Scenario 1Fintive is a distinguished security provider specializing in online payments and protection solutions.

PECB ISO-IEC-27001-Lead-Auditor Question Answer

Scenario 1

Fintive is a distinguished security provider specializing in online payments and protection solutions. Founded in 1999 by Thomas Fin in San Jose, California, Fintive offers services to companies operating online that seek to improve their information security, prevent fraud, and protect user information such as personally identifiable information (PII).

Fintive bases its decision-making and operational processes on previous cases, gathering customer data, classifying them according to the case, and analyzing them.

Initially, Fintive required a large number of employees to be able to conduct such complex analyses. However, as technology advanced, the company recognized an opportunity to implement a modern tool — a chatbot — to achieve pattern analyses aimed at preventing fraud in real time. This tool would also assist in improving customer service.

The initial idea was communicated to the software development team, who supported the initiative and were assigned to work on the project. They began integrating the chatbot into the existing system and set an objective regarding the chatbot, which was to answer 85% of all chat queries.

After successfully integrating the chatbot, the company released it for customer use. However, the chatbot exhibited several issues. Due to insufficient testing and a lack of sample data provided during the training phase — when it was supposed to learn the query patterns — the chatbot failed to effectively address user queries. Additionally, it sent random files to users when it encountered invalid inputs, such as unusual patterns of dots and special characters.

Consequently, the chatbot could not effectively answer customer queries, overwhelming traditional customer support and preventing them from assisting customers with their requests.

Recognizing the potential risks, Fintive decided to implement a set of new controls. The measures included enabling comprehensive audit logging, configuring automated alert systems to flag unusual activities, performing periodic access reviews, and monitoring system behavior for anomalies. The objective was to identify unauthorized access, errors, or suspicious activities in a timely manner, ensuring that any potential issues could be quickly recognized and investigated before causing significant harm.

Question

Based on the scenario above, to ensure the protection of information privacy, Fintive decided to implement security controls. Is this acceptable?

Yes, but only if the security controls do not interfere with the daily operations of Fintive.

No, because implementing too many controls on top of the chatbot could lead to a decrease in organizational efficiency.

Yes, in order to ensure information privacy, organizations have to implement security controls.

Explanation:

From Exact Extract:

1. ISO/IEC 27001:2022 – Obligation to implement security controls

ISO/IEC 27001:2022 requires organizations to implement information security controls to address identified risks, particularly where personally identifiable information (PII) is processed.

Under Clause 6.1.3 – Information security risk treatment, the standard requires that an organization:

“Determine all controls that are necessary to implement the information security risk treatment option(s) chosen.”

In this scenario, the chatbot introduced new and unmitigated risks, including:

Incorrect handling of user input

Potential unauthorized disclosure of information (sending random files)

Processing of PII without sufficient safeguards

Therefore, implementing additional security controls is mandatory, not optional.

2. ISO/IEC 27002:2022 – Privacy and monitoring controls

The controls implemented by Fintive directly align with Annex A of ISO/IEC 27002:2022, including:

A.5.34 – Privacy and protection of PIIRequires organizations to protect personal data in line with legal, regulatory, and contractual requirements.

A.8.15 – LoggingRequires audit logs to be enabled to record events for investigation.

A.8.16 – Monitoring activitiesRequires monitoring systems to detect anomalous behavior.

A.5.18 – Access rightsRequires periodic access reviews to prevent unauthorized access.

These controls are explicitly designed to detect errors, misuse, unauthorized access, and suspicious behavior — exactly the risks described in the scenario.

3. Why the other options are incorrect

Option A – IncorrectISO/IEC 27001 does not permit organizations to avoid implementing controls simply because they may affect operations. Operational impact is considered during risk assessment, but security and privacy obligations take precedence, especially for PII.

Option B – IncorrectISO/IEC 27001 does not limit the number of controls. Controls must be appropriate to the risk, not minimized for efficiency. A reduction in efficiency does not justify non-compliance or privacy violations.

4. Auditor conclusion

Implementing security controls to protect information privacy is:

Required by ISO/IEC 27001:2022

Consistent with ISO/IEC 27002:2022 Annex A controls

Appropriate given the identified risks

A correct application of risk treatment and continual improvement

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