The Ultimate Guide to ISO 27001:2022 Annex A 5.2 Roles and Responsibilities

ISO 27001 Roles and Responsibilities

ISO 27001 Information security roles and responsibilities is about ensuring the you have the required roles for information security and that those roles and responsibilities are documented.

It is important to have competent people in place implementing and operating the information security management system.

Key Takeaways

• Define Security Roles: Companies must clearly define who is in charge of information security. This means spelling out what each person’s job is.
• Assign and Document: After defining the roles, you need to assign people to them and write everything down. This makes sure everyone knows their part.
• Top Leadership is Responsible: The main leaders in the company are responsible for making sure these roles are set up correctly and that people have what they need to do their jobs.

What is ISO 27001 Annex A 5.2?

ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities is an ISO 27001 control that requires an organisation to define information security roles and responsibilities and allocate those to people.

Purpose

The purpose of ISO 27001 Annex A 5.2 is to ensure that a defined, approved and understood structure is in place for the implementation and operation of the information security management system.

Definition

ISO 27001 defines ISO 27001 Annex A 5.2 Roles and Responsibilities as:

Information security roles and responsibilities should be defined and allocated according to the organisation needs.

ISO27001:2022 Annex A 5.2 Information Security Roles and Responsibilities

General Guidance

You are going to have to

• work out what roles you need
• decide on what responsibilities those roles have
• pick people in your organisation and assign those roles and responsibilities to them
• document it
• publish it
• have them acknowledged by staff
• review them at regular intervals

How to document roles and responsibilities

You are going to need copies of the relevant standards for information security.

You then need to work through policies, research organisational best practice, and work out exactly what information security roles and responsibilities you need.

When you implement it, depending on the size of your organisation, it is not uncommon for one person to hold more than one role.

You may be thinking, if it is one person doing all the work why do I need to document so many roles?

The short answer is because the ISO 27001 standard requires it and if you are going for ISO 27001 certification then you need it.

The longer answer is that as you grow, more people will take on these roles and spread the work load.

How to identify the mandatory roles you need

You start with the list of controls from Annex A that you have chosen. Then, you will figure out what roles are needed for each of those controls.

Once you have identified all the roles, you will assign them to people in your organisation. It’s important to make sure the person you choose is able to perform the role and that their new duties won’t conflict with their current responsibilities.

Can one person hold more than one role?

If you work in a small business, you might wonder if you need all these roles and if one person can handle multiple roles. The answer is yes, you do need certain specific roles, and yes, one person can indeed hold more than one role.

What is an ISO 27001 Management Review Team?

This group sits above the information security management system. It has very specific requirements and a defined role. The team’s responsibilities include:

• Oversight and approval of policies and procedures.
• Ensuring continual improvement of the system.
• Reviewing the risk register.

ISO 27001 Roles and Responsibilities Template

The ISO 27001 Assigned Roles and Responsibilities template has the roles and responsibilities already written out and all you have to do is put the names of the people in it.

How to Implement Annex A 5.2

1. Define Key Roles and Responsibilities

Challenge: Identifying and defining all necessary roles and responsibilities related to information security.

Solution: Conduct a thorough risk assessment to understand the specific security needs of the organisation. Involve key stakeholders and subject matter experts in the process.

2. Document Roles and Responsibilities

Challenge: Ensuring that all roles and responsibilities are clearly documented and easily accessible to all employees.

Solution: Create a centralised repository for all information security related documentation, such as a shared drive or an internal wiki.

3. Assign Roles and Responsibilities

Challenge: Matching the right individuals to the appropriate roles and responsibilities based on their skills, experience, and job functions.

Solution: Consider factors such as job descriptions, skill assessments, and employee preferences when assigning roles and responsibilities.

4. Communicate and Train

Challenge: Ensuring that all employees understand their roles and responsibilities related to information security.

Solution: Conduct regular training sessions and awareness campaigns to educate employees on their specific responsibilities.

5. Obtain Acknowledgement

Challenge: Ensuring that all employees acknowledge their understanding and acceptance of their assigned roles and responsibilities.

Solution: Implement a system for tracking and recording employee acknowledgements, such as signed forms or online training modules.

6. Monitor and Review

Challenge: Regularly monitoring and reviewing the effectiveness of role and responsibility assignments.

Solution: Conduct periodic reviews to assess whether the current assignments are still appropriate and effective. Consider feedback from employees and managers.

7. Address Changes

Challenge: Ensuring that roles and responsibilities are updated to reflect changes in the organisation, technology, and threat landscape.

Solution: Regularly review and update role and responsibility assignments as needed. Communicate any changes to all affected employees.

8. Ensure Adequate Resources

Challenge: Providing employees with the necessary resources and support to fulfil their information security responsibilities.

Solution: Provide employees with the necessary training, tools, and resources to effectively perform their security-related duties.

9. Promote Accountability

Challenge: Ensuring that individuals are held accountable for fulfilling their information security responsibilities.

Solution: Establish clear consequences for non-compliance with information security policies and procedures. Conduct regular audits and reviews to identify and address any issues.

10. Continual Improvement

Challenge: Continuously improving the process for defining, assigning, and managing information security roles and responsibilities.

Solution: Regularly gather feedback from employees and stakeholders to identify areas for improvement. Conduct periodic reviews of the process and make necessary adjustments.

ISO 27001 Annex A 5.2 Explained: A Complete Guide

In the video ISO 27001 Annex A 5.2 Roles and Responsibilities Explained show you how to implement it and how to pass the audit.

How to audit ISO 27001 Annex A 5.2

To conduct an internal audit of ISO 27001 Annex A 5.2 Roles and Responsibilities use the following audit checklist which sets out what to audit and how to audit it.

1. Review Role and Responsibility Documentation

• Examine the documented information security roles and responsibilities matrix.
• Verify that it includes all key roles and responsibilities within the organisation.
• Check for clarity, completeness, and consistency in the documentation.

2. Assess Role and Responsibility Assignments

• Determine if roles and responsibilities are appropriately assigned to individuals based on their skills, experience, and job functions.
• Evaluate whether the workload is appropriately distributed across individuals.
• Check for any potential conflicts of interest or overlaps in responsibilities.

3. Verify Employee Understanding

• Interview employees to assess their understanding of their own roles and responsibilities related to information security.
• Observe employee behaviour to determine if they are fulfilling their assigned responsibilities.
• Review training records to ensure that employees have received adequate training on their security-related duties.

4. Examine Role and Responsibility Communication

• Verify that roles and responsibilities are effectively communicated to all employees through appropriate channels (e.g., employee handbooks, intranet, training sessions).
• Check for evidence of employee acknowledgement of their understanding and acceptance of their roles and responsibilities.

5. Assess Role and Responsibility Reviews

• Determine if there is a process in place for regularly reviewing and updating roles and responsibilities.
• Evaluate the effectiveness of the review process in ensuring that roles and responsibilities remain relevant and appropriate.
• Check for documentation of role and responsibility reviews and any resulting changes.

6. Evaluate Resource Allocation

• Assess whether employees have the necessary resources (e.g., training, tools, support) to effectively fulfil their information security responsibilities.
• Identify any resource gaps and recommend appropriate corrective actions.

7. Examine Accountability Mechanisms

• Determine if there are clear mechanisms in place for holding individuals accountable for fulfilling their information security responsibilities.
• Evaluate the effectiveness of disciplinary actions taken for non-compliance with information security policies and procedures.

8. Interview Key Personnel

• Conduct interviews with key personnel, such as senior management, information security officers, and employees.
• Gather their perspectives on the effectiveness of the organisation’s approach to defining, assigning, and managing information security roles and responsibilities.

9. Check for Compliance with Legal and Regulatory Requirements

• Verify that the organisation’s approach to roles and responsibilities complies with all applicable laws and regulations.

10. Evaluate Overall Effectiveness

• Assess the overall effectiveness of the organisation’s approach to defining, assigning, and managing information security roles and responsibilities.
• Identify areas for improvement and make recommendations for enhancing the effectiveness of the system.

How to pass the ISO 27001 Annex A 5.2 audit

To comply with ISO 27001 Annex A 5.2 you are going to implement the ‘how’ to the ‘what’ the control is expecting.

• Write an ISO 27001 roles and responsibilities document
• Set out what roles you have and the responsibilities those roles undertake
• Create an organisation of the roles to show how they work together
• Assign people to those roles and document when they were assigned
• Review and approve the roles and responsibilities document
• Publish the roles and responsibilities document to a place everyone that needs to see them can see them
• Plan to review your roles and responsibilities at least annually or if significant change occurs
• Keep records of your review and the changes

What an auditor looks for

The audit is going to check a number of areas for compliance with ISO 27001 Annex A 5.2 Roles and Responsibilities. Lets go through them:

1. That you have documented your roles and responsibilities

What this means is that you will have a document that sets out what the roles and responsibilities are that are involved in the ISO 27001 implementation and operation of your information security management system. What needs doing and what will be done.

2. That you have have allocated your roles and responsibilities

For the roles and responsible that you have defined and documented you are going to allocate people to them to do the work. Has each defined role been allocated to someone and can you say who if asked?

3. That allocated people are competent

We allocate people but not just any old people. The people that do the role have to be competent to perform the role. This usually means the checking of qualifications, training and / or experience.

Top 3 ISO 27001 Annex A 5.2 Mistakes and How to Fix Them

In my experience, the top 3 mistakes people make for ISO 27001 Annex A 5.2 Roles and Responsibilities are:

1. You have not documented the actual roles you require

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.

2. You allocated a role to someone that no longer works here

Prior to the audit check that roles are assigned to people that actually work here. You will be surprised how often this trips people up. Check!

3. 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.

How can an ISO 27001 Toolkit help with ISO 27001 Annex A 5.2?

The ISO 27001 toolkit provides the templates and training for ISO 27001 annex a 5.2 and specifically the ISO 27001 Assigned Roles and Responsibilities template that has best practice roles already defined where you just allocate people to the role.

In addition to that it provides support documentation for managing competence in the ISO 27001 competency matrix template and the ISO 27001 accountability matrix template to allocate people to each of the ISO 27001 clauses and controls.

The ISO 27001 statement of applicability template will define the controls that you have and as a result the roles that you need to operate those controls.

ISO 27001 Annex A 5.2: Roles and Responsibilities FAQ

Further Reading

ISO 27001 Clause 5.3 Organisational Roles, Responsibilities and Authorities

ISO 27001 Clause 7.2 Competence

ISO 27001 Competency Matrix Beginner’s Guide

ISO 27001 Roles and Responsibilities Explained

ISO 27001 Annex a 5.4 Management Responsibilities

ISO 27001 Annex A 6.5 Responsibilities After Termination Or Change Of Employment

Controls and Attribute Values