ISO 27001:2022 Annex A 5.26 Response to information security incidents for AI Companies

ISO 27001 Annex A 5.26 is a security control that requires organizations to establish and maintain documented procedures for responding to information security incidents. The primary implementation requirement involves defining technical containment playbooks, providing the business benefit of minimized operational downtime and rapid mitigation of AI-specific threats like model poisoning.

As an AI company, your primary focus is on innovation, developing sophisticated algorithms and leveraging vast datasets. 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 comes in.

Annex A 5.24 acts as your strategic playbook. 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, ensuring you aren’t figuring out who has the root password while the server is melting down.

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 house is on fire 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… processes, roles and responsibilities.”	Don’t wing it. 1. Pre-Approval: Decide now who is allowed to shut down the production model. Don’t wait for a committee meeting when the AI is hallucinating PII. 2. Call Trees: Have a list of phone numbers that works when Slack is down. 3. Templates: Have the “We are investigating a breach” email draft ready to go.

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The Business Case: Why This Actually Matters for AI Companies

Why should a founder care about an “Incident Response Plan” (IRP)? Because your preparation determines your survival rate.

The Sales Angle

Enterprise clients will ask: “Do you have a documented Incident Response Plan?” 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 pre-assigned roles for Legal, Comms, and Engineering,” you win the deal. A 5.24 is your proof of resilience.

The Risk Angle

The “Ransomware” Freeze: Hackers encrypt your training data. If you haven’t planned for this, you will panic, pay the ransom (bad idea), or lose weeks trying to restore from backups you never tested. Planning (A 5.24) ensures you know exactly where the backups are and how to restore them before the clock runs out.

DORA, NIS2 and AI Regulation: The Preparedness Mandate

Regulators demand evidence that you have thought about the worst-case scenario.

• DORA (Article 17): Financial entities must have a comprehensive ICT business continuity policy. You must plan for “communication plans” during a crisis. If you don’t have the press release drafted before the breach, you are non-compliant.
• NIS2 Directive: Mandates “incident handling” procedures. You must have a plan that defines what counts as a “Significant Incident” so you can meet the 24-hour Early Warning deadline.
• EU AI Act: Providers of High-Risk AI systems must have a “Quality Management System” that includes post-market monitoring. Your plan must include specific triggers for when an AI error (e.g., bias) becomes a reportable incident.

ISO 27001 Toolkit vs SaaS Platforms: The Planning 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
Availability	Offline Access. A Word/PDF document works when the internet is down. If you are under DDoS attack, you can still read your plan.	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 Playbook. You define the specific “Runbooks” for your AI stack (e.g., “Rotate Hugging Face Keys”).	Generic Workflows. Platforms force you into standard IT workflows that don’t account for AI-specific issues like Model Drift or Inference Latency attacks.
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 often just a ticketing system, not a planning tool.

The Three Pillars of Incident Management Planning

Effective compliance with Annex A 5.24 is not about creating a single document that gathers dust on a shelf; it’s about building a complete operational framework.

Establishing Clear Roles and Responsibilities

In a real incident, ambiguity is your greatest enemy. Knowing exactly who does what before a crisis hits is critical.

Role	Responsibility	Typical Owner
Incident Commander	Leads the response. Has authority to make “The Call” (e.g., shutdown).	CTO / VP Eng
Lead Investigator	Technical forensics. Log analysis. “How did they get in?”	Senior DevOps / SecEng
Scribe	Documents every action. Timestamps are legal evidence.	Ops Manager / PM
Comms Lead	Talks to customers and regulators. Prevents PR disasters.	CEO / Legal

Developing Your Incident Management Procedures

Your incident management procedures are the official playbook. A comprehensive process must address:

• Preparation: Setting up the war room (Slack channel) and tools (forensic backups).
• Triage: Determining severity (P1 vs P3).
• Containment: How to isolate the threat (e.g., revoke API keys).
• Recovery: Restoring from backups and verifying integrity.

Creating Effective Reporting Mechanisms

Clear and consistent reporting is the glue that holds the framework together. Establish a clear “Emergency Contact” method (e.g., a specific email or Slack command) so anyone in the company can raise the alarm.

The Evidence Locker: What the Auditor Needs to See

When the audit comes, you need proof of planning. Prepare these artifacts:

• Incident Response Plan (PDF): The master document. Version controlled and approved by management.
• Call Tree / Contact List (PDF): Up-to-date numbers for key staff, legal counsel, and the Data Protection Authority.
• Reporting Templates (Word/Jira): The blank forms you would use to log an incident. Auditors want to see that you are ready to record detail.
• Drill Records (Tabletop Exercise): Evidence that you tested the plan. “On [Date], we simulated a ransomware attack.”

Common Pitfalls & Auditor Traps

Here are the top 3 ways AI companies fail this control:

• 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 “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, likely a Minor Incident or Near Miss).
• The “Outdated” Plan: Your call tree lists employees who left 6 months ago. This proves you don’t review the plan.

Handling Exceptions: The “Break Glass” Protocol

Sometimes you need to shut down the entire product to save the data. You need a protocol for this extreme measure.

The “Total Lockdown” Workflow:

• Trigger: Confirmed active intruder in the production environment.
• Authority: Incident Commander + CEO approval required.
• Action: Sever external connections (API Gateway / Load Balancer) to stop data exfiltration.
• Log: Retroactive timeline created once containment is achieved.

The Process Layer: “The Standard Operating Procedure (SOP)”

How to operationalise A 5.24 using your existing stack (PagerDuty, Slack, Linear).

• Step 1: Planning (Manual). Create the Incident Response Plan using the Hightable.io Toolkit. Map roles to specific people.
• Step 2: Configuration (Automated). Set up PagerDuty services. Create a specific Slack channel (#incident-war-room) that triggers when an incident is declared.
• Step 3: Training (Manual). Walk the engineering team through the “Runbooks” (e.g., How to rotate AWS keys).
• Step 4: Testing (Manual). Conduct a quarterly “Tabletop Exercise” where you pretend a breach happened and test if the team knows what to do.

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 5.26 for AI Companies FAQ

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