ISO/IEC 27001

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Change Management Procedure

1. Purpose

The Change Management Procedure defines how changes to information systems, applications, infrastructure, cloud environments, configurations, security controls, processes, and technology services are requested, assessed, approved, implemented, tested, monitored, and documented.

The objective is to ensure that changes:

  • Have a legitimate business or technical purpose
  • Are appropriately assessed for risk
  • Do not unnecessarily introduce security weaknesses
  • Are authorized before implementation
  • Are tested where appropriate
  • Can be reversed when necessary
  • Are implemented by authorized personnel
  • Are properly documented
  • Generate appropriate evidence
  • Are reviewed after implementation

Core Principle

Request → Assess → Approve → Plan → Test → Implement → Verify → Record → Review


2. Scope

This procedure applies to changes involving:

  • Cloud infrastructure
  • Servers
  • Networks
  • Firewalls
  • Databases
  • Applications
  • Source code
  • CI/CD pipelines
  • Operating systems
  • Security tools
  • SaaS platforms
  • Identity and access systems
  • Production environments
  • Development and test environments
  • Configuration
  • Security controls
  • Backup systems
  • Monitoring systems
  • Business processes where security may be affected
  • Third-party technology services

3. Change Management Information

FieldDetails
Procedure ID
Procedure Owner
Change Manager
Technical Owner
Security Owner
Version
Effective Date
Review Date
Classification
StatusDraft / Approved / Retired
Approved By

4. Change Management Objectives

The organization should ensure that:

☐ Changes have a defined purpose
☐ Change ownership is identified
☐ Security impact is considered
☐ Business impact is considered
☐ Risk is assessed
☐ Required approvals are obtained
☐ Testing is performed where appropriate
☐ Backups/recovery are considered
☐ Implementation is controlled
☐ Rollback is possible where practical
☐ Changes are verified
☐ Evidence is retained
☐ Unauthorized changes are identified


5. What Is a Change?

A change is any planned or unplanned modification that may affect an organization’s:

  • Technology
  • Information
  • Security controls
  • Configuration
  • Availability
  • Integrity
  • Confidentiality
  • Business processes

Examples include:

  • Deploying new application code
  • Modifying AWS security groups
  • Changing IAM permissions
  • Upgrading a database
  • Installing a security tool
  • Changing firewall rules
  • Modifying DNS
  • Changing backup configuration
  • Updating operating systems
  • Changing CI/CD pipelines
  • Adding a new production service

6. Change Types

Classify each change appropriately.

☐ Standard Change
☐ Normal Change
☐ Emergency Change
☐ Major Change
☐ Minor Change
☐ Security Change
☐ Infrastructure Change
☐ Application Change
☐ Configuration Change
☐ Access-related Change
☐ Vendor/Supplier Change

The organization should define its own change categories and approval requirements.


7. Standard Changes

A Standard Change is a low-risk, repeatable activity that has been pre-approved.

Examples:

  • Routine patching
  • Approved user provisioning
  • Routine certificate renewal
  • Scheduled backup configuration
  • Approved software deployment

Standard changes should still:

  • Follow an approved procedure
  • Be performed by authorized personnel
  • Be recorded where required
  • Be monitored
  • Be reviewed periodically

8. Normal Changes

Normal changes require assessment and approval before implementation.

Examples:

  • New production infrastructure
  • Major application deployment
  • Database schema changes
  • Network architecture changes
  • New security controls
  • IAM architecture changes

9. Emergency Changes

Emergency changes may be required to:

  • Respond to security incidents
  • Fix critical vulnerabilities
  • Restore critical services
  • Prevent significant business impact
  • Address major system failures

Emergency changes should be:

Authorized → Controlled → Implemented → Verified → Documented → Reviewed

Where prior approval is not practical, retrospective review should be performed according to the organization’s emergency-change process.


10. Change Request

Every significant change should have a documented change request.

Change Request

FieldDetails
Change ID
Requester
Date
System
Environment
Change Type
Change Description
Business Reason
Technical Reason
Risk
Planned Date
Owner
Approver

11. Change Description

Describe:

  • What is changing?
  • Why is it changing?
  • Which systems are affected?
  • Which users/customers may be affected?
  • What dependencies exist?
  • What is the expected result?

Description


12. Business Justification

Every significant change should have a legitimate reason.

Examples:

  • New business requirement
  • Security improvement
  • Vulnerability remediation
  • Performance improvement
  • Customer requirement
  • Regulatory requirement
  • Bug fix
  • Infrastructure modernization
  • Cost optimization
  • Availability improvement

Business Justification


13. Change Impact Assessment

Assess potential impact on:

☐ Confidentiality
☐ Integrity
☐ Availability
☐ Customer data
☐ Personal data
☐ Production systems
☐ Business operations
☐ Security controls
☐ Compliance requirements
☐ Suppliers
☐ Employees/users
☐ Disaster recovery
☐ Backup
☐ Monitoring
☐ Access controls

Impact


14. Risk Assessment

Determine the risk associated with the change.

RiskLikelihoodImpactRisk LevelTreatment

Consider:

  • Security risk
  • Service interruption
  • Data loss
  • Data exposure
  • Unauthorized access
  • Configuration error
  • Compliance impact
  • Customer impact
  • Recovery difficulty

15. Security Impact Assessment

Before approval, determine whether the change affects:

☐ Authentication
☐ MFA
☐ Access control
☐ Privileged access
☐ Encryption
☐ Logging
☐ Monitoring
☐ Network security
☐ Vulnerability management
☐ Backup
☐ Data protection
☐ Privacy
☐ Security architecture

Security Assessment


16. Information Classification Impact

Determine whether the change affects information classified as:

☐ Public
☐ Internal
☐ Confidential
☐ Restricted

Information Affected


17. Compliance Impact

Determine whether the change affects:

☐ ISO/IEC 27001 requirements
☐ Customer commitments
☐ Contractual requirements
☐ Privacy requirements
☐ Legal requirements
☐ Regulatory requirements
☐ Security commitments
☐ Internal policies

Compliance Impact


18. Dependencies

Identify dependencies before implementation.

DependencyOwnerImpactMitigation

Consider:

  • Applications
  • Databases
  • APIs
  • Cloud services
  • Suppliers
  • Network connections
  • Identity systems
  • Monitoring
  • Backup
  • Security tools

19. Implementation Plan

Document the implementation steps.

StepActivityResponsibleExpected Result
1
2
3
4

Implementation should be performed by authorized personnel.


20. Testing

Where appropriate, test the change before production implementation.

Testing may include:

☐ Functional testing
☐ Security testing
☐ Integration testing
☐ Performance testing
☐ Configuration validation
☐ Vulnerability testing
☐ Backup/recovery testing
☐ User acceptance testing

Test Results


21. Test Environment

Where practical, changes should be tested in an appropriate non-production environment before production implementation.

Consider:

  • Development
  • Test
  • Staging
  • Pre-production

Production data should not be unnecessarily copied into lower environments.


22. Change Approval

Approval should be based on the risk and impact of the change.

Possible approvers:

  • System Owner
  • Application Owner
  • IT Operations
  • Security
  • Business Owner
  • Change Manager
  • Management

Approval Record

ApproverRoleDecisionDateComments
Approved / Rejected

23. Change Window

Define the planned implementation window.

Start: __________________

End: __________________

Time Zone: __________________

Consider:

  • Customer impact
  • Business hours
  • Monitoring availability
  • Support availability
  • Rollback time
  • Dependency availability

24. Communication

Where appropriate, notify affected stakeholders.

☐ IT Operations
☐ Security
☐ Business Owner
☐ Customer Support
☐ Management
☐ Affected users
☐ Supplier
☐ Customers

Communication Plan


25. Backup and Recovery Preparation

Before high-risk changes:

☐ Backup completed
☐ Backup verified
☐ Recovery process available
☐ Recovery owner identified
☐ Recovery time considered
☐ Rollback approach documented

A backup should not automatically be assumed to be recoverable without appropriate validation.


26. Rollback Plan

Every significant change should have an appropriate rollback or recovery approach.

Rollback Trigger

Rollback Steps

StepActionOwner
1
2
3

Rollback Verification


27. Production Implementation

Before implementation:

☐ Approval confirmed
☐ Change window confirmed
☐ Required personnel available
☐ Backup/recovery confirmed
☐ Monitoring active
☐ Rollback plan available
☐ Stakeholders informed

During implementation:

☐ Steps followed
☐ Activities recorded
☐ Unexpected issues recorded
☐ Security alerts monitored
☐ Service health monitored


28. Post-Implementation Verification

After implementation, verify:

☐ System available
☐ Application functioning
☐ Security controls functioning
☐ Access controls functioning
☐ Logging functioning
☐ Monitoring functioning
☐ Backup functioning
☐ Integrations functioning
☐ Expected performance achieved
☐ No unexpected security issue identified

Verification Result


29. Change Closure

A change may be closed when:

☐ Implementation completed
☐ Expected result achieved
☐ Verification completed
☐ Issues addressed
☐ Rollback not required
☐ Evidence recorded
☐ Stakeholders notified where required
☐ Change record updated
☐ Lessons learned captured where appropriate

Closure

Result: ☐ Successful ☐ Partially Successful ☐ Rolled Back ☐ Failed

Closure Date: __________________

Closed By: __________________


30. Failed Changes

If a change fails:

  1. Stabilize the affected service.
  2. Activate rollback/recovery where necessary.
  3. Assess business and security impact.
  4. Record the failure.
  5. Investigate the cause.
  6. Communicate significant impact.
  7. Correct the underlying issue.
  8. Determine whether a new change is required.
  9. Capture lessons learned.

31. Unauthorized Changes

Unauthorized changes should be identified and assessed.

Examples:

  • Unapproved production configuration
  • Unapproved firewall modification
  • Unauthorized IAM permission change
  • Unapproved software deployment
  • Direct production database modification

Such changes should be:

☐ Recorded
☐ Investigated
☐ Risk assessed
☐ Reverted or formally approved where appropriate
☐ Escalated
☐ Addressed through corrective action where necessary


32. Configuration Changes

Configuration changes may include:

  • Firewall rules
  • Security groups
  • IAM policies
  • Operating-system settings
  • Database settings
  • Application configuration
  • DNS
  • Encryption settings
  • Monitoring configuration

Configuration changes should be traceable to an authorized change where required.


33. Access-Related Changes

Changes to access permissions should follow the Access Management Procedure.

Examples:

  • New administrator
  • Permission modification
  • Production access
  • IAM policy change
  • Group membership change
  • Supplier access

Principle

Access Change → Authorization → Implementation → Verification → Record


34. Security Changes

Security changes may include:

  • Firewall configuration
  • MFA configuration
  • Endpoint security
  • SIEM rules
  • Detection rules
  • Encryption
  • Security policies
  • Vulnerability remediation
  • Security tooling

Security changes should be tested and monitored appropriately.


35. Cloud Changes

For cloud environments, changes may include:

  • New AWS resources
  • IAM policies
  • Security groups
  • VPC configuration
  • S3 permissions
  • RDS configuration
  • CloudTrail
  • CloudWatch
  • Encryption
  • Backup
  • Auto-scaling
  • DNS
  • Production deployments

Cloud changes should be traceable to approved requests where required.


36. CI/CD Changes

CI/CD pipelines can directly affect production systems.

Changes to:

  • Deployment pipelines
  • Build scripts
  • Infrastructure-as-code
  • Secrets
  • Deployment permissions
  • Production environments

should be controlled appropriately.

☐ Code reviewed
☐ Approval obtained
☐ Security impact considered
☐ Testing completed
☐ Deployment controlled
☐ Rollback available


37. Infrastructure-as-Code

Where infrastructure is managed through code:

☐ Changes tracked in version control
☐ Peer review performed where appropriate
☐ Security checks performed
☐ Testing performed
☐ Deployment authorized
☐ Change traceability maintained

Examples:

  • Terraform
  • CloudFormation
  • Ansible
  • Kubernetes manifests

38. Emergency Change Procedure

When immediate action is required:

Step 1 — Identify

Determine why emergency action is required.

Step 2 — Assess

Determine the immediate security/business impact.

Step 3 — Authorize

Obtain emergency approval where practical.

Step 4 — Implement

Perform the minimum necessary change.

Step 5 — Monitor

Closely monitor the result.

Step 6 — Verify

Confirm service/security stability.

Step 7 — Document

Complete the change record.

Step 8 — Review

Perform retrospective review.


39. Change Monitoring

After significant changes, monitor:

☐ System availability
☐ Application performance
☐ Security alerts
☐ Authentication
☐ Error rates
☐ Network traffic
☐ Database health
☐ Backup status
☐ Customer impact

Monitoring duration should reflect the risk of the change.


40. Change Evidence

Maintain appropriate evidence such as:

☐ Change request
☐ Business justification
☐ Risk assessment
☐ Security assessment
☐ Approval
☐ Test results
☐ Implementation record
☐ Deployment logs
☐ Configuration records
☐ Monitoring results
☐ Rollback evidence
☐ Post-implementation verification
☐ Closure record

Do not retain passwords, API keys, private keys, or other secrets as change evidence.


41. Change Exceptions

Where the standard change process cannot be followed:

☐ Reason documented
☐ Risk assessed
☐ Compensating controls identified
☐ Appropriate approval obtained
☐ Change recorded
☐ Retrospective review performed where required


42. Change Metrics

Possible metrics include:

MetricTargetFrequency
Successful changes
Failed changes
Emergency changes
Unauthorized changes
Changes requiring rollback
Change-related incidents
Changes completed on schedule
Changes without required approval

Metrics should be used to identify trends and improve change management.


43. Change Review

Periodically review changes to identify:

  • Repeated failures
  • Recurring emergency changes
  • Unauthorized changes
  • Inadequate testing
  • Incomplete approvals
  • Poor rollback planning
  • Security weaknesses
  • Process bottlenecks

Review Record

Review DateReviewerFindingsActions

44. Change-Related Incidents

If a change causes or contributes to a security incident or major service disruption:

  1. Initiate incident management.
  2. Stabilize the environment.
  3. Preserve relevant evidence.
  4. Assess impact.
  5. Investigate root cause.
  6. Determine corrective action.
  7. Review the change-management process.

45. Corrective Action

For significant change-related failures:

IssueRoot CauseCorrective ActionOwnerDue DateStatus

Corrective actions should be verified for effectiveness before closure.


46. Roles and Segregation of Duties

Where practical, separate:

  • Change requester
  • Change approver
  • Change implementer
  • Change reviewer

For low-risk or small-team environments, complete separation may not always be practical. Where duties overlap, appropriate compensating controls should be considered.


47. Change Frequency

The organization should determine review and approval requirements based on:

  • Change risk
  • System criticality
  • Production impact
  • Security sensitivity
  • Change complexity
  • Regulatory requirements
  • Customer commitments

High-risk changes should receive greater scrutiny than routine low-risk changes.


48. AWS SaaS Startup Example

Scenario

A SaaS startup needs to modify an AWS production security group to allow application traffic to a new service.

Change Request

Change: Add inbound HTTPS rule.

Reason: New production application service.

System: AWS production VPC.

Risk: Potential unauthorized network exposure.

Process

1. Request

Engineer creates a change ticket.

2. Assessment

Review:

  • Source IP/range
  • Destination
  • Port
  • Business requirement
  • Security impact

3. Approval

Engineering/System Owner approves.

Security reviews the change where required.

4. Testing

Validate configuration in a suitable environment where practical.

5. Implementation

Authorized engineer applies the change.

6. Verification

Confirm:

  • Application connectivity
  • Security group configuration
  • Logs
  • Monitoring
  • No unintended exposure

7. Evidence

Retain:

  • Change ticket
  • Approval
  • Configuration/IaC commit
  • Test result
  • Deployment record
  • Verification evidence

8. Closure

Close the change after successful validation.


49. Startup-Friendly Change Management Model

A startup does not need a complicated Change Advisory Board for every change.

Low Risk

Request → Approved Standard Change → Implement → Record

Normal Change

Request → Impact/Risk → Approval → Test → Implement → Verify → Close

High-Risk Change

Request → Detailed Risk → Security Review → Approval → Test → Backup → Implement → Monitor → Verify → Close

Emergency Change

Assess → Emergency Approval → Implement → Monitor → Stabilize → Document → Review

The objective is to control risk without creating unnecessary operational bureaucracy.


50. Common Mistakes

Avoid:

  • Making production changes without records.
  • Allowing developers to bypass change controls.
  • Treating all changes as equally risky.
  • Having no rollback plan for high-risk changes.
  • Failing to test changes.
  • Approving changes without understanding impact.
  • Not considering security impact.
  • Failing to monitor after implementation.
  • Making direct production database changes without traceability.
  • Treating emergency changes as a permanent bypass.
  • Failing to review failed changes.
  • Ignoring unauthorized changes.
  • Not controlling infrastructure-as-code changes.
  • Retaining secrets in change tickets.
  • Closing changes without verifying the expected result.

51. Relationship With Other ISMS Documents

DocumentRelationship
Change Management PolicyDefines change-control requirements
IT Operations ProcedureDefines operational activities
Access Management ProcedureControls access-related changes
Configuration Management ProcedureControls configuration
Vulnerability Management ProcedureAddresses security remediation
Incident Response ProcedureHandles incidents caused by changes
Backup & Restore ProcedureSupports recovery
Business Continuity PlanSupports major disruption
Cloud Security PolicyGoverns cloud changes
Risk AssessmentAssesses change-related risk
Exception RegisterRecords deviations
Corrective Action TrackerTracks change-related weaknesses
Supplier Change ProcedureControls supplier changes

52. ISO/IEC 27001 Connection

Change management supports the organization’s risk-based approach to information security by ensuring that changes affecting information systems and security controls are appropriately assessed, authorized, implemented, and reviewed.

The exact change controls and procedures should be determined based on:

  • ISMS scope
  • Risk assessment
  • Risk treatment
  • Statement of Applicability
  • Applicable controls
  • Technology architecture
  • Business requirements
  • Legal/regulatory requirements
  • Customer requirements
  • Contractual requirements

This Change Management Procedure is not itself a universally prescribed ISO/IEC 27001 document. The organization should maintain appropriate documented information and operational evidence to demonstrate that relevant changes are controlled.


53. Audit Evidence Checklist

An auditor should be able to trace:

☐ Change policy
☐ Change procedure
☐ Change request
☐ Business justification
☐ Risk assessment
☐ Security assessment
☐ Approval
☐ Test evidence
☐ Implementation record
☐ Deployment evidence
☐ Configuration evidence
☐ Monitoring evidence
☐ Rollback/recovery evidence
☐ Post-change verification
☐ Change closure
☐ Emergency changes
☐ Unauthorized changes
☐ Change metrics
☐ Corrective actions


54. Final Change Management Audit Trail

For every significant change, the organization should be able to demonstrate:

What was changed?

Why was it changed?

Who requested it?

What systems and information were affected?

What security and business risks were identified?

Who approved it?

Was it tested?

How was it implemented?

What was the rollback/recovery approach?

How was the result verified?

What evidence was retained?

What was learned from the change?

Final Principle

Change management is not about preventing change. It is about ensuring that necessary change happens in a controlled, authorized, tested, traceable, and recoverable manner.