Annex A Organizational Controls (A.5) Deep Dive

Organizational Controls are the backbone of a robust information security management system. They set the tone from the top, define clear roles, and establish the processes that make security an integral part of your organization's culture. This article dives deep into the five key control groups under A.5. For a high‑level overview of all Annex A categories, start with our Annex A Controls Overview before exploring these details.

A.5.1 - A.5.5: Information Security Policy Framework Controls

A.5.1 Policies for Information Security

The high-level directive establishes management commitment and overall objectives for information security. It sets the tone for the entire ISMS.

How to implement:

• Draft a concise Information Security Policy covering scope, objectives, roles, and responsibilities.
• Obtain formal approval from executive leadership and assign a policy owner.
• Publish the policy on your intranet or policy portal.
• Include a review cycle (annually or on significant change).

How to verify:

• Check for executive signature and version control in the document metadata.
• Confirm that the policy is accessible to all employees via your central repository.
• Review change logs to ensure scheduled reviews occur on time.

A.5.2 Review of the Policies for Information Security

A requirement to evaluate and update security policies to address evolving business needs, threats, and regulatory changes.

How to implement:

• Establish a policy review schedule (e.g., once per year or after major incidents).
• Form a cross-functional review team that includes IT, legal, and operations.
• Compare current policies to external benchmarks (industry standards, regulations).

How to verify:

• Audit review meeting minutes and evidence of policy revisions.
• Confirm stakeholders' sign-off on updated policies.
• Validate that outdated policy versions are archived.

A.5.3 Organization of Information Security

What it is: The structure and allocation of roles, responsibilities, and authority for information security management.

How to implement:

• Define an organizational chart that shows security governance roles.
• Document job descriptions for roles like Security Manager, Risk Owner, and Incident Lead.
• Communicate role assignments to all teams.

How to verify:

• Review organizational charts and role descriptions in HR records.
• Interview staff to confirm awareness of their security responsibilities.
• Check that all critical roles have documented handover procedures.

A.5.4 Mobile Device and Teleworking Policy

Guidelines and rules for the secure use of mobile devices and remote access by employees and third parties.

How to implement:

• Develop a mobile device policy covering configuration, encryption, and acceptable use.
• Define secure teleworking requirements, such as VPN usage and personal device controls.
• Distribute and obtain acknowledgments from remote workers.

How to verify:

• Inspect remote access logs for compliance with VPN and multi-factor authentication.
• Audit device management system records for enforced encryption settings.
• Confirm employee acknowledgments in the policy portal.

A.5.5 Information Security in Project Management

Integrating security requirements into project management processes for new IT initiatives or changes.

How to implement:

• Embed security checkpoints in project lifecycle phases (initiation, design, testing, deployment).
• Include threat modeling and risk assessments for each project.
• Assign a security representative to the project governance boards.

How to verify:

• Review project documentation for security requirement sections and sign-offs.
• Confirm that risk assessments and threat models exist for active projects.
• Check meeting minutes for security representative attendance and input.

A.5.6 - A.5.10: Roles, Responsibilities, and Sponsorship

A.5.6 Internal Organization of Information Security

Establishing a governance structure for managing and directing information security activities.

How to implement:

• Define a security governance model outlining committees, reporting lines, and decision-making authorities.
• Document this model in an organizational chart or governance charter.
• Communicate the structure to all relevant teams and update as roles evolve.

How to verify:

• Review the governance charter and organizational chart for accuracy and completeness.
• Check that governance committees meet regularly, with minutes recorded.
• Interview team leads to confirm their awareness of reporting lines.

A.5.7 Mobile and Remote Working Governance

Oversight of policies and procedures that secure remote access and mobile device use across the organization.

How to implement:

• Establish a policy governing remote access methods, device requirements, and acceptable use.
• Assign a remote-work coordinator responsible for policy updates and enforcement.
• Provide secure connection tools like VPN with multi-factor authentication.

How to verify:

• Audit remote-access logs for unauthorized attempts and compliance with access policies.
• Review the configuration of mobile device management (MDM) systems for enforced security settings.
• Confirm periodic policy reviews and updates.

A.5.8 Assignment of Information Security Responsibilities

Clear designation of who is responsible for each aspect of information security management.

How to implement:

• Create a responsibility matrix listing all security-related tasks and the assigned role.
• Ensure job descriptions include security responsibilities where applicable.
• Update the matrix whenever roles change or new tasks are introduced.

How to verify:

• Examine the responsibility matrix and verify alignment with job descriptions.
• Interview role holders to confirm they understand and execute their responsibilities.
• Check the change logs for updates to the matrix.

A.5.9 Segregation of Duties

Ensuring no single individual has control over multiple critical tasks that could lead to a conflict of interest or fraud.

How to implement:

• Identify critical processes (e.g., transaction processing, user provisioning) and map associated tasks.
• Assign different people to each task or implement system-based controls to enforce segregation.
• Document the segregation scheme in policies and process manuals.

How to verify:

• Audit system access and process logs to ensure no unauthorized task combinations occur.
• Review role assignments and system permissions periodically.
• Test sample transactions to confirm segregation enforcement.

A.5.10 Contact with Authorities and Special Interest Groups

Maintaining communication channels with law enforcement, regulatory bodies, and industry security groups.

How to implement:

• Designate a liaison responsible for interacting with external authorities and industry forums.
• Subscribe to relevant information-sharing communities and regulatory bulletins.
• Document contact procedures and escalation points in an external communication plan.

How to verify:

• Check records of communications with authorities and participation in security forums.
• Review the external communication plan for completeness and currency.
• Confirm that the liaison role is reflected in corporate directories and role charts.

A.5.11 - A.5.15: Risk Management and Treatment Oversight

A.5.11 Information Security Risk Assessment

A formal process to identify and evaluate potential threats and vulnerabilities that could affect your information assets.

How to implement:

• Choose a risk assessment methodology (qualitative, quantitative, or hybrid) and document it in your ISMS procedures.
• Identify assets, threats, and vulnerabilities through workshops, surveys, and system scans.
• Rate each risk's likelihood and impact according to predefined scales.
• Record findings in your risk register for ongoing tracking.

How to verify:

• Review the documented methodology for completeness and alignment with business needs.
• Check the risk register for entries covering all critical assets and risk ratings.
• Confirm that risk assessments are updated after major changes or annually.

A.5.12 Information Security Risk Treatment

Defining and applying appropriate measures to manage identified information security risks.

How to implement:

• For each risk, select one of ...