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Validate that outdated policy versions are archived.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 the treatment options: avoid, reduce, transfer, or accept.
Map chosen controls to risks in a treatment plan, assign owners, and set deadlines.
Allocate resources (budget, tools, staff) needed to implement controls.
Document the risk treatment plan and integrate it into management review cycles.
How to verify:
Audit the treatment plan for completeness, assigned actions, and target dates.
Check evidence of control implementation (e.g., configuration changes, policy updates).
Validate that residual risks are reassessed and within acceptable thresholds.
A.5.13 Reporting Information Security Events and Weaknesses
Procedures for reporting observed or suspected security events, incidents, and system weaknesses.
How to implement:
Define reporting channels (email, hotline, ticketing system) and incident categories.
Train employees on how and when to report security concerns.
Establish a triage process for initial event validation and categorization.
How to verify:
Review incident tickets or logs for prompt reporting and categorization.
Check training records to ensure all staff attended reporting procedure sessions.
Inspect triage logs to confirm timely escalation and handling.
A.5.14 Assessment of and Decision on Information Security Events
A process to evaluate reported events and decide whether they constitute incidents requiring management action.
How to implement:
Set criteria for classifying events as incidents (e.g., data breach potential, service disruption).
Appoint an incident assessment team responsible for rapid analysis and decision-making.
Document decisions and assign incident response actions as needed.
How to verify:
Audit assessment records for consistency with classification criteria.
Review incident response plans to ensure that decisions are recorded and acted upon.
Confirm follow-up actions are tracked to closure.
A.5.15 Response to Information Security Incidents
Coordinated steps to contain, eradicate, and recover from security incidents, minimizing damage and learning for future prevention.
How to implement:
Develop an incident response plan outlining containment, eradication, recovery, and communication steps.
Assign roles for incident handlers, communicators, and technical responders.
Conduct tabletop exercises and simulations to test the plan’s effectiveness.
How to verify:
Examine incident response reports and lessons-learned documentation.
Review exercise results and corrective action lists for plan improvements.
Check communication logs for stakeholder notifications and regulatory reporting compliance.
A.5.16 – A.5.20: Incident Management and Reporting
A.5.16 Management of Information Security Incidents and Improvements
Processes to manage incidents from detection through resolution, including lessons learned and continual improvement.
How to implement:
Record incidents in a centralized system with unique identifiers.
Conduct a root-cause analysis for major incidents and document findings.
Track corrective actions and verify completion.
Update policies and controls based on lessons learned.
How to verify:
Review incident logs for completeness and timeliness of updates.
Check post-incident review reports and evidence of corrective action implementation.
Confirm updated policies reference incident learnings.
A.5.17 Establishment of a Security Incident Response Team
Forming a dedicated team responsible for coordinating incident detection, response, and recovery.
How to implement:
Define roles and responsibilities for incident response team members.
Develop contact lists and escalation paths.
Provide training and run regular response drills.
How to verify:
Inspect team charters and contact rosters.
Review drill reports for performance metrics and improvement actions.
Interview team members on their roles and procedures.
A.5.18 Learning from Information Security Incidents
Systematically capturing insights from incidents to prevent recurrence.
How to implement:
Schedule post-incident review meetings.
Produce a lessons-learned report with action items and deadlines.
Assign owners for implementing improvements.
How to verify:
Check lessons-learned reports and action-item completion records.
Validate that control changes were made in response to findings.
Confirm that training or communications were updated.
A.5.19 Reporting Security Events to Management
Ensuring that significant incidents and trends are communicated upward for strategic decision-making.
How to implement:
Define criteria for reporting events to executive management.
Incorporate incident metrics into regular security dashboards and management reports.
Present summaries in governance meetings.
How to verify:
Review management meeting minutes for incident report presentations.
Confirm distribution logs for executive reports.
Check dashboards for key incident metrics.
A.5.20 Communication of Security Controls Status
Regular updates on control effectiveness and security posture across the organization.
How to implement:
Develop a security metrics dashboard covering incident rates, control health, and training completion.
Schedule periodic security briefings with stakeholders.
Publish summary reports to relevant teams.
How to verify:
Inspect dashboard configurations and data source connections.
Review briefing materials and attendance records.
Confirm report archives in shared repositories.
A.5.21 A.5.37: Business Continuity and Supplier Security
A.5.21 Supplier Security Policy
Defining security requirements and evaluation criteria for third-party providers.
How to implement:
Draft a supplier security policy outlining minimum controls and audit rights.
Integrate policy into vendor contracts.
Conduct security due diligence before onboarding.
How to verify:
Review contract templates for embedded security clauses.
Check due diligence reports on suppliers.
Confirm periodic reevaluations are scheduled.
A.5.22 Supplier Service Delivery Management
Monitoring and managing the ongoing security performance of suppliers.
How to implement:
Define key security performance indicators (KPIs) for suppliers.
Require regular security reports or certifications.
Conduct annual supplier reviews.
How to verify:
Inspect supplier KPI reports and certifications (e.g., ISO certificates).
Check review meeting minutes and action logs.
A.5.23 Security Requirements in Supplier Agreements
Embedding specific security obligations and penalties in contractual agreements.
How to implement:
Collaborate with legal to insert clauses on data protection, breach notification, and audit rights.
Obtain executive sign-off on all supplier agreements.
How to verify:
Audit a sample of active supplier contracts for required clauses.
Confirm that penalty terms are actionable and enforced when needed.
A.5.24 Supplier Service Delivery Monitoring
Ensuring suppliers adhere to agreed security standards during service delivery.
How to implement:
Implement service-level monitoring tools or dashboards.
Schedule periodic supplier audits or assessments.
Track incidents and remediation actions involving suppliers.
How to verify:
Review monitoring tool logs and supplier assessment reports.
Check incident logs tied to supplier services.
A.5.25 Business Continuity Policy and Objectives
Establishing policies and objectives for maintaining critical operations during disruptions.
How to implement:
Draft a Business Continuity Policy aligned with corporate objectives.
Define recovery time objectives (RTO) and recovery point objectives (RPO).
Obtain top-management approval.
How to verify:
Inspect policy documents for defined RTOs/RPOs.
Review approval signatures and version history.
A.5.26 Business Impact Analysis
Identifying critical business functions and their dependencies to assess the impact of disruptions.
How to implement:
Map key processes, systems, and resources.
Evaluate the financial and operational impact of downtime.
Prioritize recovery strategies based on impact ratings.
How to verify:
Audit BIA reports for completeness and accuracy.
Confirm alignment between BIA outcomes and recovery strategies in plans.
A.5.27 Business Continuity Strategy
Defining the approach and resources required for business recovery.
How to implement:
Select appropriate continuity strategies (e.g., cold site, hot site, cloud failover).
Allocate budget and assign resources for each strategy.
How to verify:
Review strategy documents and resource allocation records.
Check budget approval for continuity initiatives.
A.5.28 Business Continuity Plans and Procedures
Documented steps to restore operations for critical functions.
How to implement:
Develop detailed plans for each critical process identified in the BIA.
Include step-by-step recovery procedures, contact lists, and communication templates.
How to verify:
Inspect plan documents for completeness and clarity.
Conduct plan walkthroughs and validate participant familiarity.
A.5.29 Testing, Maintenance, and Review of BCPs
Regular exercise and update of business continuity plans to ensure effectiveness.
How to implement:
Schedule annual drills and tabletop exercises.
Update plans based on test outcomes and organizational changes.
How to verify:
Review drill reports and improvement logs.
Check version control records for plan updates.
A.5.30 Training and Awareness for BCPs
Ensuring staff understand their roles in business continuity scenarios.
How to implement:
Develop and deliver BCP-specific training sessions.
Distribute quick-reference guides or checklists.
How to verify:
Review training attendance records and feedback surveys.
Confirm that staff can articulate their continuity responsibilities.
A.5.31 Information Security Continuity: Roles and Responsibilities
Assigning clear roles for information security during a continuity events.
How to implement:
Define continuity roles in BCP documents.
Cross-train backup personnel to cover key roles.
How to verify:
Check role assignment records and training logs.
Test role handovers during exercises.
A.5.32 Physical and Environmental Security in BCP
Incorporating physical controls in continuity planning to protect facilities.
How to implement:
Include facility access, power backup, and environmental monitoring in BCPs.
Test the generator and environmental controls during drills.
How to verify:
Review maintenance and test logs for backup systems.
Confirm that the environmental sensor data aligns with the plan requirements.
A.5.33 Supplier Continuity Requirements
Ensuring critical suppliers have their own continuity plans that align with yours.
How to implement:
Assess supplier BCPs for compatibility with your RTO/RPO.
Include supply chain continuity clauses in contracts.
How to verify:
Audit supplier continuity documentation and test results.
Confirm contract clauses are enforced during supply disruptions.
A.5.34 Business Continuity Documentation and Record Keeping
Maintaining accurate BCP and continuity test records.
How to implement:
Store BCP documents and test reports in a secure, version-controlled repository.
Ensure accessibility during continuity events.
How to verify:
Inspect document repository permissions and version logs.
Validate retrieval procedures during unplanned test.
A.5.35 Continuous Improvement of BCPs
Updating continuity plans based on lessons learned and changing requirements.
How to implement:
Incorporate post-exercise feedback into plan revisions.
Review BCPs after organizational or technological changes.
How to verify:
Check improvement logs and plan versions after each update.
Confirm stakeholder review sign-offs on changes.
A.5.36 Coordination Between Business Continuity and Information Security
Ensuring alignment between ISMS and BCP activities.
How to implement:
Establish joint governance reviews for ISMS and BCP programs.
Map information security controls to continuity scenarios.
How to verify:
Review governance meeting records showing integrated agendas.
Confirm traceability between security controls and continuity plans.
A.5.37 Availability of Information Processing Facilities
Ensuring that critical processing resources are available according to business needs.
How to implement:
Define availability requirements for systems and applications.
Implement redundancy and failover mechanisms.
How to verify:
Monitor system uptime metrics against defined availability targets.
Review incident reports for downtime events and remediation effectiveness.
Embracing these Organizational Controls transforms security from a back-office task into a strategic, company-wide discipline. For a broader view of Annex A and to see how these controls interlock with People, Physical, and Technological domains, explore our ISO 27001 Annex A overview and the ISO 27001 Audit Checklist.
