ISO 27001: Implementation and Support

1) Why ISO 27001 iGaming operator

Licenses and trust: facilitates dialogue with regulators/banks/PSP/KYC providers.
System approach: unified model of risks and controls for products, platform and vendor chain.

Savings: Fewer incidents and fines, predictable demands on contractors

2) ISMS scope and context

Define ISMS boundaries (products/regions/processes), stakeholders (players, regulators, banks, partners), obligations (law, licenses, contracts) and assumptions/dependencies (cloud, sub-processors).
Output: Scope & Context document + stakeholder and requirements map.

3) Assets and risk register

Asset register: data (PII/KYC/finance), services (payments, anti-fraud, KYC), infrastructure (K8s/cloud), software/repositories, keys/secrets, people and roles.

Threat Model: PII Leaks, Fraud, Downtime PSP/KYC, SDK Exploits, DR Failures

Risk assessment: probability/impact criteria, risk level (Low-High-Critical), risk owners and treatment plans: acceptance/mitigation/avoidance/transfer.
Linkage to Controls: Risk → Control from Appendix A → KPI/KRI → Evidence.

4) ISMS Documentation Set

• Information Security Policy, Data Classification, Access and Segmentation (RBAC/ABAC/SoD/JIT/PAM), Passwords and MFA, Logs and Audits, Incident Management, Backups and DR, Development and Releases (SDLC/DevSecOps), Vulnerabilities/pentests, Cryptography/Key Management, Vendor Management (TPRM), Privacy (GDPR), Training and Awareness, Change Management, Asset Management and Acceptable Use, Physical Security.
• Documents are maintained under version control, with a change log and status (Draft/Approved/Effective).

5) Appendix A (A.5-A. 8): practical measures for iGaming

A.5 Organizational measures

Role delimitation, SoD, RACI; ISMS Committee; annual information security goals; DPO/Privacy role.
IGA/JML (Joiner-Mover-Leaver), rights re-certification, role catalogs as code.

A.6 Human resources

Checks when hiring (where legal), NDA, onboarding with MFA/WebAuthn, regular trainings (phishing/privacy), offboarding ≤ 15 min.

A.7 Physical measures

Control of access to the office/data center, segmentation, CCTV/magazines, clean desks/screens, protection of devices and media.

A.8 Process measures

Secure architecture: WAF/CDN, mTLS, KMS/HSM, encryption at rest/in transit, tokenization PII, RLS/CLS/masking.
SDLC: SAST/DAST/Dependency scanning, IaC scanning, secret scanners, artifact signing, supply-chain control.
Operations: logging (WORM + hash chains), SIEM/SOAR, antipatterns for logging secrets, backups (3-2-1), DR tests, SLA vulnerabilities/patches, release rollback tables.
CIAM/players: authentication protection, risk assessment of devices, behavioral anti-bots.

6) Statement of Applicability (SoA)

Matrix: control → status (applicable/not applicable) → justification → implementation → evidence → owner of the → metric.

7) Document and record management (evidence)

Registers: risks, assets, incidents, vulnerabilities, training, access, audits, CAPAs, vendors/subprocessors.
Requirements for records: immutability, integrity (signatures/hashes), retention periods, quick search, binding to controls and KPIs.

8) Internal audits and management review

Internal audit: annual plan (risk-based), Design/Operating Effectiveness reviews, samples, reports and CAPAs.
Management Review (1-2 times/year): KPI/KRI status, audit/incident results, assessment of resources, risks and opportunities, decisions/goals for the next period.

9) Metrics (KPI/KRI) for ISMS

• Policy coverage and relevance of documents ≥ 95%
• Implementation of audit/training plans ≥ 95%
• High/Critical SLAs ≥ 95% on time
• Proportion of automated controls ↑ QoQ

• Leaks/Incidents with PII = 0; notifications ≤ 72 h - 100%
• SoD/JIT/masking violations = 0
• DR test failure = 0; actual RTO/RPO normal

10) Integration with existing practices

Link ISO 27001 to existing sections of your wiki: Access and Segmentation Policies, RBAC/Least Privilege, Password Policy and MFA, Audit Trails, TPRM and SLA, Internal Controls and Auditing, GDPR/DPO/PIA, Incidents and Leaks, DR/BCP.

11) Roles and RACI

12) Certification Plan: Stage 1 → Stage 2

Stage 1 (documentation and readiness): Scope, context, risk model, SoA, key policies/procedures, implementation record, Stage 2 plan.
Stage 2 (practice and evidence): interviews, samples, tracing, compliance with controls in practice.
After - report, inconsistencies, remediation, issuance of a certificate (usually 3 years) + annual supervisory audit.

13) Implementation Roadmap (12 weeks → certificate)

Weeks 1-2: Context/Scope, Stakeholder Map, Asset and Risk Register (Draft), Communications Plan, Owner Designation.
Weeks 3-4: v1 policy package, SoA (draft), log/logging directories, training start, TPRM process start.
Weeks 5-6: implementation of critical controls (MFA/WebAuthn, RBAC/ABAC/JIT, WORM logs, backups/DR plan, vulnerabilities/patches), launch of internal audit No. 1 (DE).
Weeks 7-8: elimination of finds, refinement of SoA, Evidence storage, KPI/KRI dashboards, tabletop incident drill and DR mini-test.
Weeks 9-10: internal audit No. 2 (OE), Management Review, auditor's reservation, preparation for Stage 1 (document package).
Weeks 11-12: Stage 1 → quick edits → Stage 2, operational remediation, final evidence package.

14) Checklists

14. 1 Ready for Stage 1

• Scope/Context Approved
• Asset/Risk Register and Valuation Methodology
• v1 policies and procedures (minimum 12 key)
• SoA (statuses and justifications)
• Audit/training plan, owners assigned

14. 2 Ready for Stage 2

• Evidence for each A.5-A control. 8
• Logs: Accesses, Incidents, Vulnerabilities, Backups/DR, Training
• DRs/Incident Drills, Samples, CAPAs
• Total KPI/KRI and Management Review Solutions

14. 3 Support and oversight audits

• Annual Audit Plan and Risk Update
• Update SoA/Policies when environment changes
• DR ≥ 1-2 times/year, training alarms
• Staff and novice training 100%

15) Frequent mistakes and how to avoid them

ISMS "on paper": there is no link "risk → control → metric → evidence." Do dashboards and regular reviews.
Scope is too wide: start with the critical contour (payments/ACC/main product) and expand.
No risk owners: Assign domain owners and RACIs.
No automation: transfer repeatable controls to CCM (SIEM/SOAR, circuit validators, IGA checkers).
Forgot about vendors: TPRM, DPA/SLA/audit rights, sub-processor registry and monitoring.

16) Run ISMS

PDCA: Plan → Do → Check → Improve (quarterly cycles).
Change management: significant changes (architecture, regions, vendors) → risk/SoA revision.
KPI/KRI reporting: monthly board, quarterly - ISMS extended report.
Incidents and vulnerabilities: SLA corrections, retrospectives, CAPAs in the improvement register.

TL; DR

Successful ISO 27001 = clear Scope and risk model, a set of practical policies, SoA with a bunch of risk→kontrol→evidence, automated controls (MFA/RBAC/logs/DR/vulnerabilities), internal audits + Management Review, and PDCA support. Do according to the roadmap for 12 weeks - and you have a working ISMS, ready for certification and daily operation.