Picture this: It is 3 AM. Your lead developer just woke you up because your customer database is being auctioned off on the dark web. Panic sets in. You know you need to fix the technical issue, but who else do you need to call? The police? A regulator? Your lawyer?
If you don’t know the answer immediately, you are already failing ISO 27001 Annex A 5.5: Contact with Authorities.
For tech startups, this control often feels like overkill. You might think, “We are just a team of 12 people, do we really need a direct line to the FBI?” The short answer is: Yes, but it doesn’t have to be complicated. Here is how to implement Annex A 5.5 efficiently, keeping your startup agile while staying compliant.
Table of contents
What is Annex A 5.5 Actually Asking For?
The requirement is simple: You need to establish and maintain contact with relevant authorities.
The goal isn’t to be best friends with the local police chief. The goal is to ensure that if a security incident happens (like a data breach, a break-in, or a fire), you aren’t wasting precious minutes Googling phone numbers. You need to know exactly who to contact, why you are contacting them, and how to reach them.
Why Startups Often Get This Wrong
Startups usually fail this control in one of two ways:
- The “Head in the Sand” Approach: They assume they are too small to matter to regulators. (Spoiler: GDPR applies to everyone).
- The “Call 911” Approach: They assume the police handle everything. In reality, local law enforcement rarely has the tools to help with a sophisticated SQL injection attack.
Step 1: Identify Your “Relevant Authorities”
The term “authority” is broad. For a tech startup, this list usually encompasses three distinct categories:
1. Legal and Regulatory Bodies
If you handle personal data (and you likely do), you have a legal obligation to report breaches to a supervisory authority. In the UK, that’s the ICO. In the EU, it’s your local Data Protection Authority. In the US, it might be state Attorneys General.
Startup Tip: If you are in Fintech or Healthtech, you have extra layers here (like the FCA or HIPAA regulators). Map these out clearly.
2. Law Enforcement
This includes your local police for physical security issues (break-ins at the office) and specialized cyber-crime units for digital attacks. Don’t just list “911.” Find the non-emergency number for your local cyber fraud division.
3. Utility and Emergency Services
Who provides your internet? Who manages the power for your server room (if you have one)? If the fiber line is cut, you need to know who to call to get back online.
Step 2: Create the Contact List (The “Red Book”)
You don’t need a complex software solution for this. A simple, secure document (part of your Incident Response Plan) is sufficient. It should include:
- Authority Name: (e.g., Information Commissioner’s Office)
- Contact Reason: (e.g., “Report a data breach involving PII within 72 hours”)
- Phone/Email: (Verified contact details)
- Your Account Number: (If relevant, like with an ISP)
If you want to save time and ensure you haven’t missed a critical category, you can use pre-built templates. Hightable.io offers ISO 27001 toolkits that include a “Contact with Authorities” register specifically designed to satisfy auditors without over-engineering the process.
Step 3: Know the Reporting Thresholds
This is the most critical part for a startup. You do not want to call the regulator for every minor glitch. That is a great way to invite an audit you don’t want.
Your implementation must define when to contact them.
- Scenario A: A laptop is lost, but the disk is encrypted. Do we call the regulator? (Probably not, depending on local laws).
- Scenario B: Our unencrypted customer database was exported by a hacker. Do we call? (YES, immediately).
Define these triggers in your Incident Management procedure so your team doesn’t hesitate during a crisis.
Step 4: Maintain and Verify
The “Maintain” part of the control is where you will get caught out in an audit. Creating a list in 2023 and never looking at it again until your 2026 audit is a non-conformity.
The Fix: Set a recurring calendar reminder (every 6 or 12 months) to check the links and phone numbers. Regulators change websites; hotlines change numbers. Evidence of this review—even a simple “Checked by [Name] on [Date]”—is pure gold for your auditor.
DO IT YOURSELF
STOP SPANKING £10,000s on CONSULTANTS and ISMS ONLINE PLATFORMS
Common Pitfalls to Avoid
Confusing Annex A 5.5 with Annex A 5.6:
Annex A 5.5 is about Authorities (people who can fine you or arrest you). Annex A 5.6 is about Special Interest Groups (people who can help you, like forums or security meetups). Keep them separate in your documentation.
Losing the List:
If your “Contact List” is saved on the server that just got hit by ransomware, you are in trouble. Keep an offline copy or a copy in a separate, secure cloud environment.
Conclusion
Implementing ISO 27001 Annex A 5.5 isn’t about bureaucracy; it’s about resilience. For a tech startup, it means knowing exactly who can help you (or who you are legally required to inform) when the worst happens.
Start by identifying your regulatory landscape, build your list, and review it regularly. It’s a small administrative task that pays off massively when you are staring at a critical incident screen at 3 AM. If you need help structuring this list or identifying your triggers, the templates at Hightable.io are an excellent resource to get you audit-ready fast.
About the author
Stuart Barker is a veteran practitioner with over 30 years of experience in systems security and risk management.
Holding an MSc in Software and Systems Security, Stuart combines academic rigor with extensive operational experience. His background includes over a decade leading Data Governance for General Electric (GE) across Europe, as well as founding and exiting a successful cyber security consultancy.
As a qualified ISO 27001 Lead Auditor and Lead Implementer, Stuart possesses distinct insight into the specific evidence standards required by certification bodies. He has successfully guided hundreds of organizations – from high-growth technology startups to enterprise financial institutions – through the audit lifecycle.
His toolkits represents the distillation of that field experience into a standardised framework. They move beyond theoretical compliance, providing a pragmatic, auditor-verified methodology designed to satisfy ISO/IEC 27001:2022 while minimising operational friction.
