ISO 27001 Risk Treatment Plan Template

Your vendor risk assessment identified 47 critical findings across 12 suppliers. Now what?

An ISO 27001 Risk Treatment Plan transforms those findings into actionable remediation. It assigns each risk an owner, treatment option (mitigate, accept, transfer, avoid), specific controls, and implementation timeline. For TPRM teams, this template becomes your vendor remediation roadmap—tracking which controls each supplier must implement, monitoring progress, and documenting residual risk for senior leadership.

The template directly supports ISO 27001:2022 Clause 6.1.3 requirements while providing the structure needed for vendor governance committees, audit evidence, and regulatory examinations. Unlike generic risk registers, an ISO-aligned treatment plan connects each vendor risk to specific Annex A controls, making control mapping automatic and audit preparation significantly faster.

Core Template Components

Risk Identification Section

Start with risk ID, description, and initial assessment scores. Pull these directly from your vendor risk assessments or DDQ responses. Each row represents one identified risk:

Risk ID	Vendor	Risk Description	Likelihood	Impact	Risk Score
VR-001	CloudCo	Inadequate access controls on production data	4	5	20
VR-002	PaymentPro	No incident response plan documented	3	4	12

Treatment Strategy Matrix

Map each risk to ISO 27001 Annex A controls and define your treatment approach:

Risk ID	Treatment Option	ISO Control(s)	Control Description	Risk Owner
VR-001	Mitigate	A.9.1.1, A.9.2.1	Implement MFA, quarterly access reviews	CISO
VR-002	Transfer	A.16.1.1	Require cyber insurance, contractual indemnification	Legal

Treatment options follow ISO 31000 standards:

• Mitigate: Implement controls to reduce likelihood or impact
• Accept: Document acceptance with business justification
• Transfer: Insurance, contractual terms, or outsourcing
• Avoid: Terminate vendor relationship or specific services

Implementation Timeline

Track control deployment across your vendor base:

Control	Implementation Steps	Timeline	Status	Evidence Required
A.9.1.1	1. Deploy MFA2. Update access policy3. User training	Q2 2024	In Progress	Screenshots, policy docs, training records

Residual Risk Tracking

Document post-treatment risk levels:

Risk ID	Original Score	Post-Treatment Score	Residual Risk Acceptable?	Review Date
VR-001	20 (High)	6 (Low)	Yes	2024-06-01

Industry-Specific Applications

Financial Services

Banks and fintechs face stringent third-party oversight requirements from OCC, FDIC, and Federal Reserve guidance. Your treatment plan must address:

• Critical vendors: Document enhanced due diligence for providers handling customer data
• Concentration risk: Track aggregate exposure across similar vendors
• Regulatory reporting: Link treatments to specific regulatory requirements (FFIEC IT Handbook, OCC 2013-29)

Example control mapping:

• OCC Bulletin 2013-29 requirement for "ongoing monitoring" → ISO A.15.2.1 (Supplier service delivery management)
• FFIEC guidance on access controls → ISO A.9.1.1 (Access control policy)

Healthcare

HIPAA-covered entities need treatment plans addressing:

• Business Associate Agreements: Map BAA requirements to ISO controls
• PHI handling: Document encryption, access controls, audit logging
• Breach response: Link incident management controls to breach notification timelines

Treatment priorities:

1. Encryption at rest/transit (A.10.1.1)
2. Access controls with audit trails (A.9.1.1, A.12.4.1)
3. Regular security assessments (A.15.2.1)

Technology/SaaS

Software companies managing customer data require:

• Sub-processor management: Track fourth-party risks through your vendors
• Data residency: Document geographic controls and restrictions
• API security: Map authentication and rate limiting requirements

Compliance Framework Alignment

Your ISO 27001 treatment plan supports multiple frameworks simultaneously:

SOC 2 Mapping

ISO 27001 Control	SOC 2 Criteria	Implementation Notes
A.9.1.1 (Access control)	CC6.1	Logical access controls
A.12.1.1 (Operating procedures)	CC7.2	System monitoring
A.16.1.1 (Incident management)	CC7.3	Incident response

GDPR Article Alignment

• Article 32 (Security measures) → A.10.1.1 (Cryptography policy)
• Article 33 (Breach notification) → A.16.1.5 (Response to incidents)
• Article 35 (DPIA requirements) → A.6.1.2 (Risk assessment)

NIST CSF Integration

Map ISO controls to NIST functions:

• Identify: A.8.1.1 (Asset inventory)
• Protect: A.9.1.1 (Access control)
• Detect: A.12.4.1 (Event logging)
• Respond: A.16.1.1 (Incident procedures)
• Recover: A.17.1.1 (Business continuity)

Implementation Best Practices

1. Risk Prioritization

Score vendor risks using consistent criteria:

• Criticality: Business impact if vendor fails
• Data sensitivity: Type and volume of data accessed
• Replaceability: Time/cost to switch vendors

Create a 5x5 matrix scoring likelihood against impact. Treat risks scoring 15+ first.

2. Control Selection

Choose controls based on:

• Cost-effectiveness (implementation cost vs. risk reduction)
• Vendor capability (can they actually implement it?)
• Timeline feasibility (critical risks need quick fixes)

3. Evidence Collection

Define specific evidence for each control:

• Screenshots of configuration settings
• Policy documentation with version control
• Training completion records with dates
• Penetration test reports
• Audit certificates (SOC 2, ISO 27001)

4. Regular Reviews

Schedule treatment plan updates:

• Quarterly: High-risk vendor progress
• Semi-annually: Medium-risk vendors
• Annually: Low-risk vendors and full plan review

Common Implementation Mistakes

1. Generic Risk Descriptions

Wrong: "Security risk with cloud vendor" Right: "CloudCo stores 2M customer records without encryption at rest, violating our data protection policy section 4.2"

2. Unrealistic Timelines

Setting 30-day deadlines for complex implementations leads to failure. Build realistic timelines:

• MFA deployment: 60-90 days
• Encryption implementation: 90-120 days
• Full security program overhaul: 6-12 months

3. Missing Residual Risk Documentation

Every treatment leaves residual risk. Document it explicitly:

• What risk remains after treatment?
• Is remaining risk within appetite?
• Who accepted the residual risk and when?

4. Weak Evidence Requirements

"Vendor attestation" isn't evidence. Require:

• Technical proof (configurations, logs)
• Third-party validation (audit reports)
• Periodic re-verification schedules

5. Control Overkill

Implementing all 93 Annex A controls for every vendor wastes resources. Right-size controls:

• Critical vendors: 40-50 relevant controls
• Important vendors: 20-30 controls
• Standard vendors: 10-15 controls

Frequently Asked Questions

How often should we update our risk treatment plan?

Review high-risk vendor treatments quarterly, medium-risk semi-annually, and conduct a full plan review annually. Update immediately when vendors access new data types or provide new services.

What's the difference between risk treatment and risk register?

Risk registers identify and score risks. Treatment plans document specific actions, owners, and timelines to address those risks. Your treatment plan pulls from your register but adds implementation detail.

How do we handle vendors who refuse to implement required controls?

Document their refusal, calculate residual risk, and present three options to leadership: accept the risk with compensating controls, transfer risk through insurance/contractual terms, or initiate vendor replacement.

Should we use the same treatment plan template for all vendor types?

Use the same core structure but customize control selections by vendor tier. Critical vendors need comprehensive plans; low-risk vendors might only need 5-10 key controls documented.

How do we track treatment effectiveness?

Establish KPIs for each control: failed access attempts for MFA, encryption coverage percentages, incident response times. Review metrics quarterly and adjust treatments if risks aren't reducing as expected.

What evidence satisfies ISO 27001 auditors for vendor treatments?

Auditors want to see: documented risk assessments, clear treatment decisions with business rationale, evidence of control implementation, and proof of ongoing monitoring. Screenshots, audit reports, and signed attestations work best.