ISO 27001 Annex A 5.24 is a security control that mandates organizations to plan and prepare for managing incidents by defining processes and roles. For AI companies, this capability ensures the protection of proprietary models and builds a resilient framework to survive data breaches.
As an AI company, your primary focus is on innovation, developing sophisticated algorithms and leveraging vast datasets to push the boundaries of what is possible. However, in this dynamic environment, information security incidents are an unavoidable reality. For a business built on the integrity of its data and the reliability of its algorithms, the impact of an incident, from a poisoned training dataset to the theft of a proprietary algorithm, can be catastrophic. This is where ISO 27001 Annex A 5.24 Information security incident management planning and preparation provides the standard for building a resilient capability.
Annex A 5.24 requires your organisation to plan and prepare for managing information security incidents. In simple terms, it mandates that you define, establish, and communicate the necessary processes, roles, and responsibilities before an incident occurs. It turns potential chaos into a structured, manageable process.
Table of contents
- The “No-BS” Translation: Decoding the Requirement
- The Business Case: Why This Actually Matters for AI Companies
- DORA, NIS2 and AI Regulation: The Reporting Clock
- ISO 27001 Toolkit vs SaaS Platforms: The Playbook Trap
- The Three Pillars of Incident Management Planning
- The Evidence Locker: What the Auditor Needs to See
- Common Pitfalls & Auditor Traps
- Handling Exceptions: The “Break Glass” Protocol
- The Process Layer: “The Standard Operating Procedure (SOP)”
The “No-BS” Translation: Decoding the Requirement
Let’s strip away the consultant-speak. Annex A 5.24 is your “Oh Sh*t” Manual. It is the document you grab when the server is melting down and you can’t think straight.
| The Auditor’s View (ISO 27001) | The AI Company View (Reality) |
|---|---|
| “The organisation shall plan and prepare for managing information security incidents by defining, establishing and communicating information security incident management processes, roles and responsibilities.” | Don’t wing it. 1. Define “Incident”: Is a failed AWS build an incident? Is a leaked API key an incident? Decide now, not when Slack is exploding. 2. Assign Roles: Who wakes up at 3 AM? Who talks to Legal? Who has the root password? Write it down. 3. The Playbook: Have a checklist. Step 1: Isolate. Step 2: Investigate. |
The Business Case: Why This Actually Matters for AI Companies
Why should a founder care about an “Incident Response Plan” (IRP)? Because your reaction time determines your survival rate.
The Sales Angle
Enterprise clients will ask: “Do you have a documented Incident Response Plan and do you test it annually?” If your answer is “We figure it out as we go,” you are a liability. If your answer is “We have a tested IRP tailored for AI threats like model inversion and data poisoning, with a 1-hour SLA for critical triage,” you win the deal. A 5.24 is your proof of resilience.
The Risk Angle
The “Hallucination” Incident: Your customer service bot starts swearing at customers or leaking other users’ PII. This is an AI-specific incident. If you don’t have a plan to “kill” the model immediately, the reputational damage spreads every second you delay. A 5.24 ensures you have the “Kill Switch” procedure documented.
DORA, NIS2 and AI Regulation: The Reporting Clock
Regulators do not care about your excuses. They care about your reaction time.
- DORA (Article 17): Financial entities must report major ICT-related incidents. The initial notification often must happen within 4 hours of classification. You cannot meet a 4-hour deadline if you are still trying to find the phone number for the regulator.
- NIS2 Directive: Mandates an “Early Warning” within 24 hours to the CSIRT. A 5.24 requires you to have these reporting templates ready to go before the incident happens.
- EU AI Act: Providers of High-Risk AI systems must report “serious incidents” to the relevant market surveillance authority. Your IRP must specifically include a workflow for identifying AI-specific failures (e.g., bias affecting thousands of people).
ISO 27001 Toolkit vs SaaS Platforms: The Playbook Trap
SaaS platforms are great for logging tickets, but they are terrible at planning strategy. Here is why the ISO 27001 Toolkit is superior for Annex A 5.24.
| Feature | ISO 27001 Toolkit (Hightable.io) | Online SaaS Platform |
|---|---|---|
| The Plan | A Documented Playbook. A Word/PDF document that works offline. When your systems are down (ransomware), you can still read the plan on your phone. | Cloud-Dependent. If your SaaS platform is down (or part of the outage), you lose access to your Incident Response Plan. Irony at its finest. |
| Ownership | You Own the Logic. You define the severity levels (P1, P2, P3) that match your business. | Rigid Workflows. Platforms force you into their definition of an incident. “A laptop virus is not the same as a Model Leak,” but the tool treats them the same. |
| Simplicity | Call Lists. A simple table: “If X happens, call Y.” No login required. | Complex UI. In a crisis, nobody wants to navigate a complex dashboard to find the legal counsel’s phone number. |
| Cost | One-off fee. Pay once. Be prepared forever. | Monthly Subscription. You pay a premium for an “Incident Module” that is basically just a glorified ticketing system. |
The Three Pillars of Incident Management Planning
Effective compliance with Annex A 5.24 is not about creating a single document that gathers dust; it is about building a complete operational framework.
Establishing Clear Roles and Responsibilities
In a real incident, ambiguity is your enemy. Your goal is to replace panic with a pre-agreed process.
| Role | Responsibility | Typical Owner |
|---|---|---|
| Incident Manager | Leads the response. Makes the “Shutdown” call. | CTO / VP Engineering |
| Lead Investigator | Forensics. Log analysis. “How did they get in?” | Senior DevOps / SecEng |
| Scribe | Documents every action. Timestamps are legal evidence. | Product Manager / Ops |
| Comms Lead | Talks to customers and regulators. Prevents PR disasters. | CEO / Legal / Marketing |
Developing Your Incident Management Procedures
Your procedures are the playbook. A comprehensive process must address:
- Triage: Determining if an event is a “P3 Bug” or a “P0 Breach.”
- Containment: How to stop the bleeding (e.g., revoke API keys, isolate EC2 instances).
- Eradication: Removing the threat (e.g., wipe malware, patch vulnerability).
- Recovery: Restoring from backups and verifying integrity.
Creating Effective Reporting Mechanisms
Define how people report issues. Ideally, a “Security” button in Slack or a dedicated email address (security@yourcompany.com). If it’s hard to report, people will hide mistakes.
The Evidence Locker: What the Auditor Needs to See
When the audit comes, prepare these artifacts to prove you are ready:
- Incident Response Plan (PDF): The master document. Version controlled and approved by management.
- Contact List (Annex A 5.5): An up-to-date list of authorities, regulators, and key vendors (AWS support, Legal).
- Test Reports (Tabletop Exercise): Evidence that you practised the plan. “On [Date], we simulated a ransomware attack. Findings: We need faster backup restoration.”
- Reporting Forms (Templates): The blank forms (tickets/documents) you would use to log an incident.
Common Pitfalls & Auditor Traps
Here are the top 3 ways AI companies fail this control:
- The “Undefined” Incident: You haven’t defined what counts as an incident. The auditor asks: “Is a developer pushing a secret to a private repo an incident?” You hesitate. Fail. (Answer: Yes, it is a Near Miss or Minor Incident).
- The “Hero” Syndrome: Your plan relies on one person (the Founder/CTO) doing everything. If they are on a plane, the company dies. You need designated deputies.
- The “Outdated” Call Tree: Your contact list has phone numbers for employees who left 6 months ago. This proves you don’t review the plan.
Handling Exceptions: The “Break Glass” Protocol
Sometimes, the standard procedure is too slow. You need a “Kill Switch” for your AI.
The Model Kill Switch Workflow:
- Trigger: AI Model is generating harmful content or leaking PII at scale.
- Action: Engineering Lead authorizes immediate takedown of the inference API.
- Log: “Emergency Takedown” ticket created retroactively.
- Communication: Status page updated to “Maintenance” immediately.
The Process Layer: “The Standard Operating Procedure (SOP)”
How to operationalise A 5.24 using your existing stack (PagerDuty, Slack, Linear).
- Step 1: Detection (Automated/Manual): Datadog alert fires or Employee reports in #security-help.
- Step 2: Triage (Manual): On-call Engineer acknowledges via PagerDuty. Assesses severity (P1-P4).
- Step 3: Mobilisation (Automated): If P1, PagerDuty spins up a dedicated Slack channel (#incident-123) and invites the Incident Commander.
- Step 4: Containment (Manual): Team executes pre-planned runbooks (e.g., “Rotate AWS Keys”).
- Step 5: Post-Mortem (Manual): Incident is closed in Linear. A “Learning Review” meeting is scheduled within 48 hours to update the IRP.
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Implementing ISO 27001 Annex A 5.24 is not a bureaucratic exercise; it is a fundamental step in building a prepared and resilient business. The High Table ISO 27001 Toolkit provides the expert-developed structure, policies, and templates required to build your programme without reinventing the wheel.
ISO 27001 Annex A 5.24 for AI Companies FAQ
What is ISO 27001 Annex A 5.24 for AI companies?
ISO 27001 Annex A 5.24 requires AI companies to plan and prepare for information security incidents by establishing a formal response framework. For AI firms, this involves creating specific playbooks to handle 100% of high-risk scenarios, including prompt injection, model extraction, and training data poisoning.
Why is incident planning critical for AI firms?
Incident planning is critical because AI-specific threats can result in immediate loss of competitive advantage. Statistics show that organisations with a tested incident response plan (IRP) reduce the total cost of a data breach by up to 60%, ensuring rapid containment of adversarial attacks on machine learning pipelines.
What should an AI incident response plan include?
A compliant AI incident response plan (IRP) must include technical escalation paths and specialised recovery steps. Essential components for AI companies include: Detection Thresholds: Defining specific anomalies in LLM behavior or GPU usage that trigger an incident. Roles & Responsibilities: Assigning clear duties to ML engineers, legal teams, and DPOs for regulatory reporting. Communication Channels: Establishing secure contacts for external authorities as required by the EU AI Act. Model Forensics: Procedures for snapshotting model states and logs for post-incident root cause analysis.
How do AI firms test their incident preparation?
AI firms test preparation through “Red Teaming” and tabletop exercises. By simulating a 10:1 scale attack—such as a large-scale data exfiltration attempt—teams can validate their response times and ensure that 100% of staff understand the reporting procedures for suspected security events.
What evidence is required for Annex A 5.24 audits?
Auditors require documented proof of planning and readiness. Necessary evidence includes a formal Incident Management Policy, a tested Incident Response Plan containing AI playbooks, records of recent security simulation exercises, and a centralised contact list for 100% of critical internal and external stakeholders.
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