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Why ISO 27001 is important

ISO/IEC 27001 is not a paper crust, but an information security management system (ISMS) that helps predictably protect data and processes. For iGaming, this is especially critical: PII/KYC media, payment events, game integrity logs, integration with providers and affiliates. Compliance with 27001 reduces the likelihood of incidents, simplifies dialogues with regulators and opens the door to large B2B contracts.


1) What exactly gives ISO 27001 to the iGaming business

Risk-based management: Threats and vulnerabilities become a risk register with owners and deadlines.

Increased trust: easier to pass due diligence from PSP, content studios, marketing networks.

Legal support: processes and logs that are needed when checking the regulator.

Reducing TCO security: focus on priority risks instead of "patching everything."

Competitive advantage: mandatory filter in RFP/tenders in a number of markets.


2) Key elements of ISMS to 27001

Scope: which legal entity, sites, services, data covers ISMS.

Policies and roles: information security policy, RACI, management responsibility, information security committee.

Asset identification: register of data/services/integrations with classification (PII, KYC, payments, game logs).

Risk assessment: methodology, criteria, probability × impact matrix, processing plan.

SoA (Statement of Applicability): list of applied Annex A controls and justification of exceptions.

Documentation and training: managed versions, onboarding, regular training.

Improvement cycle (PDCA): internal audits, corrective actions, metrics.


3) Annex A (revision 2022): 93 controls grouped by topic

Organizational (37): information security policy, roles, employee screening, data classification, supplier management, secure development, logging and monitoring, DLP.

People (8): information security training, disciplinary measures, employee access management, termination of employment relations.

Physical (14): perimeter, access to DC/offices, equipment protection, workplaces.

Technological (34): IAM, cryptography and KMS, network filters, redundancy and DR, web application and API protection, vulnerabilities, anti-malware.

💡 Especially important for iGaming: vendor management (PSP/KYC/game aggregators), crypto controls (RNG keys/build signatures), money logging and RNG, DevSecOps and incident response.

4) How ISO 27001 overlaps with other requirements

GDPR: legal grounds, data minimization, subject rights (DSR), access log - overlapped by controls on data management and roles.

PCI DSS: tokenization/segmentation of the payment loop, vulnerability and log management are the same principles in ISMS, but PCI remains a separate standard.

Licenses and Responsible Gaming: availability of RG tools, unchanging logs - fall on the requirements of logging, retention and change management.


5) Path to certification: stages

1. Gap analysis: comparison of current practices from 27001:2022, gap map.

2. Define Scope and Asset/Risk Register.

3. Selection and justification of controls in SoA, risk handling plan.

4. Implementation of processes: policies, procedures, logging, training, IR/DR plan, supplier management.

5. Internal audit and the analysis from the management (Management Review).

6. Certification audit:
  • Stage 1 - checking readiness and documentation.
  • Stage 2 - checking the work of processes "in action."
  • 7. Certificate support: annual supervisory audits, recertification every 3 years, continuous improvements.

6) What gets into Scope iGaming companies (example)

Platform (PAM), game server (RGS), cash desk and PSP integration, KYC/AML circuit, CRM/BI, web/mobile clients, DevOps environments, RNG/RTP logs, KYC media storage, DWH/analytics, office IT services, contractors (SaaS/CDN/WAF)

Data: PII, payment tokens, operational transactions, game logs, service keys/certificates.


7) Examples of control measures "translated into practice"

Access control: RBAC/ABAC, MFA, JIT rights for admins, regular access reviews.

Cryptography: TLS 1. 3, AES-GCM/ChaCha20, KMS/HSM, key rotation, backup encryption.

Journals and monitoring: unchangeable money logs and RNG, SIEM/UEBA, cash alerts/cash registers.

DevSecOps: SAST/DAST, secret scan, infrastructure as code, change control, game build signatures, version hashes.

Vulnerability management: SLA for patches (critical ≤ 7 days, high ≤ 30), regular pen tests.

Continuity: RPO/RTO, DR exercises, asset-regions, DDoS readiness.

Vendor management: data processing contracts, supplier SLA/DR evaluation, input and periodic audits.


8) Metrics showing "live" ISO 27001

Time to eliminate critical vulnerabilities (MTTR), the share of closed corrective actions.

Share of supervised services (logging, tracing, alerts).

The percentage of employees who have completed information security trainings and the results of phishing simulations.

RPO/RTO tests: progress and recovery time.

KPI by supplier: uptime, reaction time, insiders and SLA execution.

Access review frequency and the number of extra rights identified.


9) Frequent myths and mistakes

"Certificate = Security." No, it isn't. ISO 27001 is valid only if the processes actually work and improve.

"Enough politics on paper." We need metrics, journals, trainings, audits and corrective actions.

"We will cover everything at once." The right way is a clear Scope + risk priorities.

"ISO 27001 will replace PCI/GDPR." Will not replace; it creates a framework to which industry requirements map.

"Dev and Prod cannot be separated." For 27001, the separation of environments, data and keys is basic hygiene.

"Secrets can be stored in code." Do not: need Secret-manager and leak control.


10) Implementation checklist (save)

  • Scope defined, asset register and data classification
  • Risk assessment methodology, risk map, processing plan
  • Annex A 2022 SoA justifying exceptions
  • Policies: accesses, cryptography, vulnerabilities, logs, incidents, providers, retention
  • RBAC/ABAC, MFA, JIT access, regular rights reviews
  • TLS 1. 3, encryption in storage, KMS/HSM, key rotation, encrypted backups
  • SAST/DAST, secret scan, change control, build signatures
  • SIEM/UEBA, immutable money and RNG logs, SLO dashboards
  • DR plans, RPO/RTO, asset/Anycast/CDN/WAF, DDoS procedures
  • Information security training, phishing simulations, discipline of disciplinary measures
  • Vendor management: DPIA, SLA/DR, annual assessments
  • Internal Audit, Management Review, Corrective Actions

11) Mini-FAQ

How long does the certification take? Usually 3-6 months of preparation + 2 stages of audit.

Do I need 27017/27018? Recommended for cloud and PII; they expand 27001 profile controls.

What should a startup do? Start with core processes: asset/risk registry, accesses, logs, vulnerabilities, backups - and move to full SoA.

How to convince C-levels? Show risks/penalties, partner requirements and ROI forecast (incident reduction, sales acceleration).

How to support? Annual oversight audits, quarterly internal audits, regular DR drills and metrics.


ISO/IEC 27001 builds a security discipline into a scalable system - with clear coverage, risks, controls, metrics and improvements. For iGaming, this means fewer incidents and fines, faster coordination with partners and regulators, stable operation of cash desks and games. The certificate is the final touch. The main thing is a live ISMS that helps businesses make risk decisions every day.

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