Implementing ISO 27001 Annex A 5.24 is the strategic process of establishing a resilient framework for identifying and responding to security breaches. The primary implementation requirement centers on documented technical playbooks and physical preparedness, delivering the business benefit of minimized operational downtime and legal regulatory compliance.
ISO 27001 Annex A 5.24 Information Security Incident Management Planning and Preparation Implementation Checklist
Use this implementation checklist to achieve compliance with ISO 27001 Annex A 5.24. Genuine preparedness is forged in local command-line dry runs and physical “war room” binders, not within the sanitised confines of a SaaS notification dashboard.
1. Draft a Physical Information Security Incident Management Policy
Control Requirement: Establish a documented policy and supporting procedures for managing information security incidents.
Required Implementation Step: Open your local document editor and draft a specific policy that defines what constitutes an ‘incident’ versus an ‘event’. Print a physical copy and place it in an ‘Emergency Response’ binder that is accessible even if your primary network is encrypted by ransomware.
Minimum Requirement: A version-controlled policy document signed by the CISO and stored in a secure, offline location.
2. Form an Internal Incident Response Team (IRT)
Control Requirement: Assign specific roles and responsibilities for incident management activities.
Required Implementation Step: Do not just list ‘IT’ as the owner. Manually assign specific individuals from IT, Legal, HR, and Communications to the team; document their direct office phone numbers and home contact details in a private, encrypted file.
Minimum Requirement: A formal ‘Contact Matrix’ identifying the Lead Incident Handler and secondary deputies.
3. Define Manual Incident Classification and Escalation Criteria
Control Requirement: Establish criteria for prioritising and escalating incidents based on impact and urgency.
Required Implementation Step: Create a physical 3×3 matrix mapping business impact against urgency. Manually define the ‘Red Alert’ triggers that require immediate board-level notification, bypassing the ticket-queue mentality of most GRC tools.
Minimum Requirement: A documented classification table that allows any staff member to identify a ‘Critical’ incident in under 60 seconds.
4. Establish Out-of-Band Communication Channels
Control Requirement: Ensure communication mechanisms are in place to report and manage incidents when primary systems fail.
Required Implementation Step: Set up a dedicated communication channel (e.g., a physical phone tree or a hardened, independent messaging app) that does not rely on the corporate Active Directory or Office 365 environment.
Minimum Requirement: A tested communication plan that functions during a total primary network outage.
5. Configure Local Forensic Logging Baselines
Control Requirement: Ensure that sufficient logging and monitoring are in place to detect and investigate incidents.
Required Implementation Step: Log into your core switches and servers to manually verify that NTP (Network Time Protocol) is synchronised across all devices. Ensure logs are being piped to a local, immutable ‘Write Once Read Many’ (WORM) storage device that is physically separate from the production environment.
Minimum Requirement: Synchronised timestamps across 100% of critical infrastructure logs.
6. Create Technical ‘Playbooks’ for Common Attack Vectors
Control Requirement: Develop procedures to respond to specific types of security incidents.
Required Implementation Step: Write manual ‘Playbooks’ for Ransomware, DDoS, and Phishing. These must include the specific command-line strings needed to isolate a VLAN or revoke an OAuth token—information a GRC platform cannot provide during a live breach.
Minimum Requirement: Three technical playbooks detailing manual isolation and containment steps.
7. Secure a Forensic Evidence Kit
Control Requirement: Establish procedures for the identification, collection, acquisition, and preservation of digital evidence.
Required Implementation Step: Purchase and store a physical ‘Forensic Kit’ containing write-blockers, sterile USB drives, and evidence bags. Document the manual process for maintaining a ‘Chain of Custody’ for any hardware seized during an investigation.
Minimum Requirement: A physical evidence kit and a printed Chain of Custody template.
8. Conduct a Manual Tabletop Simulation
Control Requirement: Regularly test the incident management plan through exercises and simulations.
Required Implementation Step: Gather the IRT in a physical room and run a ‘silent’ tabletop exercise where you simulate a total server room fire or data breach. Manually record the team’s actions and failures on a whiteboard, then update your procedures based on these real-world observations.
Minimum Requirement: An ‘After-Action Report’ (AAR) from a simulated exercise conducted within the last 12 months.
9. Formalise External Reporting Obligations
Control Requirement: Define procedures for reporting incidents to external authorities and stakeholders.
Required Implementation Step: Manually research and document the specific reporting portals and deadlines for the ICO (UK) or relevant regulatory bodies. Draft ‘Pro-Forma’ notification letters that can be filled in manually to save time during the first 72 hours of a breach.
Minimum Requirement: A list of external regulatory contacts and pre-drafted notification templates.
10. Implement a Post-Incident Review (PIR) Process
Control Requirement: Use lessons learned from past incidents to improve the incident management plan.
Required Implementation Step: Create a mandatory ‘Closed-Loop’ procedure where every ‘Medium’ or ‘High’ incident requires a physical meeting to document root causes. Update the ‘config files’ or ‘physical security’ controls manually following the meeting to ensure the vulnerability is closed.
Minimum Requirement: A signed PIR document for the most recent security incident or exercise.
ISO 27001 Annex A 5.24 SaaS / GRC Platform Implementation Failure Checklist
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Plan Accessibility | Stores the IR Plan in a cloud-based GRC portal. | If the network is down or credentials are compromised, you cannot access your plan; you need a physical binder. |
| Team Mobilisation | Relies on ‘In-App’ notifications to alert the team. | Attackers monitor your apps; you need an out-of-band phone tree that doesn’t touch the internet. |
| Technical Response | Provides a ‘Workflow’ that says “Isolate the Server.” | SaaS tools don’t tell you the specific CLI command to shut down a port on a legacy Cisco switch. |
| Evidence Integrity | Captures ‘screenshots’ within the GRC platform. | Screenshots are often inadmissible in UK courts; you need write-blocked images and a manual chain of custody. |
| Time Synchronisation | Assumes all system clocks are “fine” because the dashboard is green. | If your server logs are 5 seconds apart from your firewall logs, your forensic timeline is useless to an auditor. |
| External Reporting | Links to a generic ‘Regulatory News’ feed. | Fails to provide the specific, local 72-hour reporting templates required by the ICO for UK data breaches. |
| Testing & Exercise | Marks a ‘Self-Attestation’ box that a test was done. | Auditors want to see the messy whiteboard notes and the failed steps from a real physical tabletop simulation. |
| Root Cause Analysis | Uses a drop-down menu for ‘Cause’ (e.g., ‘Human Error’). | This masks the actual config file failure; real compliance requires a technical deep dive into the server room. |
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