Let’s be honest. For too many organisations, the “ISO 27001 management system” is just a collection of Word and Excel files scattered across a shared drive, with no ownership.
If your “Information Security Management System (ISMS)” looks like that, then it’s not really a system at all. Sorry to be blunt.
Why Your ISO 27001 System Can’t Just Be Documents
Clause 4.4 of ISO/IEC 27001:2022 is crystal clear:
“The organization shall establish, implement, maintain and continually improve an information security management system (ISMS)...”
Not a document repository. Not a few meeting minutes. A functioning system.
A real ISMS creates structure and clarity around four critical questions:
- What needs to happen?
In my experience, this should result in a list of recurring tasks. You can use project tools like Trello or JIRA — or you can also use the task module built directly into MS Frog. - Who is responsible?
Usually a person in the Organisation is assigned ownership of the entire Management System. They're missing the point. A Management System needs to be adopted by the persons on the ground - otherwise it'll be just a shiny book on a shelf. - When is it due?
Every task; every review of Manual; every Internal Audit... You get my point. No due date means it never gets done. - How do we track, review, and improve?
This is the most important. An organisation should be obsessed about Kaizen in everything it does. Your Management System is the backbone of your Organisation. If you improve your Management System - you improve all facets of your Organisation.
ISO 27001 Pitfalls: The Illusion of Control
One of the most common audit findings — especially under Clause 9.1 (Monitoring, Measurement, Analysis and Evaluation) — is that organisations cannot demonstrate systematic control of their information security objectives, tasks, or risks.
For example:
- Annex A Controls (i.e. Security controls) are defined, but not routinely reviewed or tested.
- Risk treatments (i.e. the mitigation of risks identified in your Annex A Controls) are logged but not actually implemented or monitored — often because no owner was assigned.
- Internal audits (Clause 9.2) are done inconsistently or parts of the Internal Audit are skipped.
- Action items vanish into the void.
Is that a system?
What an Effective ISO 27001 System Should Include
A functioning Information Security Management System should support your business in real time. That means:
✅ Automated task tracking
Each requirement (e.g., risk assessments, reviews, corrective actions) should trigger structured actions with due dates and assigned responsibilities. [Clauses 6.1.2, 10.1].
✅ Version-controlled documentation
Policies, procedures, and records should be centrally managed, versioned, and accessible. No more emailing “final_v3_final2.docx.” [Clause 7.5]
✅ Audit-ready status
You should always know: What’s completed? What’s overdue? What’s coming up? [Clauses 9.2, 9.3, 10.1]
✅ Built-in accountability
Roles and responsibilities must be clearly defined and linked to actions. ISO 27001 Clause 5.3 demands this, and auditors will check. [Clause 5.3]
✅ Evidence of continual improvement
Corrective actions, lessons learned, and policy updates should all be traceable over time. [Clause 10.2]
Why Excel Fails as an ISO 27001 System
Spreadsheets are not systems. They’re stopgaps.
Imagine your Accountant keeps your company’s records on Excel. Would you be okay with that?
Yes, you can patch together an ISMS using Excel, SharePoint, and email — but will it actually do what’s listed above?
Unlikely. And during an external audit, that fragility will clearly show.
How to Start Building a Proper ISO 27001 ISMS
Most other content on the internet does not give you a solution - and I hate that.
So here's my actionable insight: Use MS Frog to build your Management System - MS Frog is a very specific SaaS that does one thing and one thing only - it offers an affordable solution to SMEs that want to build a functioning ISMS.
👉 Use MS Frog to build your Information Security Management System.
It’s a purposely built for SMEs who are ISO certified (or want to become so).
Here’s how MS Frog will help you:
- ✅ Automated task tracking
- ✅ Version-controlled documentation
- ✅ Audit-ready dashboard
- ✅ Built-in accountability
- ✅ A focus on continual improvement baked into the system
The Bonus? Using a software will make it a 100 times easier when the person in charge of your Management System moves on. They won't leave a black box behind them and the person taking over will hit the ground running.
Conclusion: Audit-Ready, Always
If your ISO 27001 system can’t answer “who’s doing what, when, and how are we improving?” — you don’t have a system.
