ISO 27001:2022 Clause 5.3 Organisational Roles, Responsibilities and Authorities for Tech Startups

ISO 27001 Clause 5.3 is a security control that requires top management to assign and communicate Roles, Responsibilities and Authorities. This ensures accountability within the ISMS, satisfying the requirement for clear governance and providing the Business Benefit of a defined chain of command during security incidents.

For a growing tech startup, the journey to ISO 27001 certification often feels like a series of complex bureaucratic hurdles. However, ISO 27001 Clause 5.3 is much more than a compliance box to tick. It is a foundational element for building a secure, scalable and trustworthy business.

The core challenge in a fast-moving startup environment is ambiguity. Without clear lines of ownership, critical security responsibilities can “fall through the cracks.” This leads to dangerous control gaps, confusion during incident response, or a failure to manage risk effectively. When everyone thinks someone else is responsible, usually no one is.

This High Table guide breaks down ISO 27001 Clause 5.3 into actionable steps specifically for startups. We define what the clause requires, who needs to do what, and how to establish an accountability blueprint to pass your audit and scale securely.

The Business Case: Why This Actually Matters

If you don’t define who owns security, you don’t have security. You have a hobby. Clause 5.3 is the difference between a startup that collapses when the CTO leaves and one that survives.

• Sales Angle: In every Enterprise Vendor Security Assessment (VSA), question #3 is always “Who is the designated individual responsible for Information Security?” If you answer “The Team,” you fail. Enterprise clients need a name and a title to know someone is accountable for their data.
• Risk Angle: The “Bus Factor.” If only one founding engineer knows how to rotate the AWS root keys and they get hit by a bus (or poached by Google), your company is paralyzed. Clause 5.3 forces you to document authorities so operations can continue without reliance on a single “hero.”

The “No-BS” Translation: Decoding the Requirement

The Auditor’s View: “Top management shall assign the responsibility and authority for ensuring that the information security management system conforms to the requirements of this document.”

The Startup’s View: Make a RACI chart. Write down exactly who has the power to merge code to production, who can ban a user, and who pays the Cloudflare bill.

For a DevOps engineer, this translates to:

• Responsibility: “I have to patch the server.” (The doer).
• Authority: “I have the IAM permission to deploy the patch.” (The enabler).
• Accountability: “If the patch crashes prod, the CTO takes the heat.” (The owner).

DORA, NIS2, and AI Laws

Clause 5.3 is the legal anchor for modern regulations. It stops management from pleading ignorance.

• DORA (Fintech): Requires a designated “ICT Risk Management Function.” You satisfy this by using Clause 5.3 to explicitly assign this role to a specific person, separate from the commercial teams.
• NIS2: This directive introduces personal liability for management bodies. Clause 5.3 is your defence. It proves that the Board delegated specific security tasks to competent individuals, demonstrating due diligence rather than negligence.
• AI Act: Requires “Human Oversight” of high-risk AI systems. Clause 5.3 allows you to formally create the role of “AI Oversight Officer” or assign it to the Head of Data, satisfying the regulatory requirement for human intervention.

Why the ISO 27001 Toolkit Trumps SaaS Platforms

SaaS platforms confuse “Permissions” with “Roles.” They are not the same thing.

Feature	ISO 27001 Toolkit (High Table)	Online SaaS GRC Platform
Ownership	You define the roles in a Word Doc. It reflects your actual org structure.	The platform forces you into their pre-defined “Admin/Editor/Viewer” buckets.
Flexibility	Easy to handle “fractional” roles (e.g., CTO is also CISO).	Often requires a unique email for every role, leading to licensing bloat.
Cost	One-off fee.	You pay per “seat.” Assigning a security responsibility to a dev shouldn’t cost you $30/month.
Reality	Maps to your real job descriptions.	Auditors ignore SaaS “roles” because they rarely match what people actually do.

Top 3 Non-Conformities When Using SaaS Platforms

1. The “Ghost Owner” Error: The SaaS tool assigns “Risk Owner” to a user who left the company 6 months ago. Because you don’t look at the tool daily, nobody noticed. An auditor spots this instantly.
2. The “Admin Trap”: The SaaS tool assumes the “Platform Admin” is the “CISO.” Often, the Admin is just an IT support person, while the CISO (who makes decisions) barely logs in. This is a failure to assign authority correctly.
3. The “RBAC Confusion”: The startup claims their “Roles and Responsibilities” are defined by the SaaS tool’s user permissions. The auditor asks, “Where is the responsibility for Physical Security defined?” The tool doesn’t cover that, so you get a Non-Conformity.

What is ISO 27001 Clause 5.3? (The Plain English Version)

To achieve compliance, you must first understand the core purpose of Clause 5.3: preventing ambiguity to ensure accountability. It ensures that everyone knows their duties, possesses the authority to execute them, and keeps leadership informed.

For a startup, this translates into three straightforward actions for top management:

1. Assign Ownership: Give a specific person or team the job of managing and owning the ISMS.
2. Grant Authority: Ensure that person has the power to execute duties and make necessary decisions (e.g., budget approval).
3. Establish Reporting: Make sure that person reports back to leadership on the effectiveness of the ISMS.

The Core Roles Your Startup Needs

High Table Tip: Do not create new job postings if you don’t need to. Map these functions to your existing team.

• The CEO (Top Management): Accountable for the ISMS. Signs the checks and the policies.
• The CISO / InfoSec Lead (Often the CTO): Responsible for the mechanics. Runs the risk assessments and audits.
• The Security Guild (Department Leads): Consulted on risks. They know if a specific control (like blocking USBs) will break their workflow.

The Evidence Locker: What the Auditor Needs to See

To pass the audit for Clause 5.3, you need these artifacts in your evidence folder:

• Organisational Chart: A simple PDF showing who reports to whom. Security should ideally have a direct line to the CEO, not buried under IT Operations.
• Job Descriptions: Signed documents for key roles (CTO, SysAdmin) that include a bullet point like “Responsible for information security within their domain.”
• RACI Matrix: A spreadsheet showing who is Responsible, Accountable, Consulted, and Informed for key security processes (e.g., Incident Response).
• Management Review Minutes: Proof that the InfoSec Lead actually reported the ISMS status to the CEO.

Common Pitfalls and Auditor Traps

• The “Paper CISO”: Assigning the role to a junior admin who has no authority to tell the CTO to fix a vulnerability. The auditor will test this by asking, “Can you block a deployment if it’s insecure?” If the answer is no, you fail Clause 5.3.
• Segregation of Duties (SoD) Fail: The same person writes the code, approves the pull request, and deploys to production. In a startup, this happens, but you must document it as a risk and implement compensating controls (e.g., post-deployment logs).
• Implied Roles: “Everyone knows Dave does backups.” If Dave gets hit by a bus, does the new guy know? If it is not written down, it doesn’t exist.

Handling Exceptions: The Break Glass Protocol

Sometimes you need to bypass defined roles (e.g., the CISO is on a flight during a breach).

• The Emergency Path: The CEO or COO assumes “Acting CISO” authority.
• The Paper Trail: Log the temporary transfer of authority in the Incident Log.
• Time Limits: Authority reverts immediately once the primary role holder is back online.

The Process Layer: Standard Operating Procedure (SOP)

Tools: HR Platform (BambooHR/Hibob), Notion (Documentation).

1. Onboarding: When a new hire starts, HR triggers a ticket. The Hiring Manager assigns specific security roles (e.g., “AWS Admin”) based on the job description.
2. Review: Quarterly, the CISO reviews the access list against the Org Chart. “Does Steve still need Admin rights now that he moved to Marketing?”
3. Change: If a role changes, update the Job Description and re-sign.
4. Evidence: Keep the signed JDs and the quarterly access review tickets as audit evidence.

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