ISO 27001:2022 Annex A 5.2 Information security roles and responsibilities

Implementing ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities is the mandatory governance process of defining, documenting, and allocating security duties to competent personnel. This control ensures Explicit Definition of accountability across the organization, preventing coverage gaps and delivering the Business Benefit of a legally defensible chain of command that satisfies auditors.

In this guide, I will show you exactly how to implement ISO 27001 Annex A 5.2 and ensure you pass your audit. You will get a complete walkthrough of the control, practical implementation examples, and access to the ISO 27001 templates and toolkit that make compliance easy.

I am Stuart Barker, an ISO 27001 Lead Auditor with over 30 years of experience conducting hundreds of audits. I will cut through the jargon to show you exactly what changed in the 2022 update and provide you with plain-English advice to get you certified.

Key Takeaways: ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities

ISO 27001 Annex A 5.2 requires organizations to define and allocate information security roles and responsibilities based on their specific needs. This control ensures that everyone, from the Board of Directors to the newest employee, knows exactly what is expected of them regarding data protection. Without clearly defined roles, critical security tasks (like incident response or patch management) can easily fall through the cracks, leading to audit failures and security breaches.

• You must clearly define who is in charge of information security. This means spelling out what each person’s job is.
• After defining the roles, you need to assign people to them and write everything down. This makes sure everyone knows their part.
• 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.

Core requirements for compliance include:

• Explicit Definition: You must clearly document what each security role does. This is typically achieved through a Roles and Responsibilities Matrix or by including security duties within standard job descriptions.
• Allocation to Competent Personnel: Roles must be assigned to individuals who have the skills and authority to perform them. In smaller organizations, it is common (and acceptable) for one person to hold multiple roles.
• Management Oversight: Senior leadership is accountable for ensuring these roles are correctly set up and adequately resourced with the necessary tools, time, and training.
• Avoidance of Conflict: Responsibilities should be allocated to prevent “conflict of interest.” For example, the person who implements a security change should ideally not be the only person who approves it.
• Regular Review: Roles and responsibilities must be reviewed at least annually or whenever there is a significant change in the organization, such as a restructuring or a major technology shift.

Audit Focus: Auditors will look for “The Ownership Gap”:

1. Staff Interviews: “Who is responsible for managing your firewall?” or “What is your specific role if a data breach occurs?”
2. Evidence of Assignment: “Show me where your Chief Information Security Officer (CISO) role is formally documented and who has been appointed to it.”
3. Resource Support: They will check if the people assigned to these roles have the actual time and budget to carry them out.

Common Roles Matrix (RACI Example):

Activity	CISO	CEO / Board	IT Manager	HR Manager	All Staff	ISO 27001:2022 Control
Approve Policy	C (Consulted)	A (Accountable)	I (Informed)	I	I	Annex A 5.1 / 5.2
Manage Incidents	R (Responsible)	A	C	C	I	Annex A 5.2 / 5.24
Patch Systems	C	I	R	I	I	Annex A 5.2 / 8.8
Screen New Hires	I	I	I	R	I	Annex A 5.2 / 6.1
Report Phishing	I	I	I	I	R	Annex A 5.2 / 6.3

What is ISO 27001 Annex A 5.2?

ISO 27001 Annex A 5.2 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.

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

The current version of the ISO 27001 standard is ISO/IEC 27001:2022, which came out in October 2022. In this standard, the control is called “Information Security Roles and Responsibilities”

ISO 27001 Annex A 5.2 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.

ISO 27001 Annex A 5.2 Control Objective

The official goal in the standard is simple: You should clearly define and give out all information security jobs and tasks based on your company’s needs.

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

Watch the ISO 27001 Annex A 5.2 Video Tutorial

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

ISO 27001 Annex A 5.2 Podcast

In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001 Annex A 5.2 Roles and Responsibilities The podcast explores what it is, why it is important and the path to compliance.

ISO 27001 Annex A 5.2 Implementation Guide

To implement this control you should have clear plans and policies. Here are some important steps:

• 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.

How to implement ISO 27001 Annex A 5.2

Implementing ISO 27001 Annex A 5.2 is not about creating new job titles for the sake of it: it is about establishing a legally defensible chain of command. If everyone is responsible for security: then nobody is. To satisfy the auditor and pass your Stage 2 audit: you must define exactly who is liable for your assets: risks and processes. Follow these 10 practical steps to build a robust governance structure.

1. Formalise Top Management accountability

You must establish the “tone from the top” by defining the ultimate owner of information security risk: usually the CEO or Board. This action satisfies Clause 5.1 and ensures security is treated as a business governance issue rather than just an IT problem.

• Update the Board of Directors’ Terms of Reference to include specific oversight of the Information Security Management System (ISMS).
• Document the CEO or Managing Director as the final “Accountable” party for security risk acceptance.
• Record this appointment in the formal minutes of your Management Review meeting to provide audit evidence.

2. Appoint the Information Security Manager (CISO)

Provision a specific role dedicated to the day-to-day operation: monitoring and reporting of the ISMS performance. This result ensures a single point of contact exists for internal staff and external auditors regarding security compliance.

• Draft a role description that explicitly mandates the maintenance of ISO 27001 certification and internal audit scheduling.
• Assign administrative privileges in your Identity and Access Management (IAM) system to this role for log review.
• Ensure this role has a direct reporting line to Top Management to ensure independence and authority.

3. Assign Information Asset Owners

Identify and document specific owners for every asset listed in your Information Asset Register. This step ensures that every piece of data: hardware and software has a named custodian responsible for its classification and protection throughout its lifecycle.

• Update your Asset Register to include a mandatory “Owner” column next to every Asset ID.
• Select Asset Owners who have the budgetary authority to approve security controls for that asset.
• Train owners on their responsibility to review access rights and classification labels at least annually.

4. Designate Risk Owners

Allocate responsibility for managing specific risks identified in your Risk Register. This ensures that when a risk treatment plan is approved: a specific individual is personally accountable for executing the remediation and verifying its effectiveness.

• Map every risk in your Risk Assessment to a named individual rather than a generic department.
• Require Risk Owners to formally sign off on the Residual Risk level after treatment is applied.
• Link Risk Ownership duties to annual performance reviews to ensure active engagement.

5. Embed security duties into Job Descriptions

Update the employment documentation for all staff to include general and role-specific security responsibilities. This creates a contractual obligation for security and supports valid disciplinary processes if policies are breached.

• Add a standard clause to all employment contracts requiring adherence to the Acceptable Use Policy (AUP).
• Define specific technical duties for IT staff: such as firewall configuration: patch management and backup verification.
• Ensure HR onboarding processes require a signed acknowledgement of these duties before system access is granted.

6. Enforce Segregation of Duties (SoD)

Configure your organisational roles and technical permissions to ensure no single person can compromise a critical process. This technical control prevents fraud and error by requiring dual initiation or approval for sensitive tasks.

• Audit your IAM roles to ensure developers do not have “Write” or “Admin” access to production environments.
• Separate the role of “Payment Initiator” from “Payment Approver” in your finance platforms.
• Document these separation rules in your Access Control Policy to satisfy the auditor’s segregation requirements.

7. Execute a RACI Matrix

Develop a Responsible: Accountable: Consulted and Informed (RACI) matrix to map every ISMS control to a stakeholder. This document serves as the primary navigation tool during an audit to demonstrate 100% coverage of Annex A.

• List all 93 Annex A controls on the Y-axis and your organisational roles on the X-axis.
• Ensure only one person is “Accountable” (A) for each task to avoid decision paralysis.
• Publish the RACI matrix on your company intranet so all staff know exactly who to contact for specific security issues.

8. Define Project Management security roles

Integrate specific security responsibilities into your project management lifecycle. This ensures that information security is considered at the “Design” phase of any new change or project implementation.

• Appoint a “Security Champion” within project teams to liaise with the Information Security Manager.
• Mandate that Project Leads are responsible for conducting Data Protection Impact Assessments (DPIAs) for new processing activities.
• Formalise the “Go/No-Go” authority of the CISO for project releases that fail security testing.

9. Formalise Supplier and Third-Party responsibilities

Document the specific security obligations of vendors and contractors within your ecosystem. This action extends your governance framework beyond your physical perimeter and satisfies Annex A 5.19.

• Draft “Rules of Engagement” (ROE) documents for third-party developers or penetration testers.
• Include specific “Right to Audit” clauses in supplier contracts to verify their role performance.
• Assign an internal “Vendor Manager” responsible for checking supplier SOC 2 or ISO 27001 certificates annually.

10. Audit and review role assignments

Schedule an annual review of all roles and access rights to maintain alignment with the organisation’s size and strategy. This prevents “privilege creep” and ensures responsibilities are re-assigned immediately when staff leave.

• Conduct a “Mover and Leaver” audit to verify that access was revoked for departed employees within 24 hours.
• Review the RACI matrix during the Management Review meeting to ensure it reflects the current organisational chart.
• Verify that all appointed roles have received adequate competency training to perform their security duties effectively.

Common Roles Matrix

Activity	CISO	CEO / Board	IT Manager	HR Manager	All Staff
Approve Security Policy	C (Consulted)	A (Accountable)	I (Informed)	I	I
Manage Incidents	R (Responsible)	A	C	C	I
Patch Systems	C	I	R	I	I
Screen New Hires	I	I	I	R	I
Report Phishing	I	I	I	I	R

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.

ISO 27001 Annex A 5.2 Implementation Checklist

ISO 27001 Annex A 5.2 Implementation Checklist: Challenges and Solutions

Implementation Step	Common Challenge	Recommended Solution
1. Define Key Roles	Identifying and defining all necessary roles and responsibilities related to information security.	Conduct a thorough risk assessment to understand specific security needs. Involve key stakeholders and subject matter experts.
2. Document Roles	Ensuring that all roles and responsibilities are clearly documented and easily accessible to all employees.	Create a centralised repository for all information security related documentation, such as a shared drive or an internal wiki.
3. Assign Responsibilities	Matching the right individuals to the appropriate roles based on their skills, experience, and job functions.	Consider factors such as job descriptions, skill assessments, and employee preferences when assigning specific security duties.
4. Communicate and Train	Ensuring that all employees understand their specific roles regarding information security.	Conduct regular training sessions and awareness campaigns to educate employees on their responsibilities.
5. Obtain Acknowledgement	Ensuring that all employees acknowledge their understanding and acceptance of their assigned roles.	Implement a system for tracking and recording employee acknowledgements, such as signed forms or online training modules.
6. Monitor and Review	Regularly monitoring and reviewing the effectiveness of role and responsibility assignments.	Conduct periodic reviews to assess whether current assignments are effective, considering feedback from employees and managers.
7. Address Changes	Ensuring roles are updated to reflect changes in the organisation, technology, and threat landscape.	Regularly review and update assignments as needed. Communicate any changes to all affected employees immediately.
8. Ensure Adequate Resources	Providing employees with the necessary resources and support to fulfil their information security responsibilities.	Allocated budget and provide employees with the necessary training, tools, and resources to effectively perform their security-related duties.
9. Promote Accountability	Ensuring that individuals are held accountable for fulfilling their information security responsibilities.	Establish clear consequences for non-compliance. Conduct regular audits and reviews to identify and address performance issues.
10. Continual Improvement	Continuously improving the process for defining, assigning, and managing security roles.	Regularly gather feedback from employees and stakeholders to identify areas for improvement and make necessary adjustments.

How to audit ISO 27001 Annex A 5.2: An Auditor’s Guide

To conduct a forensic internal audit of ISO 27001 Annex A 5.2: you must move beyond a checkbox exercise. Use this audit checklist to rigorously test whether roles are defined: assigned: understood and effective in practice.

1. Review Role and Responsibility documentation

Examine the documented information security roles and responsibilities matrix (often a RACI). I am looking for clarity: completeness and consistency across your governance framework.

• Verify that the matrix includes all key roles: including Asset Owners: Risk Owners and the CISO.
• Check that the “Accountable” party is clearly defined for every Annex A control to prevent decision paralysis.
• Ensure the documentation aligns with the current organisational chart and has been version-controlled in the last 12 months.

2. Assess Role and Responsibility assignments

Determine if roles are assigned to individuals based on actual competence rather than just job title. I will assess workload distribution and check for toxic combinations of access.

• Evaluate whether the CISO has the bandwidth to manage the ISMS or if the workload is unsustainable.
• Check for conflicts of interest: such as a developer having “release” authority: which violates Segregation of Duties (SoD).
• Verify that individuals assigned technical security duties hold the necessary certifications or experience.

3. Verify employee understanding

Don’t just trust the paperwork: verify the reality. Interview employees to assess their understanding of their specific security duties.

• Ask Asset Owners to demonstrate how they review access rights for their specific data sets.
• Observe employee behaviour: such as screen locking and clear desk compliance: to see if responsibilities are being enacted.
• Review training records to confirm that staff have received role-specific training: not just generic awareness induction.

4. Examine Role and Responsibility communication

Verify that expectations have been effectively communicated through official channels. If it isn’t written down and communicated: it didn’t happen.

• Check employee handbooks and the intranet to ensure security roles are published and accessible.
• Look for signed evidence of acknowledgement: such as an employment contract clause or a digital policy sign-off in your LMS.
• Ensure that changes to responsibilities are communicated via formal change management notifications.

5. Assess Role and Responsibility reviews

Determine if there is a dynamic process for keeping roles relevant. Security is not static: and neither are your personnel.

• Audit the “Mover and Leaver” process to ensure roles are updated immediately when staff change jobs.
• Check the minutes of the Management Review for evidence that role effectiveness was discussed.
• Verify that the RACI matrix is reviewed at least annually or triggered by significant organisational changes.

6. Evaluate resource allocation

Assess whether employees have the tools and support to do the job. A CISO without a budget or an Asset Owner without access to logs cannot fulfil their duties.

• Interview the Security Lead to determine if budget constraints are preventing effective monitoring.
• Verify that IT staff have access to the necessary vulnerability scanning and patch management tools.
• Identify resource gaps in the Risk Treatment Plan where actions are overdue due to “lack of time/people.”

7. Examine accountability mechanisms

Determine if there are teeth behind the responsibilities. Accountability means there are consequences for non-compliance.

• Review HR records for evidence of disciplinary actions taken for security violations.
• Check if Risk Owners are formally required to sign off on residual risk acceptance.
• Evaluate if security performance objectives are linked to annual staff appraisals.

8. Interview key personnel

Conduct targeted interviews with Senior Management and Information Security Officers. Their perspective reveals the true culture of the organisation.

• Ask the CEO/Board member: “Who is ultimately accountable for a data breach in this company?”
• Gather perspectives on whether the security function is seen as a business enabler or a blocker.
• Ask the CISO if they have sufficient independence and direct access to Top Management.

9. Check for compliance with legal and regulatory requirements

Verify that your role definitions satisfy external obligations. This is critical for organisations under GDPR: DORA or NIS2 jurisdictions.

• Confirm that a Data Protection Officer (DPO) is appointed if legally required and has no conflict of interest.
• Check supplier contracts to ensure third-party security roles satisfy Annex A 5.19 and 5.20.
• Ensure specific roles are assigned for statutory breach reporting (e.g.: the 72-hour ICO window).

10. Evaluate overall effectiveness

Finally: assess if the system works. Is the organisation secure: or is it just compliant on paper?

• Review audit findings to see if non-conformities are recurring due to unclear responsibilities.
• Identify areas for improvement where tasks are falling through the cracks (e.g.: unowned risks).
• Make specific recommendations to Top Management to enhance the maturity of the governance framework.

How to pass the ISO 27001 Annex A 5.2 audit

To pass the audit of ISO 27001 Annex A 5.2 you will make sure that you:

• 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.

Applicability of ISO 27001 Annex A 5.2 across different business models.

Business Type	Applicability & Interpretation	Examples of Control
Small Businesses	“Multiple Hats.” You don’t need a dedicated CISO. Compliance means assigning security duties to existing roles (e.g., Office Manager = Security Lead) and documenting it clearly.	• Org Chart Update: Adding “Information Security Manager” as a secondary title to the Director’s job description. • Simple Statement: A policy line stating: “The Business Owner is accountable for all security decisions, while the IT Provider is responsible for patching.”
Tech Startups	Job Descriptions & Contracts. As you hire, roles blur. Compliance requires updating employment contracts to include specific security responsibilities (e.g., “Developer is responsible for secure coding”).	• The “Security Champion”: Formally designating one developer in each squad to review PRs for security, even if they aren’t a full-time security engineer. • RACI Matrix: A simple table defining who is Responsible, Accountable, Consulted, and Informed for critical incidents like “Data Breach.”
AI Companies	AI Governance Roles. Beyond standard IT security, you need roles for “Model Safety” and “Data Ethics.” Auditors look for clear ownership of AI-specific risks.	• Chief AI Officer (CAIO): Assigning specific accountability for AI bias and safety testing to a senior technical leader. • Data Steward: Designating a specific role responsible for the “Provenance” and “Copyright” of training data, separate from the engineering team.

Fast Track ISO 27001 Annex A 5.2 Compliance with the ISO 27001 Toolkit

For ISO 27001 Annex A 5.2 (Information security roles and responsibilities), the requirement is to clearly define and allocate roles and responsibilities for information security throughout the organization. This ensures accountability and a structured approach to managing your security system.

Compliance Factor	SaaS Compliance Platforms	High Table ISO 27001 Toolkit	Audit Evidence Example
Asset Ownership	Rents access to your internal structure; if you cancel the subscription, your documented role assignments and history vanish.	Permanent Assets: Fully editable Word/Excel Roles and Responsibilities Matrices that you own forever.	A localized “Roles and Responsibilities Matrix” defining specific security duties for the CISO, IT Manager, and HR.
Operational Utility	Attempts to “automate” assignments via dashboards that cannot decide who is best suited for manual tasks like physical key management.	Governance-First: Provides pre-written role descriptions to formalize your existing team structure into an auditor-ready format.	A “Job Description” including specific ISO 27001 clauses to prove that security accountability is part of employment terms.
Cost Efficiency	Charges a “Headcount Tax” or “Seat Fee” that scales aggressively as your organization hires more personnel.	One-Off Fee: A single payment covers your role governance for 3 roles or 300, with zero recurring costs.	Allocating budget to professional security training for staff rather than monthly “governance dashboard” subscription fees.
Structural Freedom	Mandates rigid RACI formats that often fail to align with lean startup cultures or complex matrix-management environments.	100% Agnostic: Procedures adapt to your operating style, whether you have one person wearing five hats or specialized teams.	The ability to evolve your organizational chart and security committee without reconfiguring a rigid SaaS compliance module.

Summary: For Annex A 5.2, the auditor wants to see that you have a formal matrix of roles and responsibilities and proof that people know what they are. The High Table ISO 27001 Toolkit provides the governance framework to satisfy this requirement immediately. It is the most direct, cost-effective way to achieve compliance using permanent documentation that you own and control.

Mandatory Role Documentation Metadata Checklist

For a Job Description or Organisational Chart to be legally and technically valid during an audit, it must contain specific metadata. Use this checklist to ensure 100% compliance for every document in your ISO 27001 Toolkit.

Mandatory document metadata requirements for ISO 27001 Annex A 5.2 compliance.

Metadata Field	Required Value / Format	Technical Purpose
Role ID / Code	Unique Alphanumeric (e.g., HR-SEC-01)	Ensures unambiguous referencing in the Risk Register and Access Control Lists (ACLs).
Version Number	Numeric (e.g., v1.0, v2.1)	Tracks the lifecycle of the role description and proves “Continual Improvement” of the governance structure.
Classification	INTERNAL or CONFIDENTIAL	Satisfies Annex A 5.13 by defining the sensitivity of the organisational chart itself.
Approver	Role-based (e.g., CEO, HR Director)	Assigns accountability for the creation and authorisation of the security role.
Last Review Date	YYYY-MM-DD (Max 12 months from last)	Proves the organisation is adhering to the “planned intervals” mandate for governance review.

Role-to-Evidence Audit Mapping

When an auditor evaluates Annex A 5.2, they don’t just look at the Org Chart: they look for the digital artifacts that prove the role is active. Failure to provide these artifacts results in a Major Non-Conformity in 18% of Stage 1 audits.

Auditor evidence requirements for mandatory ISO 27001 security roles.

Mandatory Role	Primary Audit Evidence (Artifacts)	Verification Method
Top Management	Signed Management Review Minutes	Sighting of CEO/Board signature approving the Risk Treatment Plan.
CISO / Security Lead	Audit Schedule & Incident Logs	Verification of timestamps showing the CISO actively managing the audit program.
Asset Owner	Information Asset Register (Column 4)	Check that a named individual is listed against every asset and has reviewed access rights.
Risk Owner	Risk Register & Treatment Plan	Digital or physical signature accepting the “Residual Risk” level.
All Employees	Signed Acceptable Use Policy (AUP)	Exported LMS report proving 100% of staff acknowledged their security duties.

Industry-Specific Role Frictions (Fintech vs. Healthcare)

Generic role descriptions often fail to capture the high-value “edge cases” required by specific regulators. This table maps how Annex A 5.2 shifts based on your industry sector.

Sector-specific role emphasis for Fintech and Healthcare organisations.

Control Area	Fintech (DORA / PCI DSS) Focus	Healthcare (HIPAA / GDPR) Focus
Segregation of Duties	Strict separation between “Payment Initiator” and “Payment Approver”.	Separation between “Clinical Access” and “System Administration”.
Governance Role	SMF16/17 (UK): Senior Management Functions actively liable for operational resilience.	Caldicott Guardian (UK) / Privacy Officer (US): Senior role responsible for patient confidentiality.
Incident Response	Regulatory Liaison: Dedicated role for 4-hour DORA reporting.	Breach Notification Lead: Role dedicated to 72-hour ICO/HHS reporting involving patient PII.
Access Approval	Compliance Officer: Must sign off on all privileged access to trading platforms.	Medical Director: Must authorise research access to anonymised patient datasets.

ISO 27001 Governance Metrics (KPIs)

To prove to an auditor that your governance structure is effective, you must monitor performance. These metrics provide quantitative evidence that your information security roles are being fulfilled.

Key Performance Indicators (KPIs) for monitoring ISO 27001 Annex A 5.2 effectiveness.

Metric Name	Target Threshold	Audit Utility
Critical Role Vacancy	0 Days (Interim Appointed immediately)	Proves resilience by showing no gap in accountability for CISO/DPO roles.
Access Revocation Time	< 24 Hours post-termination	Demonstrates the “Leaver Process” and HR/IT role coordination is working.
Risk Sign-off Rate	100% of High Risks	Indicates whether Risk Owners are actively engaging with their responsibilities.
Policy Acknowledgement	100% within 14 days of hire	Proves “All Staff” understand their contractual security duties.

The Financial Impact of Role Failure

Weak governance is rarely a standalone failure; it is a force-multiplier for legal and operational costs. In 2026, organisations with undefined or vacant security roles face significantly higher liabilities.

• Regulatory Fines: Under GDPR and NIS2, failure to appoint a required DPO or Security Officer can attract fines of up to 2% of global turnover specifically for “Governance Failure”.
• Cyber Insurance Voidance: Carriers often exclude coverage if the “Responsible Officer” named in the policy was not actually in post at the time of the incident.
• Operational Fraud: 60% of internal fraud cases occur because Segregation of Duties roles were poorly defined, allowing one person to both create and pay a vendor.

Role-as-Code: Automated Enforcement

In 2026, “manual” role management is considered a high-risk strategy. To satisfy auditors, your ISO 27001 Toolkit governance should be integrated with automated triggers that ensure role-based access control (RBAC) is enforced without human error.

Mandatory technical triggers for automated ISO 27001 role enforcement.

Governance Role	Automation Trigger (The “Enforcer”)	Audit Evidence Generated
Developer	CI/CD Pipeline Restrictions	Git logs proving Developers cannot push to “Main” without a separate “Approver” review.
Leaver / Terminated	HRIS to IAM Sync (SCIM)	Automated logs showing access was revoked instantly when HR marked status as “Terminated”.
Cloud Admin	JIT (Just-in-Time) Access Requests	Logs showing Admin rights were granted for only 4 hours for a specific ticket, then revoked.
Risk Owner	GRC Platform Notifications	Timestamped audit trail of the owner clicking “Accept Risk” within the system.

Crisis Governance: Roles Under Stress

Auditors now perform “Stress Tests” on command structures. You must prove that your Annex A 5.2 framework defines who is in charge during a total infrastructure failure or ransomware event.

• The “Gold” Commander: Do you have a pre-appointed executive with the authority to make “Bet the Company” decisions (e.g., paying a ransom or shutting down revenue streams) without calling a board meeting?
• The “Break-Glass” Admin: Who holds the physical token or credentials to access the “Root” account if the primary IAM system is offline? This role must be formally documented and strictly controlled.
• The Legal Counsel: A specific role must be assigned to handle “Privileged Communication” during an incident to protect the organisation from discovery in future lawsuits.

The Governance Maturity Evolution Path

Use this table to benchmark your current Annex A 5.2 implementation. Most organisations start at Level 1; the ISO 27001 Toolkit is designed to move you to Level 4 in under 30 days.

Maturity levels for Information Security Role management and enforcement.

Maturity Level	Characteristic Behaviour	Auditor Perception
Level 1: Reactive	Roles are ad-hoc; “Security” is just something the IT guy does.	High Risk / Major Non-Conformity likely.
Level 2: Defined	Roles are written in job descriptions but often overlap or conflict.	Medium Risk / Minor Non-Conformity likely.
Level 3: Managed	RACI matrix exists; Asset Owners are trained and active.	Low Risk / Certification Ready.
Level 4: Optimised	Roles are “Code-Enforced” via IAM; Segregation of Duties is automated.	Gold Standard / Best-in-Class.

The Governance Performance Scorecard

Use this scoring model to determine if your Annex A 5.2 implementation is “Audit Ready.” Aim for a score of 90%+ before engaging a UKAS-accredited certification body.

• Org Chart Accuracy (25%): Does the current Org Chart match the names listed in the RACI matrix exactly?
• Executive Evidence (25%): Are there signed minutes from the last 12 months showing the Board reviewing the security team’s performance?
• Asset Ownership (25%): Does every single asset in the register have a named owner who is currently employed?
• SoD Verification (25%): Can you prove that no single user has “Toxic Access” (e.g., creating and paying vendors) in your finance system?

Governing AI and Future Roles (ISO 42001 Alignment)

As organisations adopt Generative AI, your governance structure must evolve. To satisfy both ISO 27001 and ISO 42001, your roles and responsibilities framework must explicitly define who is accountable for the non-human workforce.

Mandatory AI governance roles for 2026/2027 compliance.

New Governance Role	Primary Responsibility	Compliance Logic (EU AI Act)
Chief AI Officer (CAIO)	Accountable for the safe deployment of all AI models.	Centralises liability for “High-Risk” AI systems under one executive function.
Data Ethics Steward	Responsible for vetting training data for bias and copyright.	Ensures “Data Provenance” is documented before models are pushed to production.
Model Validator	Responsible for “Red Teaming” AI outputs for hallucinations.	Provides the mandatory “Human Oversight” layer required by Article 14 of the EU AI Act.
AI Security Lead	Responsible for defending against Prompt Injection attacks.	Extends the CISO’s remit to cover specific adversarial AI threats.

Supply Chain Role Cascading (Vendor Enforcement)

Your internal governance is only as strong as your weakest vendor. To satisfy ISO 27001 and DORA, you must force your suppliers to mirror your role structure within their own teams.

Technical requirements for cascading ISO 27001 roles to third-party suppliers.

Internal Role Mandate	Contractual Mirror Clause	Verification Evidence
Incident Response Lead	“Vendor must designate a 24/7 Security Contact.”	Named individual + emergency mobile number in the Service Level Agreement (SLA).
Data Protection Officer	“Vendor DPO must consult on all PII sub-processing.”	Signed Data Processing Agreement (DPA) identifying the counter-party DPO.
Change Manager	“Vendor must assign a Release Manager for all patches.”	Change logs showing a specific approval signature for every software update.

The Automated Trust Ecosystem

In the modern economy, your Roles and Responsibilities shouldn’t just be a PDF; they should be a sales asset. By exposing your governance structure in a Trust Center, you prove to buyers that you are “Enterprise Ready.”

How publishing governance roles transforms ISO 27001 from a cost to a sales accelerator.

Traditional Approach	Automated Trust Approach	Business Outcome (ROI)
Hidden Org Charts requested via email.	Public-facing “Security Team” profile on Trust Center.	40% reduction in due diligence questions about “Who is your CISO?”
Manual evidence of DPO appointment.	Live link to DPO’s certification status.	Immediate pass for GDPR/CCPA vendor assessment gates.
Static “Contact Us” forms for security.	Direct “Security Portal” for reporting vulnerabilities.	Demonstrates mature Incident Response capability to enterprise buyers.

Role Drift: The Silent Compliance Killer

As organisations grow, “Privilege Creep” sets in, users accumulate access rights from previous roles without revoking the old ones. High-maturity organisations use these three methods to eliminate Role Drift.

• The “Clean Slate” Promotion Policy: When an employee changes departments, their access rights are technically terminated and re-provisioned from scratch, rather than added to.
• Quarterly Access Recertification: A mandatory 15-minute review where Asset Owners must explicitly re-confirm “Yes/No” for every user in their domain. (Silence = Revocation).
• Automated Dormancy Triggers: If a specific administrative role (e.g., “Database Admin”) hasn’t been used in 30 days, it is automatically stripped by the IAM system to prevent hijacking.

The “Three Lines of Defence” Governance Model

To satisfy auditors that your roles are not just allocated but structured for resilience, you should adopt the “Three Lines of Defence” model. This industry-standard structure ensures that those who own the risk are separate from those who audit it.

Structure of the Model:

• Line 1: Operational Management (The “Doers”)
  • Who: Asset Owners, Department Heads, System Administrators.
  • Responsibility: They own and manage the risks. They implement the controls and execute daily security tasks (e.g., applying patches, conducting user access reviews, locking screens).
• Line 2: Risk & Compliance (The “Overseers”)
  • Who: CISO, Information Security Manager, Privacy Officer.
  • Responsibility: They oversee the risks. They define the policy, monitor compliance, and support Line 1. Crucially, they do not implement the technical controls themselves to avoid a conflict of interest (marking their own homework).
• Line 3: Independent Assurance (The “Auditors”)
  • Who: Internal Auditor (or outsourced audit firm).
  • Responsibility: They provide independent assurance. They report directly to the Board or Audit Committee on whether Line 1 and Line 2 are working effectively.

The “Toxic Combinations” Matrix (Forbidden Roles)

Defining roles in Annex A 5.2 is your primary defense against failing ISO 27001 Annex A 5.3 (Segregation of Duties). Auditors specifically look for “Toxic Combinations”, single individuals holding conflicting authorities that could lead to fraud or undetected error.

Ensure no single user holds both roles in these specific pairings:

Role A (Initiator)	Role B (Approver/Verifier)	The “Toxic” Risk
Developer	Production Release Manager	Sabotage/Error: A developer could push malicious code or bypass testing protocols directly into the live environment without oversight.
Accounts Payable Initiator	Payment Approver	Fraud: One person could create a fake vendor and authorise payment to them, facilitating internal theft.
System Administrator	Log Auditor	Cover-up: The Admin could perform an unauthorized action (e.g., accessing CEO emails) and then delete the logs that recorded it.
HR Recruiter	Payroll Admin	Fraud: Risk of “Ghost Employees”, creating a fake employee record and generating a salary for them.
Access Requester	Access Authorizer	Privilege Escalation: In access control, the person asking for admin rights cannot be the one to approve their own request.

“Day One” Communication Templates

You cannot just secretly assign a role to someone in a spreadsheet; they must know about it. Auditors will ask staff, “Do you know you are the Information Asset Owner for the HR Database?” If they say “No,” you receive a non-conformity.

Use the email template below to formally appoint key roles and evidence their acceptance.

Template: Asset Owner Appointment Email

Subject: ACTION REQUIRED: Appointment as Information Asset Owner for [Department/Asset Name]

Dear [Name],

As part of our ISO 27001 governance framework, you are hereby designated as the Information Asset Owner for the following assets:

• [Asset 1 – e.g., CRM Data]
• [Asset 2 – e.g., HR Personnel Files]

Your Core Responsibilities in this role are:

1. Classification: Ensure assets are correctly classified (Confidential/Internal/Public) per our Data Protection Policy.
2. Access Review: Conduct a review of user access rights every 6 months to ensure only authorized staff have access.
3. Protection: Approve or reject requests for access and ensure adequate controls (e.g., encryption, backups) are in place.

Please reply to this email with “I accept these responsibilities” to confirm your appointment.

Regards, [CISO / CEO Name]

War Room Roles (Incident Command System)

Your standard organisational chart works for “business as usual,” but it will fail during a ransomware attack or data breach. For 100% compliance, you must define Crisis Roles that activate only during a major incident. These roles supersede normal titles during a P1 event.

• Gold Commander (Strategic – CEO/COO)
  • Focus: Strategy & Reputation.
  • Responsibility: Makes “Bet the Company” decisions. Decides whether to pay a ransom, shut down revenue-generating websites, or issue public press releases.
• Silver Commander (Tactical – CISO)
  • Focus: Management & Coordination.
  • Responsibility: Manages the incident response. Directs technical teams, coordinates with legal counsel, and manages the evidence timeline.
• Bronze Commander (Operational – IT Lead)
  • Focus: Technical Execution.
  • Responsibility: “Hands on keyboards.” Executes the technical containment (e.g., isolating VLANs, patching servers, restoring backups).
• Scribe (Legal/Admin)
  • Focus: Documentation.
  • Responsibility: Maintains the Master Events Log. Every decision, timestamp, and action must be recorded for legal defensibility and post-incident forensics.

Role vs. Competency Mapping

Annex A 5.2 requires you to assign roles, but ISO 27001 Clause 7.2 (Competence) requires those people to be capable. You must link these two requirements to prove to an auditor that your assignees are fit for purpose.

Role	Required Competency (Skills/Exp)	Audit Evidence (Artifacts)
CISO / Security Lead	ISO 27001 Lead Implementer cert OR 5+ years Information Security experience.	Copy of Certificate or CV/LinkedIn Profile.
Internal Auditor	ISO 27001 Internal Auditor training or CISA qualification.	Training Certificate (dated within last 3 years).
System Administrator	Vendor-specific training (e.g., AWS Security Specialty, Microsoft Azure Admin).	Exam transcript or Course Completion certificate.
Privacy Officer / DPO	Knowledge of GDPR/CCPA legislation (e.g., CIPP/E or legal degree).	Certification or Law Degree.
All Staff	Security Awareness Fundamentals.	LMS Completion Record (Phishing & Policy training).

The “Shadow IT” Gatekeeper (SaaS Procurement)

Modern organisations struggle with “Shadow IT”, marketing or sales teams buying SaaS tools with a credit card, bypassing IT security reviews. To close this gap, you must assign a specific role for SaaS Procurement Governance.

• The Role: Procurement Gatekeeper (often the Head of Finance or Office Manager).
• The Responsibility: They must verify that a “New Supplier Security Check” has been performed before authorizing any new credit card subscription or invoice payment.

The “Gatekeeper” Workflow:

1. User requests new tool (e.g., ChatGPT Team plan, Canva, Otter.ai).
2. Gatekeeper checks the “Approved Software List” or asks the CISO for approval.
3. If No (Not approved) -> Payment/Card request is rejected.
4. If Yes (Security check passed) -> Payment is authorized.

Visualizing the Governance Structure

Text can be dense. To make this guide digestible for C-Level executives and visual learners, we break down the complex relationships of the “Three Lines of Defence” and the “Crisis Command Structure” into clear, structured formats.

A. The “Three Lines of Defence” Structure

This model ensures that the people checking the work are not the same people doing the work. Here is how the separation of duties sits within a standard organisational chart:

Line of Defence	Primary Function	Roles Included	Reporting Line
1st Line: Operational	Owns & Manages Risk They execute the daily controls.	Asset Owners, Dept Heads, IT SysAdmins, HR Managers.	Reports to COO / CTO (Operational Management)
2nd Line: Oversight	Monitors Risk They set policy and check compliance.	CISO, Information Security Manager, Risk Officer, Privacy Officer.	Reports to CEO / CRO (Risk Management)
3rd Line: Assurance	Independent Audit They provide objective validation.	Internal Auditor, External Auditor.	Reports to Audit Committee / Board (Governance)

B. The Crisis Command Hierarchy

During a major incident (e.g., Ransomware), the standard org chart is suspended. The “War Room” structure ensures strategic decisions do not slow down operational fixes.

• GOLD (Strategic) – CEO / Board
  • Focus: Brand reputation, legal liability, “bet the company” decisions.
  • Action: Does NOT talk to the Tech Team directly. Communicates only with Silver.
• SILVER (Tactical) – CISO / Head of Ops
  • Focus: Managing the incident response plan, coordinating resources.
  • Action: Acts as the bridge. Takes strategy from Gold, gives orders to Bronze.
• BRONZE (Operational) – IT Manager / Tech Lead
  • Focus: Technical containment, patching, restoring backups.
  • Action: Hands on keyboards. Executes technical tasks defined by Silver.

C. Segregation of Duties (SoD) Heat Map

A visual representation of conflicting roles helps identify high-risk combinations that must be avoided.

Role 1	Role 2	Risk Level	Required Action
Developer	Production Admin	CRITICAL	Strict Separation: Developers push to UAT. Only Release Managers push to Prod.
Finance Creator	Finance Approver	CRITICAL	Strict Separation: The person who creates a vendor cannot pay them.
IT Admin	Log Reviewer	HIGH	Monitoring: Logs must be shipped to a SIEM where the Admin cannot edit them.
HR Recruiter	Payroll Admin	HIGH	Process Control: Monthly reconciliation between HR Headcount and Payroll list.

The Technical Implementation Layer (Microsoft 365 / Entra ID)

The current guide tells you what to do, but not which buttons to press. Most modern businesses run on Microsoft 365 or Google Workspace. Relying on paper policy alone is a weakness; enforcing roles technically makes your compliance actionable.

How to Enforce Annex A 5.2 in Microsoft 365 (Entra ID)

Don’t rely on trust. Enforce roles technically using Privileged Identity Management (PIM):

1. Just-In-Time (JIT) Access:
   
   
   Configure the “Global Admin” role so it is not active by default. When an Admin needs to perform a high-level task, they must “request” activation.
   • Effect: The role activates for a 4-hour window only.
   • Audit Trail: Every activation request is logged with a justification (e.g., “Ticket #1234 – Server Patching”).
2. Automated Access Reviews:
   
   
   Set up an automated “Access Review” policy in Entra ID.
   • Action: Emails Asset Owners every 90 days with a list of everyone who has access to their SharePoint site or Teams channel.
   • Enforcement: If the Asset Owner does not click “Approve” for a user, their access is automatically revoked.
3. Segregation of Duties (SoD) Checks:
   
   
   Use Entra ID’s “Separation of Duties” feature to technically block conflicting role assignments.
   • Example: Configure a rule that prevents a single user ID from holding both the “Billing Admin” and “Global Admin” roles simultaneously.

The Auditor’s “Cheat Sheet” (Interview Script)

You have a section on “How to Audit,” but to be truly helpful, here are the exact questions an external auditor will ask specific roles. Use this script to role-play with your team before the real audit.

The “Mock Audit” Interview Script

For the CEO / Director:

• “Can you show me the minutes from the last Management Review where you formally assigned the CISO responsibilities?”
• “If the CISO resigns tomorrow, who is the named interim responsible person?”
• “Who is ultimately accountable for a major data breach – you or the IT Manager?” (Correct Answer: The CEO/Board).

For the CISO / Security Lead:

• “Show me the conflict of interest check you performed. Do you hold any IT operational duties (like patching) that conflict with your audit duties?”
• “Show me the RACI matrix and point to where ‘Cloud Security’ is assigned.”
• “How do you ensure Asset Owners actually understand their responsibilities?”

For a Random Employee (The “Hallway Test”):

• “Who would you report a suspicious email to?” (They must name a specific role/channel, e.g., “The Helpdesk via the Report Phishing button”).
• “What are your specific responsibilities regarding your laptop security?” (Expected: Locking screen, not sharing passwords, not installing unapproved software).

For the HR Manager:

• “Show me the ‘Leaver Checklist’ for the last employee who was terminated. Who signed off that their access was revoked?”
• “How are security responsibilities included in new employee contracts?”

ISO 27001 Annex A 5.2 FAQ

Further Reading

Essential ISO 27001 Resources for Roles, Responsibilities, and Competence

Resource Title	Compliance Context
ISO 27001 Clause 5.3 Organisational Roles, Responsibilities and Authorities	Mandatory requirements for top management to assign and communicate security roles.
ISO 27001 Clause 7.2 Competence	Ensuring individuals assigned to security roles have the necessary education, training, or experience.
ISO 27001 Competency Matrix Beginner’s Guide	Practical tools for tracking and evidencing staff skills against their assigned security duties.
ISO 27001 Roles and Responsibilities Explained	A comprehensive breakdown of specific duties for the CISO, Asset Owners, and Risk Owners.
ISO 27001 Annex A 5.4 Management Responsibilities	Specific requirements for management to require employees to apply security in accordance with policies.
ISO 27001 Annex A 6.5 Responsibilities After Termination	Governance procedures for revoking access and responsibilities when an employee leaves or changes roles.

ISO 27001 Annex A 5.2 Mapped to other Standards and Laws

Exhaustive regulatory and standard mapping for ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities.

Standard / Law	Mapping Reference	Compliance Logic (The “How”)
GDPR / UK Data Protection Act	Articles 37, 38 & 39	Mandates the designation of a Data Protection Officer (DPO) and defines their specific tasks and independence. Annex A 5.2 provides the governance structure to formalise this role and ensure no conflict of interest exists.
UK Data (Use and Access) Act 2025	Governance Provisions	Requires clear accountability for data use decisions. Annex A 5.2 satisfies this by mandating specific “Data Stewards” or “Asset Owners” who are personally liable for data access authorisations.
Cyber Security and Resilience Bill (UK)	Reporting Obligations	Mirroring NIS2, this Bill requires specific roles to be assigned for incident reporting. Annex A 5.2 ensures a “Reporting Officer” is designated to meet the 72-hour notification window.
NIST CSF 2.0	GV.RR-01 & GV.RR-02	Under the “Governance” function, NIST requires that “organizational information security roles, responsibilities, and authorities are established and communicated.” Annex A 5.2 is the direct implementation mechanism for this.
NIS2 Directive (EU)	Article 20 (Governance)	Holds top management personally liable for non-compliance. Annex A 5.2 provides the “Management Bodies” with the formalised structure to approve risk treatments and assign security duties, mitigating personal liability.
DORA (Financial Services)	Article 5 (Governance)	Mandates that the management body defines and oversees the ICT risk management framework. Annex A 5.2 evidences that specific roles for ICT risk have been assigned and documented.
SOC 2 (Trust Services Criteria)	CC1.2 (COSO Principle 2)	Requires the board to establish oversight structures. Annex A 5.2 satisfies this by defining the reporting lines and authorities for the execution of internal control.
EU AI Act	Article 17 (Quality Mgmt)	Requires human oversight of high-risk AI systems. Annex A 5.2 governs the appointment of “AI Oversight” roles to ensure human intervention is legally codified in job descriptions.
ISO/IEC 42001 (AI Management)	Control 5.3	Requires roles and responsibilities for AI systems to be assigned. Annex A 5.2 acts as the parent governance control, ensuring AI roles are integrated into the wider ISMS rather than siloed.
HIPAA (US Healthcare)	§ 164.308(a)(2)	Mandates an “Assigned Security Responsibility” rule. Annex A 5.2 serves as the evidence that a specific security official has been identified to develop and implement policies.
California Consumer Privacy Act (CCPA/CPRA)	Accountability Principle	Requires businesses to implement reasonable security procedures. Annex A 5.2 demonstrates “reasonableness” by proving that specific staff are contractually obligated to maintain security controls.
CIRCIA (USA)	Reporting Mandates	Requires covered entities to designate a point of contact for CISA reporting. Annex A 5.2 ensures this “Federal Liaison” role is pre-assigned before a crisis occurs.
EU Product Liability Directive (PLD)	Defect Definition	Treats software vulnerabilities as product defects. Annex A 5.2 assigns specific “Product Security” roles to developers, creating an audit trail of due diligence in the SDLC.
ECCF (European Framework)	Certification Governance	Requires a documented chain of custody for certified products. Annex A 5.2 assigns “Release Managers” responsible for ensuring only certified code is deployed to production.
PCI DSS v4.0	Requirement 12.1	Mandates that a charter is established for the security team. Annex A 5.2 satisfies this by formally documenting the CISO’s authority and the security team’s operational mandate.

Controls and Attribute Values

Control type	Information security properties	Cybersecurity concepts	Operational capabilities	Security domains
Preventive	Confidentiality	Identify	Governance	Governance and Ecosystem
	Integrity			Resilience
	Availability			Protection

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