Scenario 2:

Clinic, founded in the 1990s, is a medical device company that specializes in treatments for heart-related conditions and complex surgical interventions. Based in Europe, it serves both patients and healthcare professionals. Clinic collects patient data to tailor treatments, monitor outcomes, and improve device functionality. To enhance data security and build trust, Clinic is implementing an information security management system (ISMS) based on ISO/IEC 27001. This initiative demonstrates Clinic's commitment to securely managing sensitive patient information and proprietary technologies.

Clinic established the scope of its ISMS by solely considering internal issues, interfaces, dependencies between internal and outsourced activities, and the expectations of interested parties. This scope was carefully documented and made accessible. In defining its ISMS, Clinic chose to focus specifically on key processes within critical departments such as Research and Development, Patient Data Management, and Customer Support.

Despite initial challenges, Clinic remained committed to its ISMS implementation, tailoring security controls to its unique needs. The project team excluded certain Annex A controls from ISO/IEC 27001 while incorporating additional sector-specific controls to enhance security. The team evaluated the applicability of these controls against internal and external factors, culminating in the development of a comprehensive Statement of Applicability (SoA) detailing the rationale behind control selection and implementation.

As preparations for certification progressed, Brian, appointed as the team leader, adopted a self-directed risk assessment methodology to identify and evaluate the company’s strategic issues and security practices. This proactive approach ensured that Clinic’s risk assessment aligned with its objectives and mission.

Question:

Does the Clinic's SoA document meet the ISO/IEC 27001 requirements for the SoA?