How to Implement the National Security Framework (ENS) Step by Step in an Organization

Implementing the National Security Framework (ENS) in an organization is a rigorous process that requires planning, technical execution, and continuous control. The ENS is a mandatory legal framework in Spain for public sector entities and for private organizations that handle sensitive data or provide services to the government, aiming to ensure that information and electronic services are managed under clear and consistent security requirements.

Summary: Context on the ENS

The National Security Framework is a regulatory framework established by Royal Decree 311/2022, which requires the application of principles and minimum security requirements to the information systems and services of public administrations and their providers. Its goal is to protect the confidentiality, integrity, availability, traceability, authenticity, and preservation of information, adopting a risk-based security management approach.

The fundamental principles of the ENS revolve around comprehensive security, covering prevention, detection, and incident response, with clearly defined roles and responsibilities and continuous system monitoring. These principles form the foundation for the entire implementation process.

Compliance with the ENS is legally mandatory for many organizations in Spain, including all public administrations and the companies that contract with them. Beyond avoiding penalties and exclusion from public procurement processes, implementing the ENS improves resilience against cyberattacks, risk management, and trust from clients and users.

How to Prepare Your Organization for the ENS: Key Phases

Phase 1: Preparation and Initial Analysis

Before formally implementing the ENS in an organization, it is crucial to conduct thorough preparation that establishes the foundation for the project.

Scope Evaluation and Situation Diagnosis

The first step in implementing the ENS is understanding the organization’s real situation. This involves assessing the current state of information systems, existing policies, procedures, and technical and organizational capabilities. Without this precise diagnosis, any implementation plan would lack a solid foundation.

This analysis should document information assets, data flows, existing threats, and technological vulnerabilities. It is essential for determining which systems should enter the compliance process and what their risk level is.

Identification of Compliance Obligations

Although many organizations are aware that ENS compliance is required, not all formally verify whether they are subject to this obligation. It is necessary to confirm whether the organization must implement the ENS, which depends on whether it is a public entity, a provider of public services, or manages sensitive information for the government.

Phase 2: Adaptation Plan

With the initial diagnosis completed, the next step is to design a structured plan that guides the implementation.

Definition of Scope and System Categorization

The adaptation plan begins with defining which information systems will enter the implementation process. Not all systems in an organization have the same complexity or criticality, so each must be categorized according to the security level required by the ENS: basic, medium, or high.

This categorization is based on security dimensions (confidentiality, integrity, availability, etc.) and determines which measures from Annex II of the ENS apply in each case.

Development of the Security Policy

The Security Policy is the governing document of the organization’s security system. It defines security objectives, roles and responsibilities, the competencies of the involved departments, and establishes how information security will be managed on a daily basis.

It is a mandatory and fundamental document that must be approved by the organization’s leadership and aligned with the ENS principles.

Risk Analysis and Statement of Applicability

Once scope and policies are defined, a risk analysis is conducted for each system. This analysis identifies threats, evaluates the impact and likelihood of each risk, and serves as the basis for selecting the necessary security measures.

The Statement of Applicability (SoA) specifies which controls are applied and why, based on the risk analysis and system categorization. This document is essential to demonstrate that a rigorous and consistent method was followed to implement ENS measures.

Phase 3: Implementation of Security Measures

With the adaptation plan approved, technical and organizational measures outlined in the SoA are deployed.

Implementation of Organizational Measures

Organizational measures affect security management within the organization, including defining roles and responsibilities, staff training, and raising user awareness about security best practices.

It is important that these measures are integrated into daily processes rather than remaining in documents, ensuring that all personnel understand their role in overall security.

Technical Implementation of Security Measures

Technical implementation covers all technological aspects necessary to meet ENS requirements: secure network and system configurations, access controls, data encryption, monitoring, backups, and malware protection, among others.

These measures must be documented, tested, and verified to ensure they function as expected and align with the organization’s security policy.

Phase 4: Audit and Certification

Once the measures are deployed, the organization must undergo evaluation processes to certify actual compliance with the ENS.

Formal Audit and Internal Evaluation

For medium- and high-level systems, ENS compliance is verified through formal audits conducted by accredited entities. These audits check that the measures are not only documented but actually implemented and functioning correctly.

For basic-level systems, evaluation may be a self-assessment, although external audits are also allowed.

Obtaining ENS Conformity Certification

A positive audit result allows the issuance of an ENS conformity certificate, officially verifying that the organization meets the established requirements. This certification is crucial for participating in public tenders or providing services to organizations that require compliance.

Phase 5: Maintenance and Continuous Improvement

ENS implementation does not end with obtaining certification. The ENS requires a continuous improvement process, where the organization monitors and adapts its security measures in response to new risks, technological changes, or organizational changes.

Monitoring and Metrics

Regularly reporting the state of security with clear metrics and indicators allows deviations to be detected and measures reinforced before they become incidents. There are specific tools that facilitate this management, such as the INES project developed by the National Cryptologic Center.

Periodic Re-Evaluations

Audits and evaluations are not one-time events. The ENS establishes regular compliance reviews periodically, or when significant system changes occur, to ensure the security level is maintained over time.

Implementing the National Security Framework in an organization is a strategic process that spans from initial planning to certification and continuous improvement. Complying with the ENS not only fulfills legal obligations but also raises the level of security, builds trust, and facilitates access to business opportunities with the public sector.