Auditing ISO 27001 Annex A 5.5 Contact with Authorities ensures that an organization has established appropriate channels for regulatory reporting and incident notification. This process validates the Primary Implementation Requirement of maintaining maintained contact lists and defined trigger protocols for legal authorities. The Business Benefit mitigates legal risk and ensures rapid, compliant responses to security incidents or data breaches.
This technical verification tool is designed for lead auditors to establish the legitimacy of organisational external engagements. Use this checklist to validate compliance with ISO 27001 Annex A 5.5 (Contact with Authorities) by ensuring formalised channels exist for regulatory reporting and incident notification.
1. List of Relevant Regulatory Authorities Verified
Verification Criteria: A maintained register exists identifying all legal, regulatory, and supervisory bodies relevant to the organisation’s industry and jurisdiction.
Required Evidence: Legal and Regulatory Register or an “Authorities Contact List” within the ISMS documentation.
Pass/Fail Test: If the organisation cannot produce a list of specific authorities (e.g., ICO for UK GDPR, FCA for finance) relevant to their ISMS scope, mark as Non-Compliant.
2. Defined Trigger Points for Authority Notification Confirmed
Verification Criteria: Internal procedures explicitly define the specific security incidents or legal requirements that necessitate immediate contact with authorities.
Required Evidence: Incident Response Plan (IRP) or Data Breach Notification Policy containing specific “thresholds” for reporting.
Pass/Fail Test: If the documentation lacks binary criteria for when an incident must be escalated to an external body, mark as Non-Compliant.
3. Designated Liaison Personnel Identification Validated
Verification Criteria: Specific roles (e.g., DPO, CISO, Legal Counsel) are formally designated as the sole points of contact for interacting with authorities.
Required Evidence: Responsibility Assignment Matrix (RACI) or Job Descriptions specifying “Authority Liaison” duties.
Pass/Fail Test: If any staff member can contact a regulator regarding a security event without a formal internal approval path, mark as Non-Compliant.
4. Authority Contact Information Accuracy Verified
Verification Criteria: Contact details for relevant authorities (phone numbers, portal links, emergency emails) are current and verified within the last 12 months.
Required Evidence: The “Authorities Contact List” showing a “Last Verified” date and valid, non-generic contact points.
Pass/Fail Test: If contact details for a primary regulator are found to be disconnected or significantly outdated, mark as Non-Compliant.
5. Reporting Timelines Alignment with Legal Requirements Confirmed
Verification Criteria: Internal reporting deadlines (e.g., 72 hours for GDPR) are documented and align with the statutory requirements of the relevant jurisdictions.
Required Evidence: Data Protection Policy or Regulatory Compliance Framework documenting specific hourly/daily windows for notification.
Pass/Fail Test: If internal policy allows for notification windows that exceed legal requirements (e.g., “within 7 days” for a 72-hour requirement), mark as Non-Compliant.
6. Secure Communication Channels for Sensitive Reporting Verified
Verification Criteria: The organisation has identified and tested secure methods for transmitting sensitive breach data to authorities (e.g., encrypted portals).
Required Evidence: Screenshots of bookmarked regulatory portals or documented instructions for using encrypted communication for reporting.
Pass/Fail Test: If the only method for reporting a high-sensitivity breach is via unencrypted standard email, mark as Non-Compliant.
7. Evidence of Past Regulatory Interactions (If Applicable) Validated
Verification Criteria: If incidents occurred, the organisation must show that authorities were contacted within the required timeframe and through the correct channels.
Required Evidence: Incident logs, submission receipts from regulatory portals, or email threads with external legal counsel/authorities.
Pass/Fail Test: If a reportable incident occurred but no record of communication with the relevant authority exists, mark as Non-Compliant.
8. Regulatory Update Monitoring Process Confirmed
Verification Criteria: A proactive process is in place to monitor changes in legislation or authority requirements that might affect the ISMS.
Required Evidence: Subscription logs to regulatory newsletters, minutes from legal update meetings, or entries in a “Change in Law” log.
Pass/Fail Test: If the organisation has no systematic way to identify when a regulator changes its reporting requirements, mark as Non-Compliant.
9. Internal Escalation Path to Liaison Role Verified
Verification Criteria: Staff members know how to report an event internally so that the designated liaison can determine if authority contact is needed.
Required Evidence: Staff awareness training records or an internal “Whistleblowing/Reporting” flowchart.
Pass/Fail Test: If a sample of staff cannot identify the person or department responsible for regulatory reporting, mark as Non-Compliant.
10. Authority Contact Log Integrity Validated
Verification Criteria: A central log is maintained to record all instances of contact with authorities, including the date, reason, and outcome.
Required Evidence: “Regulatory Contact Log” or a filtered view of the Incident Management System showing “External Reporting” actions.
Pass/Fail Test: If communications with authorities are stored only in individual email inboxes without a central record, mark as Non-Compliant.
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Authority Identification | GRC tool provides a generic list of worldwide regulators. | Verify that the list is specifically narrowed down to the organisation’s actual trading jurisdictions and industry. |
| Notification Thresholds | SaaS template says “We will contact authorities when required by law.” | Demand specific, quantifiable triggers (e.g., “Exfiltration of >1000 PII records”) to ensure objective decision-making. |
| Liaison Roles | Tool assigns “The Board” as the point of contact. | Verify a *single* operational lead (like a CISO) is the gatekeeper to prevent confused or conflicting reporting. |
| Contact Accuracy | The tool links to the homepage of the regulator (e.g., ico.org.uk). | Verify the specific *reporting portal* link or the emergency hotline number is documented and functional. |
| Timeline Adherence | Tool logs a ticket as “Closed” once the authority is notified. | Verify that the *timestamp* of the notification matches the legal requirement relative to the “Time of Discovery.” |
| Communication Security | GRC tool assumes standard email is sufficient for reporting. | Verify if the regulator requires a specific secure portal and if the organisation has login credentials ready. |
| Update Monitoring | The GRC provider claims they “update the software when laws change.” | The organisation must prove *they* are monitoring for changes, as GRC vendors often lag behind local legislative shifts. |
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