Re: ISO27001 vs NIST 800-171

["Penn, Blake C" <blake.penn () SECURITY GATECH EDU>]

Chris,

There is no comparison.

The two are enormously different.  NIST 800-171 is a data security standard designed to protect CUI.  NIST 800-171 is 
much closer to something like the PCI DSS (another data security standard) than ISO 27001.

ISO 27001 is an information security management standard.  It is not designed to protect data – its purpose is to 
provide a framework for a strong information security program and is the only globally recognized standard for this – 
that is, it is the gold standard for running a cybersecurity program.

A much misunderstood part of ISO 27001 are the controls in Appendix A.  None of these controls are mandatory – ISO 
27001 has no mandatory controls, none.  In ISO 27001, controls exist to treat risk per clause 6.1.3.  The controls in 
Appendix A are simply common controls used to treat cybersecurity risk.  The list was designed in order to ensure that 
common controls available to treat risk were not missed (clause 6.1.3 c), but again, none of them are required – the 
only requirement is to consider these controls in the treatment of risk.  ISO 27001 allows you to design your own 
controls to treat risk and/or to borrow them from control frameworks (clause 6.1.3 b).  Controls that exist without an 
associated risk within ISO 27001 are even actually considered a deficiency.  So, your ISO 27001 auditor could actually 
issue a finding in an ISO 27001 audit if you had a control in place and hadn’t mapped that to some risk(s) that the 
control was treating.

ISO 27001 is an excellent standard by which to incorporate regulatory requirements as all regulatory requirements have 
associated regulatory compliance risks.  Managing these risks in ISO 27001 is handled like any other cybersecurity risk 
with regulatory compliance risks being listed and managed within the risk register.  You can incorporate GRC tools and 
techniques within ISO 27001 to manage a multiplicity of regulatory requirements and multi-map/reuse controls.

NIST 800-171 is a regulatory requirement, ISO 27001 is not.  NIST 800-171 can be managed within ISO 27001.  ISO 27001 
cannot be managed within NIST 800-171.  We’ve all seen those spreadsheets that map multiple regulatory compliance 
requirements together – when these include ISO 27001 controls it shows a fundamental misunderstanding of that standard, 
as again, none of the controls in that standard are mandatory.

I’d be glad to discuss the nuances in more detail with you (or anyone else for that matter) if you are interested.  I’m 
a former ISO 27001 principle auditor, so I’ve had this discussion many times before.


Blake Penn
Information Security Policy and Compliance Manager
Cyber Security
Georgia Institute of Technology
(404) 385-5480

From: The EDUCAUSE Security Constituent Group Listserv <SECURITY () LISTSERV EDUCAUSE EDU> On Behalf Of Davis, Chris
Sent: Friday, 31 August, 2018 09:21
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: [SECURITY] ISO27001 vs NIST 800-171

Can anyone provide me a quick and dirty compare/contrast between the two?  Which is more appropriate for a higher 
education setting seeking to comply with the various regulatory requirements typically found in higher ed?

Thanks!

Chris


Christopher Davis, Ph.D.
Chief Information Officer
Assistant Professor of Education
Apple Teacher
Lourdes University
6832 Convent Blvd | REH 003P | Sylvania, OH 43560
cdavis () lourdes edu<mailto:cdavis () lourdes edu>

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