Scenario 8: EsBank provides banking and financial solutions to the Estonian banking sector since September 2010. The company has a network of 30 branches with over 100 ATMs across the country.
Operating in a highly regulated industry, EsBank must comply with many laws and regulations regarding the security and privacy of data. They need to manage information security across their operations by implementing technical and nontechnical controls. EsBank decided to implement an ISMS based on ISO/IEC 27001 because it provided better security, more risk control, and compliance with key requirements of laws and regulations.
Nine months after the successful implementation of the ISMS, EsBank decided to pursue certification of their ISMS by an independent certification body against ISO/IEC 27001 .The certification audit included all of EsBank’s systems, processes, and technologies.
The stage 1 and stage 2 audits were conducted jointly and several nonconformities were detected. The first nonconformity was related to EsBank’s labeling of information. The company had an information classification scheme but there was no information labeling procedure. As a result, documents requiring the same level of protection would be labeled differently (sometimes as confidential, other times sensitive).
Considering that all the documents were also stored electronically, the nonconformity also impacted media handling. The audit team used sampling and concluded that 50 of 200 removable media stored sensitive information mistakenly classified as confidential. According to the information classification scheme, confidential information is allowed to be stored in removable media, whereas storing sensitive information is strictly prohibited. This marked the other nonconformity.
They drafted the nonconformity report and discussed the audit conclusions with EsBank’s representatives, who agreed to submit an action plan for the detected nonconformities within two months.
EsBank accepted the audit team leader's proposed solution. They resolved the nonconformities by drafting a procedure for information labeling based on the classification scheme for both physical and electronic formats. The removable media procedure was also updated based on this procedure.
Two weeks after the audit completion, EsBank submitted a general action plan. There, they addressed the detected nonconformities and the corrective actions taken, but did not include any details on systems, controls, or operations impacted. The audit team evaluated the action plan and concluded that it would resolve the nonconformities. Yet, EsBank received an unfavorable recommendation for certification.
Based on the scenario above, answer the following question:
Based on scenario 8, EsBank submitted a general action plan. Is this acceptable?
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