ISO 27001 certification isn't just a badge. It's a systematic approach to managing information security that demonstrates to clients, partners, and regulators that you take data protection seriously.
But achieving ISO 27001 compliance in multi-cloud environments presents unique challenges. Your data lives across AWS, Azure, and Google Cloud. Your applications span containers, serverless, and VMs. How do you implement rigorous security controls across this landscape?
This checklist breaks down ISO 27001 requirements for cloud organizations.
Understanding ISO 27001 in Cloud Context
ISO 27001 provides a framework for managing sensitive information. In cloud environments, you're responsible for security IN the cloud (applications, data, configurations) while your provider handles security OF the cloud (infrastructure, network).
Phase 1: Foundation
1. Define Your ISMS Scope
- Document which systems, data, and processes are covered
- Identify all cloud services in scope
- Map data flows across platforms
- Define boundaries clearly
2. Conduct Risk Assessment
- Identify security risks across cloud infrastructure
- Evaluate likelihood and impact
- Prioritize based on business impact
- Document risk treatment decisions
Cloud-specific risks:
- Misconfigured S3 buckets or Azure storage
- Over-permissioned IAM roles
- Unencrypted data
- Lack of network segmentation
- Insufficient logging
- Inadequate backup and disaster recovery
3. Create Statement of Applicability
- Review all 93 ISO 27001 Annex A controls
- Determine which apply to your organization
- Document justification for exclusions
Phase 2: Implement Controls
Access Control (A.9)
- Implement least privilege across all platforms
- Enforce MFA for cloud console access
- Use identity federation for centralized auth
- Implement just-in-time access
- Review permissions quarterly
Cryptography (A.10)
- Encrypt all data at rest (AES-256+)
- Enforce TLS 1.2+ for data in transit
- Use cloud provider KMS or HSM services
- Rotate encryption keys per policy
Operations Security (A.12)
- Implement change management
- Use Infrastructure as Code (Terraform, CloudFormation)
- Maintain dev/staging/prod separation
- Configure centralized logging
- Establish backup and recovery procedures
Communications Security (A.13)
- Implement network segmentation using VPCs
- Configure security groups and network ACLs
- Use private endpoints for service communication
- Implement WAF for internet-facing apps
- Enable DDoS protection
System Development (A.14)
- Integrate security into CI/CD pipelines
- Implement code scanning (SAST/DAST)
- Scan container images for vulnerabilities
- Review and approve infrastructure changes
Incident Management (A.16)
- Define incident response procedures
- Implement automated alerting
- Establish communication protocols
- Document playbooks
- Conduct post-incident reviews
Business Continuity (A.17)
- Implement multi-region or multi-AZ deployments
- Define RTO and RPO requirements
- Test backup restoration regularly
- Document disaster recovery procedures
Phase 3: Documentation
Required documents:
- Information Security Policy
- Access Control Policy
- Incident Management Procedure
- Business Continuity Plan
- Risk Management Procedure
- Change Management Procedure
- Data Classification Policy
- Cloud Security Standards
Training:
- Security awareness for all staff
- Specialized training for cloud engineers
- Document training completion
Monitoring:
- Define security metrics and KPIs
- Conduct monthly security reviews
- Track control effectiveness
- Report to management regularly
Phase 4: Certification
Stage 1: Documentation Audit
- Engage accredited certification body
- Prepare all documentation
- Address Stage 1 findings
Stage 2: Operational Audit
- On-site or virtual assessment
- Demonstrate control operation
- Address non-conformities
Ongoing:
- Surveillance audits every 6-12 months
- Maintain continuous improvement
- Recertification every 3 years
Timeline Expectations
- Small organization (under 50 people): 6-9 months
- Medium organization (50-250 people): 9-12 months
- Large organization (250+ people): 12-18 months
With existing frameworks (SOC 2): 4-6 months
Common Pitfalls
- Assuming cloud provider handles everything - They secure infrastructure, you secure configurations and data
- Inconsistent security across platforms - Different teams using different standards
- Inadequate logging - Enabled but never reviewed
- Over-permissioned IAM - Started broad, never reduced
- Lack of automation - Manual processes don't scale
The Bottom Line
ISO 27001 in cloud requires systematic implementation across identity, encryption, network security, monitoring, and incident response. Treat compliance as an ongoing program, not a one-time project.
Need help with ISO 27001 in your cloud environment? Our certified experts can assess your posture and build a roadmap to certification. Schedule a security assessment.
About Flat Rock Technology
Flat Rock Technology holds ISO 27001, ISO 9001, and CyberEssentials certifications. With 16 years helping organizations implement security controls in AWS, Azure, and Google Cloud, we provide expertise to achieve and maintain ISO 27001 compliance.
