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ISO 27799: Applying ISO/IEC 27002 Controls to Health Information Security

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By NHI Mgmt Group, edited by Lalit Choda Updated 8 November 2026 12 min read
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Health organisations run ISO/IEC 27001 programmes built for offices, yet their riskiest assets are electronic health records, infusion pumps, imaging modalities and the building systems that keep wards running. ISO 27799 is the health sector guidance that interprets the ISO/IEC 27002 control set for that environment. The third edition, ISO 27799:2025, was published by ISO in December 2025 and replaced the 2016 edition, which ISO now lists as withdrawn. This guide explains what the standard covers, how it sits inside an ISMS, where identity and machine credentials matter in clinical settings, how to implement and evidence it, and how it maps to HIPAA, NIST CSF 2.0 and ISO 27001. It is for ISMS managers, CISOs and auditors at hospitals, clinics, digital health providers and anyone else that holds personal health information.

Key takeaways

  • It is guidance, not a certification scheme: you certify an ISMS against ISO/IEC 27001 and use ISO 27799 to choose and implement controls for health information, in the same way 27017 works for cloud.
  • The current edition is ISO 27799:2025: edition 3, 72 pages, published December 2025 by ISO/TC 215 and built on ISO/IEC 27002:2022; ISO 27799:2016 is withdrawn.
  • Scope is broader than IT: the 2025 abstract covers EHRs, medical devices with health software or firmware, and building management, infection control, environmental and physical security systems on healthcare premises.
  • Any size, any setting: it applies to any organisation that provides care or holds personal health information, on premises or in the cloud, from hospitals and ambulances to residential and virtual care.
  • Clinical access is the hard part: shared workstations, emergency access, device service accounts and integration engine credentials are where health ISMS programmes most often fall short.

What it is and who it applies to

ISO 27799:2025, "Health informatics: Information security controls in health based on ISO/IEC 27002", is published by ISO/TC 215 Health informatics (not by JTC 1/SC 27, which owns the 27000 family). It is the third edition: the first appeared in 2008 and the second, ISO 27799:2016 "Information security management in health using ISO/IEC 27002", aligned to the 2013 versions of 27001 and 27002. The 2016 abstract excluded anonymisation and pseudonymisation methods, network quality of service and data quality, and those topics remain better served by other standards. It extends the generic control set described in the ISO 27002 Controls Guide with health-specific implementation guidance.

Scope from the ISO abstract (2025 edition)

Scope dimensionWhat ISO listsPractical examples
SystemsGeneric IT, EHRs, medical devices containing health software or firmware, other digital equipment on premisesEHR and PACS servers, infusion pumps, patient monitors, building management, nurse call, access control and CCTV
InformationAll forms, however captured, stored or transferredClinical notes, DICOM images, dictation audio, telehealth video, paper records scanned into the EHR
OrganisationsAny size that provides care or holds personal health information, on premises or cloudHospitals, GP and dental practices, laboratories, insurers, health apps, cloud EHR providers
SettingsHospitals, clinics, ambulances, mobile imaging and diagnostic units, residential care, remote and virtual careHome monitoring kits, mobile scanners, community nursing laptops

It is not a law. In the United States the binding rule is the HIPAA Security Rule, covered in the HIPAA Security Rule Guide; ISO 27799 is useful there as a control catalogue and for organisations that also operate internationally. Elsewhere, regulators and health systems often accept an ISO 27001 certificate whose Statement of Applicability (SoA) references 27799 as evidence of good practice; the Healthcare Cyber Regulation Map shows the binding rules by jurisdiction.

ISO 27799 compared with the HIPAA Security Rule

AspectISO 27799:2025HIPAA Security Rule
NatureVoluntary international guidanceUS federal regulation enforced by HHS Office for Civil Rights
WhoAny organisation providing care or holding personal health information, worldwideUS covered entities and business associates handling electronic protected health information
FormControl guidance aligned to the 93 ISO/IEC 27002:2022 controlsAdministrative, physical and technical safeguards, with required and addressable implementation specifications
AssuranceThrough ISO/IEC 27001 certification, with 27799 cited in the SoANo certification; compliance shown through documented risk analysis and safeguards
InformationAll forms, including paper, audio and videoElectronic protected health information only (paper sits under the Privacy Rule)

Many US providers use both: HIPAA defines what must be done, and ISO 27799 supplies a richer control catalogue and an internationally recognised way to evidence it, which matters to multinational research partners and cloud suppliers.

Structure and key requirements

Edition 3 is built on ISO/IEC 27002:2022, which arranges 93 controls into four themes: organisational (5.1 to 5.37), people (6.1 to 6.8), physical (7.1 to 7.14) and technological (8.1 to 8.34). For each control the health guidance confirms, extends or adds to the generic text. ISO's public abstract does not list the health-specific additions control by control, and NHI Mgmt Group has not reproduced the paid text, so obtain the standard before you write your SoA. The table shows where clinical environments typically change how a 27002 control is implemented.

ISO/IEC 27002:2022 controlWhy health differsPractical implementation
5.9 Inventory of information and assetsMedical devices and building systems sit outside IT asset toolsOne inventory covering devices, firmware versions, network location and clinical owner
5.15 to 5.18 Access control, identity, authentication, access rightsShared clinical workstations, rotating staff, locums and studentsRole based access tied to rota and HR feeds, fast user switching or tap and go badges, prompt leaver removal
5.19 to 5.23 Suppliers and cloudDevice makers, EHR vendors and clearing houses hold data or remote accessSecurity clauses, remote support via controlled paths, cloud shared responsibility documented
5.29, 5.30 Continuity and ICT readinessLoss of systems affects patient safety, not just revenueTested clinical downtime procedures and recovery priorities agreed with clinical leads
5.34 Privacy and protection of PIIHealth data is special category data in many jurisdictionsLink the ISMS to the privacy programme; see the ISO/IEC 27701 Privacy Information Management Guide
7.7 Clear desk and clear screenScreens in public clinical areas, shared cartsShort lock timers with badge re-entry so clinicians do not defeat them
8.8 Technical vulnerabilitiesRegulated devices cannot be patched without the manufacturerManufacturer disclosure statements, compensating segmentation, risk acceptance signed by clinical owner
8.15, 8.16 Logging and monitoringPatients and regulators expect to know who viewed a recordRecord access audit trails, inappropriate access ("snooping") reviews, VIP record monitoring
8.22 Segregation of networksFlat hospital networks expose devicesClinical device zones; see the Hospital Clinical Network Segmentation Guide

Identity and NHI requirements

Clinical environments contain a dense web of non-human identities: HL7 and FHIR integration engine accounts, PACS and modality service accounts, device management platforms, laboratory interfaces, claims and clearing house API keys, and the vendor support accounts behind all of them. Applying 27002 controls 5.16 Identity management, 5.17 Authentication information, 8.2 Privileged access rights and 8.5 Secure authentication means:

  • Emergency access: clinicians need records when the normal path fails. Design break-glass access with named accounts, a stated reason, automatic alerting and retrospective review rather than shared emergency passwords. See the Break-Glass Account Guide.
  • Remote access without MFA: the Change Healthcare breach began with a remote access login that had no MFA. Every remote path into clinical or claims systems should require phishing resistant MFA, including vendor support portals.
  • Integration engine credentials: one interface account often reads and writes across EHR, laboratory and billing systems. Give each interface its own credential, scope it to the message types it needs, store it in a vault and alert on interactive logons.
  • Medical device accounts: many devices ship with fixed maintenance passwords. Record them in the inventory, vault what can be vaulted, restrict network reach where they cannot be changed, and track manufacturer fixes.
  • Certificates and API keys: FHIR APIs, e-prescribing and health information exchange rely on certificates and OAuth clients. Inventory them with owners and expiry dates; the Healthcare Identity Security Guide covers patterns.

Implementation steps

  1. Buy the 2025 edition: obtain ISO 27799:2025 and ISO/IEC 27002:2022, and retire references to the 2016 edition in policies and the SoA.
  2. Set ISMS scope around care delivery: include clinical systems, medical devices, building systems on premises, remote and virtual care services and cloud processors, and mark interfaces to out-of-scope systems.
  3. Build one asset inventory: combine IT assets, biomedical engineering device lists and facilities systems, with a clinical owner for each.
  4. Run a risk assessment with patient safety criteria: rate impact on care delivery and patient harm alongside confidentiality, and involve clinical safety officers. The ISO/IEC 27005 Information Security Risk Guide covers method.
  5. Rebuild the SoA: use the 2022 control structure and record, for each control, the 27799 guidance applied or the justified exclusion. See the ISO 27001 Statement of Applicability Template.
  6. Fix access first: MFA on all remote access, leaver processing within a day, break-glass design, vaulting of interface and device credentials.
  7. Pilot clinically: test new controls (lock timers, badge login, network filtering) on one ward or department with clinical sign-off, measure workflow impact, keep a rollback plan and expand in rings.
  8. Certify and maintain: have an accredited body audit against ISO/IEC 27001, then run surveillance audits and annual access reviews.

Small practice or hospital group

A GP or dental practice rarely needs certification; it can use 27799 as a checklist with focus on supplier contracts, MFA, backups and record access logging, as set out in the Cyber Security for Dental and GP Practices Guide. A hospital group needs a dedicated medical device security function, a central identity platform linked to rostering, and a formal link between the ISMS, clinical safety and biomedical engineering.

Evidence and assessment

EvidenceWhat an auditor checksMetric to track
Scope statement and combined asset inventoryMedical devices and building systems included, owners namedPercentage of networked medical devices in the inventory with owner and firmware version
Risk assessmentPatient safety and care continuity criteria usedOpen high risks past target date
SoA in the 2022 structure with 27799 guidanceEvery control addressed, exclusions justifiedOpen SoA gaps
Record access audit and snooping reviewsLogs retained, reviews performed, outcomes acted onInappropriate access alerts reviewed within 5 working days
Joiner, mover, leaver recordsTimely removal for staff, locums and contractorsMedian hours from leaving to account disablement
Break-glass and remote access logsEvery emergency use reviewed, MFA on remote pathsPercentage of break-glass events reviewed; remote paths without MFA (target zero)

Mapping to other frameworks

TopicISO/IEC 27001:2022 Annex ANIST CSF 2.0HIPAA Security Rule (45 CFR Part 164)
Risk analysisClauses 6.1.2, 8.2ID.RA164.308(a)(1)(ii)(A) risk analysis
Asset inventoryA.5.9ID.AM-01Supports risk analysis
Identities and credentialsA.5.16, A.5.17, A.8.5PR.AA-01164.312(a)(2)(i) unique user identification; 164.312(d) authentication
Access rights and emergency accessA.5.15, A.5.18, A.8.2PR.AA-05164.308(a)(4) access management; 164.312(a)(2)(ii) emergency access procedure
Logging and monitoringA.8.15, A.8.16DE.CM-01164.312(b) audit controls
SuppliersA.5.19 to A.5.22GV.SC-05, GV.SC-07164.308(b) business associate contracts
Physical securityA.7.1 to A.7.4PR.AA-06164.310 physical safeguards
Data protection at restA.8.24PR.DS-01164.312(a)(2)(iv) encryption and decryption

For medical device makers, the device lifecycle standards matter more than 27799: see the IEC 81001-5-1 Health Software Security Lifecycle Guide and the FDA Medical Device Cybersecurity Guide.

Common pitfalls

  • Citing the withdrawn edition: SoAs and policies that still reference ISO 27799:2016 and the 2013 control numbers look stale to auditors.
  • Leaving devices and facilities out of scope: the 2025 abstract explicitly brings medical devices and building systems in, and attackers use them as pivots.
  • Controls clinicians bypass: two minute screen locks without badge re-entry lead to propped open sessions and shared logins.
  • Shared emergency passwords: a break-glass password on a sticky note gives no accountability; use named emergency access with review.
  • Remote access without MFA: as the Change Healthcare case showed, one unprotected remote login can halt claims processing across a national health system.
  • Logging without review: record access logs nobody reads do not detect snooping or misuse.
  • Treating the cloud EHR as the vendor's problem: the 2025 scope covers health information held in the cloud, so the SoA must show which controls the provider operates, which you operate, and how you verify the provider's side through contracts, attestations and access reviews of vendor support accounts.

Practitioner checklist

  • Obtain ISO 27799:2025 and remove references to the 2016 edition.
  • Scope the ISMS to include medical devices, building systems and virtual care.
  • Merge IT, biomedical and facilities inventories with clinical owners.
  • Add patient safety and care continuity to risk criteria.
  • Rebuild the SoA in the 2022 structure with 27799 guidance noted per control.
  • Enforce phishing resistant MFA on every remote and vendor access path.
  • Implement named break-glass access with alerting and review.
  • Vault integration engine, device and API credentials with named owners.
  • Review record access logs for inappropriate access every month.
  • Test clinical downtime and recovery procedures at least once a year.

Standards and references

Related NHI Mgmt Group resources: HIPAA Security Rule Guide · Healthcare Identity Security Guide · Medical Device Security Guide · ISO 27001 Certification Guide. This guide summarises ISO 27799 as listed by ISO at 8 November 2026 and is not legal advice.

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NHIMG Editorial Note
Researched and written by the NHI Mgmt Group editorial team using AI tools, under the editorial direction of Lalit Choda. Facts are drawn from the sources listed on this page and checked by our automated quality process. Last updated 8 November 2026. Spotted an error? Use our contact page.
NHI Mgmt Group, the independent authority on Non-Human Identity, IAM and Agentic AI security. nhimg.org