How to Audit ISO 27001 Clause 5.3 Roles, Responsibilities, and Authorities

Auditing ISO 27001 Clause 5.3 is a vital governance review that verifies the alignment of organizational power with security accountability. By auditing this control, firms satisfy the Primary Implementation Requirement of role authorization, delivering the Business Benefit of a resilient, leadership-backed Information Security Management System (ISMS).

Auditing Clause 5.3 requires a rigorous examination of the governance framework to ensure that information security roles are clearly defined, properly authorised, and effectively communicated. The following steps guide an auditor through verifying that accountability is established and that there is a direct line of sight between security performance and senior leadership.

1. Provision Formal Role Appointments

Confirm that key security roles, such as the CISO or Information Security Manager, have been formally appointed. This ensures that the individual has the explicit mandate required to operate across departmental boundaries.

• Inspect formal appointment letters or Board meeting minutes.
• Verify that the appointment includes a clear scope of authority.
• Cross-reference the appointment with the organisational chart to ensure no conflicting reporting lines.

2. Formalise Security Responsibilities in Job Descriptions

Review standard and technical job descriptions to ensure they include specific security duties. This embeds security into the employment lifecycle and establishes legal accountability for the role holder.

• Sample job descriptions for IT, HR, and DevOps roles.
• Ensure that requirements for policy compliance and incident reporting are explicitly stated.
• Check for “Secure Coding” requirements in developer-specific job descriptions.

3. Audit the Assignment of IAM Governance Roles

Examine the assignment of responsibility for Identity and Access Management (IAM). Clear authority over who can approve, modify, or revoke access is critical for maintaining the principle of least privilege.

• Identify the designated “Asset Owners” within the Asset Register.
• Verify that access requests require approval from the specific Asset Owner, not just IT.
• Check the IAM role matrix for evidence of segregation of duties.

4. Review Reporting Lines to Top Management

Validate that the individual responsible for the ISMS has a direct and independent reporting line to senior leadership. This prevents security concerns from being suppressed by operational or financial priorities.

• Inspect the organisational structure for a direct path to the Board or CEO.
• Review Management Review Meeting minutes for evidence of security performance reports.
• Verify that the CISO has the authority to bypass middle management for urgent escalations.

5. Verify Authority for Incident Response

Confirm that the Incident Response Team (IRT) has the formal authority to take critical actions, such as isolating production servers or revoking admin access, during a breach.

• Inspect the Incident Management Plan for “Emergency Power” clauses.
• Check that Rules of Engagement (ROE) documents define the limits of this authority.
• Verify that stakeholders are aware of who holds the authority to invoke the “kill switch”.

6. Evaluate Resource Allocation Authority

Determine if those responsible for the ISMS have the authority to request or allocate budget and personnel. Responsibility without resource authority often leads to a hollow security posture.

• Review budget approval logs for security tools like MFA or SIEM platforms.
• Check for evidence of management’s response to security resource requests in meeting minutes.
• Confirm that security training budgets are controlled by the security function.

7. Audit Awareness of Security Roles

Interview a random sample of staff to verify their awareness of who holds key security authorities. Documentation is ineffective if the workforce does not know who to contact during a security event.

• Ask employees to name their designated Data Protection Officer or Security Manager.
• Verify staff know who has the authority to approve their access to sensitive systems.
• Check the internal directory or intranet for clear “Security Contact” listings.
• Confirm that new starters are introduced to these roles during induction.

8. Examine Risk Owner Accountability

Cross-reference the Risk Register with identified Risk Owners to ensure they have the seniority to accept or treat risks. Accountability must sit with those who can actually influence the business environment.

• Verify that Risk Owners are senior enough to sign off on high-level risk treatment plans.
• Confirm that Risk Owners have formally acknowledged their responsibilities.
• Check for evidence of Risk Owners making informed decisions on control implementation.

9. Revoke Obsolete Responsibilities

Audit the process for updating roles and responsibilities when an individual leaves the organisation or changes roles. Failure to update responsibilities leads to “orphaned” security controls.

• Review the Joiners, Movers, and Leavers (JML) process for ISMS role updates.
• Check that the ISMS responsibility matrix is updated following staff turnover.
• Verify that technical ownership tags in cloud environments (e.g., AWS/Azure) are current.

10. Inspect Communication of Authorities to Third Parties

Confirm that relevant security authorities are communicated to external suppliers and partners. This ensures that third parties know who is authorised to request data or initiate security audits.

• Review supplier contracts for designated security points of contact.
• Verify that external Rules of Engagement (ROE) documents specify internal authorities.
• Check that access requests from suppliers are approved by the correct internal role holder.

ISO 27001 Clause 5.3 Audit Steps and Evidence

Table 1: Detailed Audit Steps, Execution Methods, and Evidence Examples for Clause 5.3

Audit Step	How To Execute	Common Examples of Evidence
1. Role Appointment	Interview Top Management to confirm they understand who they have appointed to lead the ISMS.	Signed CISO appointment letter, Board meeting minutes.
2. JD Review	Sample HR files for technical and non-technical staff to find security-specific clauses.	Job descriptions including “Compliance with ISO 27001 policies”.
3. IAM Authority	Trace an admin access request from the ticket system to the final approver.	Okta or Active Directory logs showing approval by the Asset Owner.
4. Reporting Independence	Review the organisational chart and past performance reports for senior management.	ISMS performance slide decks presented to the Board.
5. Incident Authority	Ask the Incident Lead what happens if they need to shut down a production server.	Incident Response Plan, delegated authority list.
6. Budgetary Power	Verify if security tools requested in the last 12 months were approved and funded.	Financial approval emails, POs for security software (e.g. MFA).
7. Staff Interviews	Stop an employee in the hallway and ask who the “Data Protection Officer” is.	Auditor interview notes, staff awareness quiz results.
8. Risk Owner Check	Pick a “High” risk from the register and check the owner’s job title and authority.	Risk Register, signed Risk Treatment Plan (RTP).
9. Role Offboarding	Select a person who recently left the company and check who took over their security duties.	Updated responsibility matrix, HR leaver checklist.
10. Third-Party Sync	Check if a major supplier has a record of who is authorised to request an audit.	Supplier Security Annex, MSA contact list.

Common SaaS and GRC Platform Audit Failures

Table 2: Why automated SaaS and GRC platforms often fail ISO 27001 Clause 5.3 audits

Failure Mode	The SaaS / GRC Platform Bias	Audit Consequence
Generic Accountabilities	Platforms provide a “set of roles” that don’t match the organisation’s actual structure.	Non-conformity for failing to define roles relevant to the organisation.
Zombie Responsibility	Automated tools often assign “Ownership” to an admin account that no one monitors.	Critical security tasks are ignored because no human is actually responsible.
Reporting Silence	Platforms track “tasks” but do not facilitate the actual reporting line to Top Management.	Failure to prove that leadership is informed of ISMS performance.
Paper Sovereignty	The platform says someone is “Responsible,” but their job description says otherwise.	Auditor identifies a disconnect between the “GRC tool world” and reality.
Automated Approval Gaps	Systems auto-approve access based on logic, removing the “Human Authority” requirement.	Compliance finding regarding lack of management oversight for IAM.
Lack of Authority Proof	Software shows a “Green Tick” for role assignment without the required board-level evidence.	Major finding for lack of Top Management commitment.
Siloed Awareness	Only the GRC users know who the roles are; the rest of the company is in the dark.	Staff fail auditor interviews regarding security accountability.
Disconnected HR	Role changes in HR systems don’t sync to the GRC platform’s responsibility matrix.	ISMS responsibilities are left with people who have left the company.
Template Complacency	Staff assume that using the platform’s default roles constitutes “compliance”.	The organisation lacks a deep understanding of their own governance.
Proprietary Lock-in	Responsibility data is stuck in a tool format that is difficult for an auditor to parse.	Auditor frustration and potential delays in certification.

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