ISO 27001 Roles and Responsibilities: Annex A 5.2

Introduction

I am going to show you what ISO 27001 Annex A 5.2 Roles and Responsibilities is, what’s new, give you ISO 27001 templates, an ISO 27001 toolkit, show you examples, do a walkthrough and show you how to implement it.

I am Stuart Barker the ISO 27001 Ninja and using over 30 years experience on hundreds of ISO 27001 audits and ISO 27001 certifications I show you exactly what changed in the ISO 27001 update and exactly what you need to do for ISO 27001 certification.

ISO 27001 Roles and Responsibilities

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

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.

What is ISO 27001 Annex A 5.2?

ISO 27001 Annex A 5.2 Information Security Roles and Responsibilities is an ISO 27001 Annex A 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

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Implementation Guide

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

If you are resolutely dead set on going through the pain of this yourself you are going to need copies of the relevant standards for information security, about 1 week of your life dedicated to this and a lot, and I mean a lot, of patience.

You then need to work through policies, research organisational best practice, and work out exactly what roles you need. Then work out what responsibilities they should have. We fast tracked it in our template and can tell you it is a massive ball ache.

When you finally do 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.

ISO 27001 Roles and Responsibilities Template

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

Watch the Tutorial

In the video ISO 27001 Roles and Responsibilities Explained – ISO27001:2022 Annex A 5.2 show you how to implement it and how to pass the audit.

How to comply

To comply with ISO 27001 Annex A 5.2 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 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 the auditor will check

The audit is going to check a number of areas for compliance with ISO 27001 Annex A 5.2 ISO 27001 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 Mistakes People Make

In my experience, the top 3 mistakes people make for ISO 27001 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.

Implementation Checklist

Roles and Responsibilities ISO 27001 Annex A 5.2 Implementation Checklist:

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.

Audit Checklist

Roles and Responsibilities ISO 27001 Annex A 5.2 Audit Checklist:

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.

ISO 27001 Roles and Responsibilities FAQ

Controls and Attribute Values

Further Reading

ISO 27001 Organisational Roles, Responsibilities and Authorities: Clause 5.3

ISO 27001 Competence: Clause 7.2

ISO 27001 Competency Matrix Beginner’s Guide

ISO 27001 Roles and Responsibilities Explained

ISO 27001 Management Responsibilities: Annex A 5.4

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