How to implement ISO 27001 Policies for Information Security and Pass the Audit
Introduction
In this ultimate guide to the ISO 27001 Annex A 5.1 Policies for Information Security you will learn
- What are Policies for Information Security
- What information security policies you need
- How to write policies for ISO 27001
- ISO 27001 policy templates you can download and use straight away
- An implementation guide
- An implementation checklist
- An audit checklist
Table of contents
- Introduction
- ISO 27001 Policies
- What are ISO 27001 Policies for Information Security?
- What is ISO 27001 Annex A 5.1?
- Purpose
- Definition
- How to implement ISO 27001 policies for information security
- ISO 27001 Policy Templates
- Implementation Checklist
- Audit Checklist
- Watch the Tutorial
- How to comply
- What the auditor will check
- Mistakes People Make
- Changes and Differences to ISO 27002:2013
- ISO 27001 Annex A 5.1 FAQ
- ISO 27001 Annex A 5.1 Attributes Table
- ISO 27002:2022 Control 5.1
ISO 27001 Policies
ISO 27001 policies are statements of what you do for information security and are used to communicate to staff what must be done and to customers what you do.
What are ISO 27001 Policies for Information Security?
Policies are a foundation stone of an information security management system. They are approved by senior management and outline an organisation’s approach to safeguarding sensitive data. Furthermore, they include both high-level and low-level guidelines, ensuring that all employees understand their responsibilities in maintaining data confidentiality, integrity, and availability. Subsequently, policy reviews, stakeholder communication, and a formal change management process are crucial for maintaining the effectiveness of this critical element of an organisation’s information security management system.
Basically they are intended to ensure the ongoing suitability, adequacy, and effectiveness of management direction and support for information security, aligning with all applicable business, legal, statutory, regulatory, and contractual requirements.
What is ISO 27001 Annex A 5.1?
ISO 27001 Annex A 5.1 Policies for Information Security is an ISO 27001 Annex A control that requires an organisation to have an information security policy and topic specific policies in place, communicated, reviewed and acknowledged.
I like this change from the old ISO 27001:2013 version as it calls out explicitly now that a pack or suite of policies will be required rather than just the headline information security policy.
Purpose
The purpose of the Annex A 5.1 Policies for Information Security is to ensure the suitability, adequacy and effectiveness of managements direction and support for information security.
Definition
ISO 27001 defines ISO 27001 Annex A 5.1 as:
Information security policy and topic-specific policies should be defined, approved by management, published, communicated to and acknowledged by relevant personnel and relevant interested parties, and reviewed at planned intervals and if significant changes occur.
ISO 27001:2022 Annex A 5.1 Policies for Information Security
DO IT YOURSELF ISO 27001
Finally! Implement ISO 27001 yourself without spending a penny on consultants or software.
How to implement ISO 27001 policies for information security
The following is compliance guidance for Policies for Information Security.
Organisations must have an “information security policy” approved by top management. This policy outlines the organisation’s approach to managing information security.
Time needed: 1 hour and 30 minutes
How to implement ISO 27001 policies for information security
- Assign ownership
The Senior leadership team is responsible for developing, approving, and implementing appropriate information security policies.
- Address policy requirements
The policy should address:
Business needs: Align with business strategies and requirements.
Legal and contractual obligations: Comply with all relevant laws, regulations, and contracts.
Security risks: Consider current and potential threats to information security. - Include policy statements
The policy should include statements on:
Defining information security: Clearly define what constitutes information security for the organisation.
Setting security objectives: Establish clear information security goals or a framework for setting them.
Guiding principles: Outline principles for all information security activities.
Compliance: Commit to meeting all applicable information security requirements.
Continuous improvement: Commit to ongoing improvement of the information security management system.
Responsibilities: Assign responsibility for information security management to specific roles.
Handling exceptions: Establish procedures for handling exceptions to security policies. - Include topic specific policies
Topic-specific policies provide more detailed guidance on implementing specific security controls. These policies should align with and support the main information security policy.
Examples of topic-specific policies include:
Access control
Physical security
Asset management
Data transfer
Device security
Network security
Incident management
Data backup
Cryptography
Data classification
Vulnerability management
Secure development - Approve policies
Top management must approve any changes to the main policy.
- Review policies
Relevant personnel with the necessary authority and expertise should develop, review, and approve topic-specific policies.
Regular policy reviews are essential. These reviews should assess:
Changes to the organisation’s business strategy.
Changes in the organisation’s technology.
Updates to laws, regulations, and contracts.
Evolving security risks and threats.
Lessons learned from security incidents.
Management reviews and audits should inform policy review processes. - Communicate Policies
Communication is key. Policies must be communicated to all relevant personnel and stakeholders in a clear, accessible, and understandable format. Recipients should acknowledge their understanding and agreement to comply.
The organisation can choose the format and names for these policy documents. Topic-specific policies can be called standards, directives, or other suitable names.
When distributing policies outside the organisation, care must be taken to protect confidential information
Supplementary Guidance
Topic-specific policies can vary across organisations.
| Information security policy | Topic-specific policy | |
|---|---|---|
| Level of detail | General or high-level | Specific and detailed |
| Documented and formally approved by | Top management | Appropriate level of management |
Table 1: Information Security Policy vs. Topic-Specific Policies
ISO 27001 Policy Templates
ISO 27001 Annex A 5.1 Policy Templates are already fully populated and ready to go.
Implementation Checklist
Policies for Information Security ISO 27001 Annex A 5.1 Implementation Checklist:
1. Establish Information Security Policy
Challenge
Defining the scope and objectives of the policy in a way that aligns with business needs and risk appetite.
Solution
Conduct a thorough ISO 27001 risk assessment to identify key threats and vulnerabilities. Involve senior management and key stakeholders in the policy development process.
2. Develop Supporting Policies
Challenge
Ensuring that supporting policies (e.g., access control, data classification, incident response) are comprehensive, consistent, and aligned with the overarching information security policy.
Solution
Use a standardised ISO 27001 template for developing supporting policies. Conduct regular reviews of existing policies to ensure they remain relevant and effective.
3. Communicate and Disseminate Policies
Challenge
Ensuring that all employees are aware of and understand the information security policies.
Solution
Utilise various communication channels (e.g., intranet, email, workshops) to disseminate policies. Provide clear and concise summaries of key policies.
4. Obtain Acknowledgement of Policies
Challenge
Ensuring that all employees acknowledge their understanding and commitment to complying with information security policies.
Solution
Implement a system for tracking and recording employee acknowledgements of policies. Consider using electronic signatures or online training modules.
5. Integrate Policies into Business Processes
Challenge
Ensuring that information security policies are integrated into all relevant business processes and activities.
Solution
Develop clear procedures and workflows that incorporate security controls and requirements. Provide regular training and guidance to employees on how to implement policies in their daily work.
6. Review and Update Policies
Challenge
Keeping information security policies up-to-date with changes in technology, threats, and regulatory requirements.
Solution
Conduct regular reviews of all information security policies. Establish a clear process for updating and approving policy changes.
7. Address Policy Exceptions
Challenge
Handling requests for exceptions to information security policies in a consistent and controlled manner.
Solution
Establish a clear process for evaluating and approving requests for policy exceptions. Ensure that all exceptions are properly documented and justified.
8. Monitor Compliance with Policies
Challenge
Ensuring that employees are complying with information security policies on an ongoing basis.
Solution
Implement monitoring and auditing procedures to identify and address any instances of non-compliance. Conduct regular internal audits to assess the effectiveness of information security controls.
9. Promote a Culture of Security Awareness
Challenge
Creating a culture where employees are aware of and committed to information security.
Solution
Lead by example and demonstrate a commitment to information security from senior management. Conduct regular security awareness campaigns and training.
10. Continual Improvement
Challenge
Continuously improving the information security policy framework based on feedback, lessons learned, and changes in the threat landscape.
Solution
Regularly gather feedback from employees and stakeholders on the effectiveness of information security policies. Conduct periodic reviews of the policy framework and make necessary adjustments.
Audit Checklist
Policies for Information Security ISO 27001 Annex A 5.1 Audit Checklist:
1. Review the Information Security Policy
- Examine the policy’s scope, objectives, and commitment to information security.
- Verify that it addresses confidentiality, integrity, and availability of information.
- Check for alignment with organisational goals, risk assessments, and legal/regulatory requirements.
2. Assess Supporting Policies
- Review supporting policies (e.g., access control, data classification, incident response).
- Ensure consistency and alignment with the overarching information security policy.
- Check for completeness, clarity, and relevance to the organisation’s specific needs.
3. Evaluate Policy Communication and Dissemination
- Verify methods used to communicate and disseminate policies to employees (e.g., intranet, email, workshops).
- Assess the effectiveness of communication channels in reaching all relevant personnel.
- Check for evidence of employee acknowledgement of policy understanding.
4. Examine Policy Implementation and Enforcement
- Observe how policies are integrated into daily business processes and activities.
- Interview employees to understand their awareness and adherence to policies.
- Check for evidence of consistent enforcement of policies across the organisation.
5. Review Policy Exception Handling
- Assess the process for evaluating and approving requests for exceptions to policies.
- Verify that exceptions are properly documented, justified, and reviewed.
- Check for consistency and fairness in the handling of exception requests.
6. Analyse Policy Review and Updates
- Examine the frequency and effectiveness of policy reviews.
- Verify that policies are updated to address changes in technology, threats, and business needs.
- Check for documentation of policy changes and approvals.
7. Assess Policy Compliance Monitoring
- Review the methods used to monitor compliance with information security policies (e.g., audits, reviews, incident reports).
- Evaluate the effectiveness of monitoring activities in identifying and addressing non-compliance.
- Check for corrective and preventive actions taken to address identified issues.
8. Interview Key Personnel
- Conduct interviews with key personnel involved in policy development, implementation, and enforcement (e.g., senior management, information security officers, employees). Gather their perspectives on the effectiveness and relevance of information security policies.
9. Check for Compliance with Legal and Regulatory Requirements
- Verify that information security policies comply with all applicable laws and regulations.
- Assess the organisation’s ability to demonstrate compliance with relevant legal and regulatory requirements.
10. Evaluate Overall Effectiveness
- Assess the overall effectiveness of the information security policy framework in achieving its objectives.
- Identify areas for improvement and make recommendations for enhancing the effectiveness of the policy framework.
Watch the Tutorial
Watch ISO 27001 Annex A 5.1 Policies for Information Security Explained Simply
How to comply
To comply with ISO 27001 Annex A 5.1 you are going to implement the ‘how’ to the ‘what’ the control is expecting. In short measure you are going to
- Write an ISO 27001 information security policy
- Supplement that information security policy with topic specific policies
- Ensure your policies are classified and have document mark up
- Have the policies approved by management and have evidence of that happening
- Publish the policies to a place everyone that needs to see them can see them
- Tell those people where those policies are
- Communicate your policies as part of your communication plan and document you did it
- Get people to acknowledge the policies and keep evidence that they have
- Plan to review your policies at least annually or if significant change occurs
- Keep records of your policy review and the changes
What the auditor will check
The audit is going to check a number of areas for compliance with Annex A 5.1. Lets go through them
1. That you can link policy to requirements
What this means is that you need to show that your policies are linked
- to the business strategy, which you recorded and evidenced in the ISO 27001 organisation overview template.
- to the law, regulations and contracts , which you recorded in the ISO 27001 legal register.
- to risks, which you recorded in your ISO 27001 risk register.
2. That your policy includes required statements
For the main ISO 27001 information security policy there are some required statements that need to be included. You need to
- define information security and the confidentiality, integrity and availability definition
- include your information security objectives
- include principles that will guide on information security activities activities
- include a commitment to satisfy applicable requirements related to information security
- have a commitment to continually improving your information security management system
- assign responsibilities for information security management to defined roles
- cover how you handle exemptions and exceptions.
3. That top management approved the policy
The audit will look to see that the main ISO 27001 information security policy and the topic specific policies have been approved and signed off by top management. The level will have been defined in your ISO 27001 Roles and Responsibilities Template document in line with ISO 27001 Annex A 5.2 Roles and Responsibilities
Mistakes People Make
In my experience, the top 3 mistakes people make for ISO 27001 Annex A 5.1 are
You have no evidence that anything actually happened
You need to keep records and minutes of everything. You need a paper trail to show it was done. Make sure you have updated communication plans, minutes of meetings, records of acknowledgement, records of approval. If it isn’t written down it didn’t happen.
One or more members of your team haven’t done what they should have done
Prior to the audit check that all members of the team have done what they should have. Do they know where the policies are? Have they acknowledged them? Did someone join last month and forget to do it? Check!
Your document and version control is wrong
Keeping your document version control up to date, making sure that version numbers match where used, having a review evidenced in the last 12 months, having documents that have no comments in are all good practices.
Changes and Differences to ISO 27002:2013
While the 2022 version of ISO 27001 retains many similarities to its predecessor, distinctions emerge:
Control 5.1 “Information Security Policies” in ISO 27001:2022 consolidates two controls (5.1.1 and 5.1.2) from the 2013 version. While the core principle remains the same – establishing and maintaining an information security policy – the 2022 version provides a more comprehensive and structured approach.
Key Enhancements in ISO 27001:2022
- Expanded Guidance: Control 5.1 now includes a detailed description of its purpose and expanded implementation guidance.
- Attributes Table: The inclusion of an attributes table facilitates easier mapping of controls to industry-specific terminologies.
- Enhanced Requirements: The policy requirements are more comprehensive, encompassing:
- Clear definition of information security.
- Establishment of information security objectives.
- Commitment to continuous improvement of the ISMS.
- Redefined Topic-Specific Policies: The scope of topic-specific policies has been revised, with a focus on key areas like incident management, asset management, and secure development.
Key Differences
Consolidation of Controls: The 2013 controls for “Policies for Information Security” and “Review of Policies for Information Security” are merged into a single control in the 2022 version.
Emphasis on Regular Review: The 2022 version explicitly emphasises the need for regular policy reviews, particularly in response to changes in the information security environment.
Comprehensive Policy Requirements: The 2022 version includes more detailed requirements for the information security policy, such as a commitment to continual improvement.
Overall, Control 5.1 in ISO 27001:2022 provides a more robust and comprehensive framework for establishing and managing information security policies within an organisation.
ISO 27001 Annex A 5.1 FAQ
The list of policies you need can be found here in the High Table Ultimate Guide to ISO 27001 Policies.
The primary purpose is to establish a framework for managing information security within an organisation. It outlines the organisation’s commitment to protecting its information assets from various threats.
You decide what policies you need by first completing your ISO 27001 Statement of Applicability and then identify in conjunction with the ISO 27001 standard the required policies for your implementation.
The list of policies you need can be found here in the High Table Ultimate Guide to ISO 27001 Policies.
There are policy templates for ISO 27001 Annex A 5.1 located in the High Table ISO 27001 Policy Templates Toolkit.
All of the ISO 27001 Policies have free, example PDF’s that you can download in the the High Table ISO 27001 Policy Templates Toolkit.
Yes. Whilst the ISO 27001 Annex A clauses are for consideration to be included in your ISO 27001 Statement of Applicability there is no reason we can think of that would allow you to exclude ISO 27001 Annex A 5.1. Policies are a fundamental part of any governance, risk and compliance framework. They are a fundamental part of any information security management system. They are explicitly required for ISO 27001.
Yes. You can write the policies for ISO 27001 Annex A 5.1 yourself. You will need a copy of the standard and approximately 3 months of time to do it. It would be advantageous to have a background in information security management systems. Alternatively you can download the ISO 27001 Policy Templates Toolkit.
ISO 27001 templates for ISO 27001 Annex A 5.1 are located in the High Table ISO 27001 Policy Templates Toolkit.
ISO 27001 Annex A 5.1 is not particularly hard. It can take a lot of time if you are doing it yourself but it is not technically very hard. Policies are statements of what you do so as long as you know what you do, or will do, you are in a good place. We would recommend templates to fast track your implementation.
ISO 27001 Annex A 5.1 will take approximately 3 months to complete if you are starting from nothing and doing it yourself. With an ISO 27001 Policy Template bundle it should take you less than 1 day.
The cost of ISO 27001 Annex A 5.1 will depend how you go about it. If you do it yourself it will be free but will take you about 3 months so the cost is lost opportunity cost as you tie up resource doing something that can easily be downloaded. If you download an ISO Policy Template toolkit then you are looking at a couple of hundred pounds / dollars.
ISO 27001 Annex A 5.1 Information Security Policies is important because people need to know what is expected of them. Policies are statements of what you do. They are not statements of how you do it. How you do it is covered in process documents.
The policies tell people what is expected of them and what they should do.
From a HR perspective you have no come back if someone does something wrong unless you have told them what they should do right and the consequences for getting it wrong.
If you don’t tell me, I don’t know.
No matter how simple, straightforward, obvious or common sense YOU think it is, someone, somewhere will disagree and there is nothing you can do about it unless you have told them.
The senior leadership team is responsible for the information security policies. As the policies set out the direction and what must be done it is the responsibility of the senior leadership to set and agree that direction.
Other than your ISO 27001 certification requiring it, the following are benefits of implementing ISO 27001 Annex A 5.1:
Improved security: People will know what is expected of them reducing the likelihood and impact of an attack
Reduced risk: Having direction on how you do things will reduce risk
Improved compliance: Standards and regulations require information security policies to be in place
Reputation Protection: In the event of a breach having effective policies will reduce the potential for fines and reduce the PR impact of an event
Scope: Defines the boundaries of the policy (e.g., which parts of the organisation, types of information).
Objectives: States the desired outcomes of the information security program (e.g., confidentiality, integrity, availability).
Responsibilities: Clearly defines the roles and responsibilities of management, employees, and other stakeholders.
Compliance: Outlines compliance with relevant laws, regulations, and standards (e.g., GDPR, PCI DSS).
Number of Policies: ISO 27001 doesn’t specify a specific number of policies. It requires an overarching Information Security Policy and supporting policies as needed to address identified risks.
Examples:
Access Control Policy
Data Classification Policy
Incident Response Policy
Remote Access Policy
Bring Your Own Device (BYOD) Policy
Email Security Policy
Social Media Policy
Intranet
Email
Workshops/Training Sessions
Employee Handbooks
Meetings
Posters
Security Awareness Campaigns
Require employees to sign acknowledgement forms.
Incorporate policy awareness into training programs.
Use online training modules with quizzes to test understanding.
Regularly: At least annually, or more frequently if there are significant changes (e.g., new technologies, regulatory updates, security incidents).
Disciplinary action may be taken, depending on the severity of the violation. Consequences can range from warnings to termination of employment.
Develop standard operating procedures (SOPs) that incorporate security controls.
Provide regular training and guidance to employees on how to implement policies in their daily work.
Conduct regular audits and assessments to monitor compliance.
Reduced risk of data breaches and cyberattacks
Improved data protection and compliance
Enhanced organisational reputation and trust
Increased employee awareness and security-conscious behaviour
Improved operational efficiency and productivity
ISO 27001 Annex A 5.1 is the information security control requirement of the ISO 27001 standard for ISO 27001 certification. ISO 27002 Control 5.1 is the implementation guidance for the control.
Yes, Policies for Information Security is a required information security control for ISO 27001 certification.
ISO 27001 Annex A 5.1 Attributes Table
| Control type | Information security properties | Cybersecurity concepts | Operational capabilities | Security domains |
|---|---|---|---|---|
| Preventive | Confidentiality | Identify | Governance | Governance and Ecosystem |
| Integrity | Resilience | |||
| Availability |
ISO 27002:2022 Control 5.1
ISO 27002:2022 Control 5.1 provides implementation guidance for ISO 27001 Policies for Information Security.
