In this ultimate how to implement guide to ISO 27001 Annex A 5.29 Information Security During Disruption, you will learn directly from an ISO 27001 Lead Auditor:
- The requirement of the control
- The required implementation steps
- The minimum requirement
I am Stuart Barker, the ISO 27001 Lead Auditor and author of the Ultimate ISO 27001 Toolkit.
Using over 30 years of industry experience across hundreds of audits, I’m giving you the exact templates, walkthroughs, and practical examples you need to achieve ISO 27001 certification.
Table of contents
- ISO 27001 Annex A Information security during disruption Implementation Checklist
- 1. Define the Minimum Security Baseline for Disruption
- 2. Verify Patch Parity for Standby Systems
- 3. Replicate Firewall and ACL Configurations
- 4. Establish Secure Emergency Communication Channels
- 5. Define “Break Glass” Access Procedures
- 6. Configure Local Logging for Disconnected States
- 7. Test Security Controls During BC Exercises
- 8. Secure the Hardcopy Fallback Process
- 9. Scan Data Integrity Before Repatriation
- 10. Conduct Post-Disruption Security Review
- ISO 27001 Annex A 5.29 SaaS / GRC Platform Implementation Failure Checklist
Implementing ISO 27001 Annex A 5.29 is the strategic process of ensuring information security controls remain effective during technical disruption or disaster recovery. The primary implementation requirement involves defining and verifying a specific security baseline for emergency operations, delivering the business benefit of continuous data protection and minimized risk exposure when operating in crisis modes.
ISO 27001 Annex A Information security during disruption Implementation Checklist
Use this implementation checklist to achieve compliance with ISO 27001 Annex A 5.29. Compliance requires you to demonstrate that your information security controls remain effective, or are adequately compensated for, when your organisation is operating in a crisis or disaster recovery mode.
1. Define the Minimum Security Baseline for Disruption
Control Requirement: The organisation must determine the level of information security required during a disruption.
Required Implementation Step: Open your Business Continuity Plan (BCP) and insert a specific “Security Baseline” section. You must explicitly list which security controls (e.g., MFA, VPN, Endpoint Protection) are non-negotiable and must remain active even when running on backup infrastructure.
Minimum Requirement: A defined list of “Critical Security Controls” within the BCP documentation.
2. Verify Patch Parity for Standby Systems
Control Requirement: Information security must be maintained at an equivalent level on alternative processing sites.
Required Implementation Step: Log in to your warm or cold standby servers and manually verify the OS and application patch levels. You must ensure that dormant Disaster Recovery (DR) hardware has not drifted behind the production environment, leaving it vulnerable to exploits the moment it is activated.
Minimum Requirement: A patch comparison report showing identical versions between Production and DR servers.
3. Replicate Firewall and ACL Configurations
Control Requirement: Network security perimeters must be maintained during a failover.
Required Implementation Step: Export the configuration files from your primary firewalls and compare them against the secondary site’s network gear using a “diff” tool. You must ensure that Access Control Lists (ACLs) and VLAN tagging rules are identical so that failover does not result in an “allow all” default state.
Minimum Requirement: Evidence of a configuration audit matching rulesets across primary and secondary locations.

