CISM Information Security Governance Practice Question
Which of the following is the FIRST step in the security policy development lifecycle?
⚠ Common exam trap
CISM often tests lifecycle ordering, and candidates frequently assume 'stakeholder consultation' or 'legal review' comes first because those sound collaborative or risk-averse — but the exam expects gap analysis as the foundational first step that identifies what the policy must address.
Answer choices
Why each option matters
Answer the question above first, then reveal the full breakdown to understand why each option is right or wrong.
Correct answer & explanation
✓
Gap analysis
In the security policy development lifecycle, a gap analysis is performed first to compare the organization's current state against the desired state (e.g., regulatory requirements, frameworks like ISO 27001 or NIST). This identifies what policies are missing or inadequate before drafting begins. Only after gaps are understood can legal review, stakeholder consultation, and formal approval meaningfully occur.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✓
Gap analysis
Why this is correct
Gap analysis compares current security posture against a chosen framework or standard, revealing deficiencies that the policy must address. This precedes drafting, approval and implementation, so it is genuinely first. Without identifying gaps, subsequent policy content lacks justified scope and direction.
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Legal review
Why it's wrong here
Legal review validates drafted policy against statutes and contracts; it occurs after the policy is written, not before. It is tempting because compliance scrutiny feels foundational, but the lifecycle begins with identifying the need and scope, then drafting, review, approval, publication and maintenance.
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Approval
Why it's wrong here
Approval comes last, after the policy has been drafted and reviewed; it authorises release rather than initiating development. It is tempting because sign-off is a mandatory governance gate, and in a policy revision cycle approval of the prior version may precede drafting the next, but it cannot be the first step of creating a new policy.
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Stakeholder consultation
Why it's wrong here
Consultation gathers input once a draft and scope exist; without an initial risk assessment or draft there is nothing concrete to consult on. It is tempting because stakeholder engagement is genuinely essential and early, but it follows identification of need and drafting, not precedes them.
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JA
Written and reviewed by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
Last reviewed September 2026 · checked against the official ISACA exam blueprint
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