Safeguard 17.5: Assign Key Roles and Responsibilities

Safeguard 17.5 requires you to formally assign, document, and maintain clear cybersecurity roles and responsibilities so every critical security activity has an accountable owner and backup. To operationalize it fast, publish a role-to-control responsibility matrix (RACI), tie it to your security governance cadence, and retain recurring evidence that owners are performing the work. ¹

Key takeaways:

• You need named owners (and delegates) for key security functions, not generic “IT” ownership. ²
• Auditors will look for role clarity plus proof the roles operate: meeting notes, approvals, tickets, exceptions, and metrics. ²
• Make the assignment durable by linking it to HR joiner/mover/leaver workflows and your control testing calendar. ³

Safeguard 17.5: assign key roles and responsibilities requirement is a governance control with a simple test: can you show who is responsible for each security outcome, and can you prove they actually do it on an ongoing basis? CIS Controls v8 treats role clarity as an implementation enabler, because many “technical” failures trace back to ownership gaps: alerts that no one triages, vulnerabilities that no one remediates, exceptions that no one approves, and third-party risks that no one monitors. ¹

For a CCO, compliance officer, or GRC lead, the fastest path is to translate your security program into a short list of key functions, assign accountable owners, document decision rights, and set a predictable operating rhythm. Then, make evidence collection routine so you are not scrambling when an auditor asks, “Who owns this?” and “Show me it happened.” ²

This page gives requirement-level implementation guidance you can put into production quickly: applicability, plain-English interpretation, a step-by-step build, the artifacts to retain, common audit hangups, mistakes to avoid, and a practical 30/60/90-day execution plan. ¹

Regulatory text

Framework requirement (excerpt/summary): “CIS Controls v8 safeguard 17.5 implementation expectation (Assign Key Roles and Responsibilities).” ¹

Operator interpretation: You must define and assign key cybersecurity roles and responsibilities across your organization so security tasks have clear accountability, coverage, and escalation paths. The standard of proof is documented assignment plus operational evidence that assigned owners perform the responsibilities as part of normal business. ²

Plain-English interpretation (what the requirement really means)

Safeguard 17.5 expects you to answer these questions with documentation and repeatable practice:

• Who is accountable for each major security function (policy, risk, incident response, logging, vulnerability management, access control, third-party security, etc.)? ²
• Who does the work day to day, and who is the backup when the primary owner is out? ²
• Who approves exceptions and accepts risk, and what is the escalation route when security work conflicts with delivery timelines? ³
• How do you prove it operates (tickets, approvals, meeting minutes, reports, metrics, reviews)? ²

If your current state is “security is shared” or “IT handles it,” you will fail the intent. Shared responsibility still needs named accountable owners and defined decision rights. ²

Who it applies to (entity and operational context)

Safeguard 17.5 applies broadly to enterprises and technology organizations implementing CIS Controls v8. ¹

Operationally, it matters most when you have:

• Multiple IT and security teams (or IT plus a managed service provider) where work can fall through handoffs. ²
• Regulated obligations mapped to CIS Controls (SOC 2, ISO 27001, PCI DSS, HIPAA Security Rule, GLBA), where you must show governance and control ownership, even if CIS is the organizing framework. ²
• Meaningful third-party dependency (cloud providers, SaaS, MSP/MSSP, payment processors), where your internal roles must cover oversight, escalation, and exception handling. ²

What you actually need to do (step-by-step)

Step 1: Define the “key roles” list for your environment

Start with a pragmatic set of roles tied to outcomes, not org chart titles. Examples you can tailor:

• Security program owner (often CISO or Head of Security)
• GRC / risk owner (often GRC lead)
• Incident response lead and incident commander delegate
• Vulnerability management owner
• Identity and access management owner
• Security logging/SIEM owner
• Data protection owner (classification, encryption, retention alignment)
• Secure configuration owner (benchmarks, baselines)
• Third-party security owner (TPRM)
• Security awareness/training owner
• Change management approver for security-impacting changes
  Your goal is full coverage for the security functions you run and the controls you claim. ²

Step 2: Create a control-to-role responsibility matrix (RACI)

Build a matrix that maps each relevant CIS safeguard (or your internal control statements) to:

• A (Accountable): one named role (not a committee)
• R (Responsible): operational doers (teams or roles)
• C (Consulted): stakeholders (legal, privacy, HR, product)
• I (Informed): executives/board committee as needed
  Keep it readable. Auditors prefer a clear table over prose. ²

Minimum expectation for 17.5: Every key security activity has an A and an R, plus an escalation path when work is blocked. ²

Step 3: Write role charters with decision rights and boundaries

For each key role, publish a short charter (one to two pages) that answers:

• Scope: what systems, business units, and third parties are covered
• Decision rights: what the role can approve (exceptions, compensating controls, tool changes)
• Required cadence: what gets reviewed and how often (tie to your governance calendar)
• KPIs/metrics: what evidence proves the role is operating
  This reduces “shadow ownership” and helps in reorganizations. ³

Step 4: Assign named individuals and backups (delegations)

Roles need names. For each role, document:

• Primary assignee (name, title, department)
• Backup/delegate (name/title)
• Approval authority (who can accept risk, who can sign off exceptions)
  If you outsource functions, document the internal accountable owner and the external responsible party (for example, MSSP as R, internal Security Ops Manager as A). ²

Step 5: Embed assignments into HR and operating workflows

Make the assignments durable:

• Add role ownership to onboarding for security/IT leadership roles.
• Trigger a review on job changes and departures.
• Include role ownership confirmation in your annual policy review or control attestation cycle.
  This is where many programs break: the document exists, but it is not maintained after reorgs. ²

Step 6: Prove operation with recurring evidence capture

Map 17.5 to documented control operation and recurring evidence capture. ¹ Practical examples of “operation” evidence:

• Incident response: on-call rota, incident postmortems with incident commander named
• Vulnerability management: remediation SLAs tracked in tickets, exception approvals with approver identity
• Access reviews: sign-off records showing reviewer and approver
• Logging: dashboard ownership, alert triage tickets assigned to the right role
• Third-party security: due diligence approvals, risk acceptances, ongoing monitoring actions
  Use your ticketing system, GRC tool, and meeting minutes as primary evidence sources. ²

Step 7: Test the control like an auditor would

Run a tabletop audit against a small sample: pick a security process, ask “who owns this,” and request evidence from the last operating cycle. If you cannot produce it quickly, fix the workflow and the evidence capture point. ²

Required evidence and artifacts to retain

Retain artifacts that prove both assignment and operation: ²

• Role and responsibility policy/standard (or governance charter)
• RACI matrix mapping controls or security functions to roles
• Named role assignments and backups (org chart excerpt or assignment register)
• Decision-rights documentation (exception and risk acceptance authority)
• Governance cadence artifacts: security steering committee minutes, risk committee minutes, action logs
• Tickets and approvals showing the right owner acted (access reviews, vulnerability exceptions, IR records)
• Training/enablement for role holders where applicable (for example, incident commander training)
• Periodic review evidence: dated sign-off that roles and assignments were revalidated after org changes

Common exam/audit questions and hangups

Auditors and assessors commonly push on: ²

• “Show me the accountable owner.” If you list a team, they will ask for a person.
• “How do you ensure continuity?” Missing backup/delegate is a recurring finding.
• “Who can accept risk?” Many programs lack explicit risk acceptance authority and thresholds.
• “Prove it operated.” A RACI alone is not evidence of operation. Expect sampling.
• “How do you keep it current?” They will ask what triggers updates (reorgs, tool changes, M&A).

Frequent implementation mistakes and how to avoid them

1. Mistake: treating the org chart as the control. Org charts do not show decision rights or control ownership.

   • Fix: publish a RACI tied to controls and outcomes, not reporting lines. ²

2. Mistake: “Security owns everything.” That creates bottlenecks and weakens accountability in IT and product.

   • Fix: make security accountable for governance and oversight, and assign operational ownership to the teams that run the systems (with security consulted/approving where required). ²

3. Mistake: no coverage for third-party oversight. Procurement signs the contract; nobody owns security monitoring post-signature.

   • Fix: assign an accountable third-party security owner and define handoffs with procurement, legal, and business owners. ²

4. Mistake: roles assigned, but no evidence trail.

   • Fix: design evidence capture into workflows (tickets, approvals, meeting notes) and schedule recurring exports into your audit repository. ¹

Enforcement context and risk implications

CIS Controls v8 is a framework, not a regulator, so enforcement typically shows up indirectly: during customer audits, SOC 2/ISO assessments, cyber insurer reviews, or regulator exams that expect clear governance and accountability. Role ambiguity increases incident impact because escalation paths and decision authority are unclear during time-sensitive events, and it increases audit findings because control operation cannot be attributed to an owner. ²

If you want this to hold up under scrutiny, treat 17.5 as “security accountability infrastructure.” Without it, other safeguards become hard to operate and hard to prove. ²

Practical 30/60/90-day execution plan

First 30 days (stabilize ownership)

• Inventory key security functions you run and the controls you claim in scope. ²
• Draft a first-pass RACI for those functions; name accountable owners and backups. ²
• Document risk acceptance and exception approval authority for common scenarios (vuln exceptions, access exceptions, logging gaps). ²
• Stand up an evidence folder structure aligned to the RACI so owners know where artifacts go. ²

Days 31–60 (make it operational)

• Publish role charters and socialize decision rights with IT, engineering, and procurement. ³
• Add role ownership checks into joiner/mover/leaver workflows for relevant leadership roles. ²
• Define the governance cadence (steering committee agenda, metrics, action tracking) and run the first cycle. ²
• Start recurring evidence capture from tickets and systems of record (GRC exports, approval logs). ²

Days 61–90 (prove it and harden it)

• Perform a sampling-based internal test: pick several controls, identify the owner, and collect recent evidence. ²
• Close gaps: unclear handoffs, missing backups, missing exception approvals, outdated assignments. ²
• Add a periodic attestation for role owners to confirm responsibilities and update changes. ²
• If you use Daydream, map Safeguard 17.5 to a documented control, assign owners in the platform, and schedule recurring evidence requests so proof is collected continuously rather than during audit drills. ¹

Frequently Asked Questions

Do we need a dedicated CISO to meet safeguard 17.5: assign key roles and responsibilities requirement?

No. CIS expects roles and responsibilities to be assigned, not a specific title. You can meet the requirement with equivalent accountable owners and clear decision rights. ²

Can a managed security service provider (MSSP) be the “owner” for incident response or monitoring?

The MSSP can be responsible for performing tasks, but you still need an internal accountable owner who has authority to accept risk, approve actions, and escalate decisions. Document both in your RACI. ²

What is the minimum documentation auditors expect for 17.5?

A RACI (or equivalent) that names accountable owners and backups, plus evidence the owners operate the processes (tickets, approvals, minutes, reports). A policy without operating proof usually fails sampling. ²

How do we keep role assignments current during reorganizations?

Tie updates to HR workflows and require a periodic ownership review as part of your governance cadence. Revalidate after leadership changes, acquisitions, or major technology shifts. ²

We already have job descriptions. Do they count as role assignments?

Job descriptions help, but they rarely map to specific controls or show decision rights and backup coverage. Use job descriptions as input, then publish a control-aligned RACI and role charters. ²

How granular should the RACI be?

Granular enough that each key security activity has a single accountable owner and clear doers, but not so detailed that maintenance collapses after the next reorg. Start with key functions, then expand only where audits find ambiguity. ²

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8

2. CIS Controls v8

3. CIS Controls Navigator v8