Monitoring, review and change management of supplier services
On a regular basis the organization is to monitor, review and evaluate suppliers' security practices and service delivery and to manage changes to them.
What the requirement asks
On a regular basis the organization is to monitor, review and evaluate suppliers' security practices and service delivery and to manage changes to them. Purpose: keep information security and service delivery at the level set in the supplier agreements. Guidance: this oversight should confirm that the security terms are honoured, that incidents and problems are handled properly and that changes in the supplier's services or business situation do not disrupt delivery. A relationship management process should: check service performance against the agreement; track supplier-side changes such as service enhancements, new applications and systems, revised policies and procedures, and new or changed controls to fix incidents or improve security; track changes in the services themselves such as network changes, new technologies, new products, versions or releases, new development tools and environments, relocated facilities, and changed or added sub-suppliers or subcontracting; review supplier service reports and hold the progress meetings the agreement calls for; audit suppliers and sub-suppliers, alongside independent auditor reports where available, and follow up findings; exchange and review incident information as agreed; examine supplier audit trails and records of security events, operational problems, failures, fault tracing and disruptions; respond to and manage identified events or incidents; identify and manage vulnerabilities; review the security of the supplier's own supplier relationships; make sure the supplier keeps enough capacity and workable plans to hold agreed continuity levels after major failure or disaster (see 5.29 and 5.30, 5.35 and 5.36, and 8.14); make sure suppliers name people responsible for checking and enforcing compliance with the agreement; and regularly evaluate whether the supplier keeps adequate security. A designated person or team owns each relationship, with the technical skills and resources to check that requirements, especially security ones, are met, and deficiencies trigger appropriate action. ISO/IEC 27036-3 gives more detail. In the ISMS the control is compared with the controls determined in risk treatment and recorded in the Statement of Applicability as included or excluded, with the reason and the implementation status.
What the guidance adds
Supplier monitoring is expected to be planned. The guidance asks for the service measures, the review, the change notification and the action when performance drops.
Status of the guidance. The guidance lens for 5.22 reads the draft, which is at stage 40.00 and is not published, against the published ISO/IEC 27001:2022 requirement above. It is our reading, not a quotation, and it is not a requirement.
What good looks like
Put the control in the Statement of Applicability with an owner, a status and the risk it treats. Then keep service performance reports and minutes of periodic supplier review meetings and one live sample together.
Evidence an assessor asks for
- Supplier performance monitoringService performance reports and minutes of periodic supplier review meetings
- Supplier performance monitoringRecords of supplier changes (new technology, locations, releases, sub-suppliers) with the organization's assessment of each
- Supplier performance monitoringSupplier audit reports and reviews of independent auditor or attestation reports, with tracked follow-up of findings
- Supplier performance monitoringIncident and security event information received from suppliers and the organization's review of it
- Supplier performance monitoringEvidence of supplier continuity capability such as tested continuity plans or exercise results
- Supplier performance monitoringA named relationship owner for each critical supplier and records of actions taken on service deficiencies
The question an assessor will ask
An assessor will ask for service performance reports and minutes of periodic supplier review meetings, then trace it to the system it protects. For A.5.22 the test is whether that record ties to a live sample, not whether the control is named in a policy.
Common gaps
- Supplier changes such as moving hosting location or adding sub-processors happen without notice or review
- Assurance reports are filed but exceptions in them are never followed up
- No one is accountable for monitoring security performance of a given supplier
- Supplier incident information is not integrated into the organization's incident process
Before the next audit
Before the next audit, check one live sample for this gap: supplier changes such as moving hosting location or adding sub-processors happen without notice or review.