies that Annex A is the formal entry point for mitigation.

After selection of treatment options or any applicable controls, ISO 27001 demands an explication of such choices. This process is done mainly through the SoA. The SoA is a document of necessity prescribing that all controls of Annex A should be specified along with an indication as to which ones are operational (to mitigate identified risks) and which are not with justifications. The risk treatment plan should correspond to the SoA: for each of the risks, it must contain the control (from the SoA) that will be used to treat it, along with other required actions. The risk treatment plan, apart from Clause 6.1.3, would also support some other most popular clauses of ISO 27001, for instance, Clause 8 (Operation) asks the application of risk treatment plan and maintains evidence of it. The auditor will look evidence that show the treatment done and also review annually as well.

Developing A Risk Treatment Plan

The process of formulating a Risk Treatment Plan involves creating an ISO 27001 risk treatment plan, which constitutes a series of coordinated actions usually undertaken after a risk assessment is completed. The simplified overview would be:

1. Select a Risk Assessment Methodology: Decide on risk assessment as quantitative, qualitative, or a hybrid method. The method selected should be consistent with and aligned with the business objectives. This methodology defines the scoring and prioritization of risks.

2. Identify and Assess Risks: Create a catalogue of information assets, identifying threats/vulnerabilities affecting them. Risk should be evaluated in terms of likelihood and impact according to your method, leading to an ordered list of risks. At this stage, you should identify your own appetite for risk and what levels of risk (if any) you are willing to accept outright.

3. Determine Risk Treatment Strategies: For each significant risk, make a choice between avoid, reduce, transfer, or accept option. Most organizations transfer or avoid extreme risks when risk mitigation is not feasible and reduce (mitigate) medium to high risks with controls. Only trivial risks are fully accepted. “Deciding the risk treatment strategies for each risk type — avoidance, acceptance, reduction, or transfer”

4. Choose Controls and Prepare the SoA: For any risk that will be reduced, certain controls must be selected for implementation. This often means that relevant controls listed in ISO 27001 Annex A will be selected. Prepare or update the Statement of Applicability to include those controls with justifications for their inclusion. This public SoA will give auditors a justification on your controls.

5. Assign Owners and Resources: Each control/action will have an assigned owner responsible for implementing it. Resources will also be allocated (budget, staff time, technology) for the implementation of each risk treatment action. Make sure the risk owners are aware of what their responsibilities.

6. Document the Plan: All the above information must be put together into the plan document. The plan must demonstrate a clear relationship between each risk, the treatments and controls selected for it, the owner, the timeline, and the resources. Templates often have columns for Risk ID, Description, Treatment Option, Controls/Actions, Owner, Deadline, Status, etc.

7. Implement Controls and Actions: Implement the controls by carrying out the requirements laid out in the plan by establishing controls, modifying processes, purchasing insurance, or otherwise acting on the chosen strategies. Training should be provided on these subjects, and the plan should then be communicated to all stakeholders.

8. Monitor and Review: Controls are monitored continuously in terms of effectiveness while assessing whether risks are currently being managed as expected or otherwise. Security incidents or changes of context that will affect risk probabilities are tracked. The risk treatment plan will be updated regularly (for example, once a year or after substantial changes) to accommodate new risks or modifications, assuring that the plan will remain relevant and useful. 

Implementing And Maintaining The Risk Treatment Plan

As development comes in, implementation is a very shared task. The common pitfall assignments include accountability and buy-in. The risk treatment plan needs to be implemented; otherwise, it will merely be viewed as a written thing. A few good practices are given below:

• Management Approval: Prior to rolling out the plan, it is preferable to have the formal agreement of senior management. This will affirm that the organization stands by the actions of the plan.
  
  

• Integration with ISMS: Treat the risk treatment plan as one of your ISMS documents. Tie its controls into existing security policies and processes.
  
  

• Communication: Communicate risk treatment plans to all relevant staff and stakeholders. Everyone involved should understand their role. Provide training regarding new controls or procedures.
  
  

• Continuous Monitoring: Use metrics, audits and reviews to verify maintenance of operational controls. As for example, incident rates, control test results, and policy compliance tracking can be used as an objective to measure performance. Any failed control or changed business risk should trigger an update to the plan.
  
  

• Risk Acceptance Records: Keep proper documentation (like risk acceptance form) for all accepted risks, specifying who approved them and why. Keep under review, as changing circumstances may warrant new treatment.
  
  

• Change Management: Treat change to controls or new technology during risk treatment. When a new system comes on board, reassess risks and adjust the plan accordingly.

Conclusion

Some ISO 27001 risk treatment plans stand for a vital deliverable of any ISO 27001 implementation. They bridge the gap between risk assessment and actionable security controls. By documenting how each identified risk will be treated-whether through avoidance, mitigation, transfer, or acceptance- organizations can manage information security more actively. This comprehensive documentation contains summaries of the risks, chosen risk treatment options, controls/actions, owners, timelines, and success criteria. Following ISO 27001 requirements (Clauses 6.1.3 and 8.3), a proper treatment plan aligns with Annex A controls and the Statement of Applicability. It should be embedded into the ISMS, adopted with management support, and continuously reviewed.