Annex A 5.1: Policies for Information Security

To meet the annex a 5.1: policies for information security requirement, you must define, approve, publish, and maintain information security policies that are appropriate to your organization, communicated to relevant personnel, and reviewed on a planned basis. Operationalize this by assigning clear ownership, setting a review cadence and change triggers, and keeping audit-ready evidence of approvals, version control, and communication. ¹

Key takeaways:

• Your “policy” must be a managed system: owner, scope, approval, distribution, review, and change control.
• Auditors will test operation, not prose: evidence of review, communications, and exceptions matters as much as the document.
• Treat policies as the top layer of your ISMS control stack, then map standards, procedures, and technical controls underneath.

Annex A 5.1 is deceptively simple: “have information security policies.” In practice, auditors and customer due diligence teams use this control to gauge whether your security program is governed or improvised. A polished policy PDF alone will not pass scrutiny if you cannot show who owns it, how it stays current, and how the organization is expected to follow it day to day. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat 5.1 as a policy management lifecycle requirement. You need a policy framework (what policies exist and how they relate), governance (who approves and who maintains), communications (how staff and relevant third parties learn what to do), and review mechanisms (how changes in business, technology, and risk drive updates). ²

This page gives requirement-level implementation guidance you can execute quickly: a step-by-step build plan, minimum evidence to retain, common audit hangups, and a practical phased execution plan. It is written to help you survive an ISO 27001 certification audit and reduce friction in customer security reviews without overengineering. ²

Regulatory text

Control focus (provided excerpt): “ISO/IEC 27001:2022 Annex A control 5.1 implementation expectation (Policies for Information Security).” ¹

Operator interpretation of what the text requires You are expected to:

1. Define information security policies that match your business and risk context (scope, objectives, and rules of behavior).
2. Approve them at the right level (so they carry authority).
3. Publish and communicate them to the people who must follow them (and, where relevant, to third parties who touch your information).
4. Review and update them based on a planned cadence and on trigger events (material business, technology, regulatory, or risk changes). ¹

A useful operational test: if an auditor asks “Show me the current policy, who approved it, when it was last reviewed, what changed, and how staff were informed,” you should be able to answer in minutes from a single system of record.

Plain-English interpretation (what “good” looks like)

Annex A 5.1 expects a policy layer that governs everything underneath (standards, procedures, and technical controls). Policies set direction and mandatory requirements; procedures describe how teams execute; configurations enforce. If your policies are disconnected from real operations, you will fail the “implemented and maintained” expectation in practice. ²

Who it applies to

Entity types: Any organization implementing ISO/IEC 27001, including service organizations that need auditable governance for information security. ²

Operational context (where it bites)

• Fast-growing environments where systems and roles change faster than documentation.
• Distributed teams where “tribal knowledge” substitutes for formal rules.
• Outsourced or cloud-heavy models where third parties handle material parts of processing and operations.
• Regulated or customer-audited companies where questionnaires demand policy references and proof of governance. ²

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

Step 1: Define your policy architecture (start small, stay enforceable)

Create a short list of top-level policies you will govern under 5.1. Keep it aligned to your ISMS scope and business model. A practical starter set:

• Information Security Policy (umbrella / charter)
• Acceptable Use Policy
• Access Control Policy
• Data Classification & Handling Policy
• Cryptography / Key Management Policy (if applicable)
• Incident Response Policy
• Third Party Security Policy (where third parties process or access information) ²

Deliverable: a policy register that lists each policy, owner, approver, version, effective date, next review date, and where it is published.

Step 2: Assign ownership and approval authority (make governance real)

For each policy:

• Name a Policy Owner (writes/maintains content; coordinates reviews).
• Name an Approver (exec or governance body with authority to enforce).
• Identify mandatory reviewers (Security, Legal/Privacy, HR, IT Ops, Product, or Procurement depending on policy). ²

Practical rule: if the approver cannot enforce compliance across functions, pick a higher approval level.

Step 3: Write policy content that is testable

Avoid narrative statements that cannot be verified. Include:

• Purpose and scope (systems, data, locations, subsidiaries, and in-scope roles)
• Policy statements using “must” language for mandatory controls
• Roles and responsibilities (RACI-style is fine)
• Exceptions process (who can approve, criteria, expiry, compensating controls)
• References to supporting standards/procedures (so operators know where execution details live) ²

Example of testable language:

• “Production access must be provisioned through a documented request and approval workflow.”
• “Security incidents must be reported through the defined incident channel and tracked to closure.”

Step 4: Put policies under document control

Implement document control rules:

• Versioning and change history
• Approval workflow evidence
• Effective date and next review date
• Single authoritative publication location (GRC system, intranet, or controlled repository)
• Access control for editing (few editors, many readers) ²

Daydream (or any GRC workflow tool) becomes useful here because it can tie together ownership, approvals, review tasks, and the evidence bundle in one place, rather than scattering proof across email threads and shared drives.

Step 5: Publish and communicate (prove people received the message)

Define communication channels by audience:

• Workforce: onboarding + annual acknowledgment, security awareness training tie-in, intranet publication
• Privileged users: role-based training and attestations
• Relevant third parties: contract clauses, security addendum references, or shared policy extracts where appropriate ²

Minimum operating expectation: you can show that the current policy version was made available and communicated to the population expected to follow it.

Step 6: Establish review cadence and trigger events

Define:

• Planned review frequency (set by you as an internal requirement).
• Trigger events, such as major incidents, significant system changes, acquisitions, new material third parties, or changes in law/regulation affecting your scope. ²

Then operationalize it with recurring tasks and assigned owners. Auditors look for “maintained,” which usually fails due to missed reviews.

Step 7: Run control health checks and remediate gaps

Create a lightweight recurring check:

• Are all policies current (within review window)?
• Are approvals current and traceable?
• Are exceptions documented and time-bound?
• Do procedures and technical controls still match policy requirements? ²

Track remediation items to closure with owners and due dates. This closes the loop between policy and operations.

Required evidence and artifacts to retain (minimum evidence bundle)

Keep evidence in a single, auditable location and be consistent across policies.

Core artifacts

• Policy register (inventory) with owners, approvers, versions, and review dates
• Current approved policy documents (PDF export or controlled doc)
• Approval records (meeting minutes, e-signature workflow, ticket approvals)
• Version history / change log (what changed, who changed it, when)
• Publication evidence (link to controlled repository; access permissions)
• Communication evidence (training assignment records, acknowledgment logs, onboarding checklist)
• Exceptions register (requests, approvals, compensating controls, expiry, closure evidence)
• Review records (scheduled review task completion, reviewer comments, outcomes) ²

Common exam/audit questions and hangups

Auditors and customer assessors tend to probe the same failure points:

1. “Who approved this policy, and do they have authority?”
   Hangup: approvals via informal email with no traceability.

2. “Show the last review and what changed.”
   Hangup: “reviewed” is claimed, but no recorded outcome or change log exists.

3. “How do you ensure employees know these rules?”
   Hangup: policies exist but no evidence of communication, training tie-in, or acknowledgment.

4. “How do you handle exceptions?”
   Hangup: ad hoc exceptions that never expire; no compensating controls documented.

5. “Is this policy aligned to your actual environment?”
   Hangup: copied templates that conflict with cloud architecture or operating model. ²

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails audits	Fix
Policies written as high-level statements only	Not testable; no linkage to execution	Add clear “must” requirements and reference procedures/standards
No defined policy owner	No maintenance accountability	Assign named owners and backups in the policy register
Reviews happen “when needed”	“Maintained” cannot be proven	Set a planned cadence plus trigger events; track completion
Publishing policies in shared drives with edit access for many	Version confusion and unauthorized edits	Use a controlled repository with tight edit permissions
Exceptions handled verbally	Unbounded risk acceptance	Use an exceptions register with approval, expiry, and compensating controls
One-time policy rollout	Employees cannot demonstrate awareness	Add onboarding + recurring acknowledgments and role-based training where needed
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Risk implications (why operators should care)

If 5.1 is weak, you get downstream control failures:

• Incidents escalate because reporting and response expectations are unclear.
• Access and change management drift because there is no enforceable baseline.
• Third-party risk rises because suppliers are not held to defined requirements.
• Audit scope expands, since auditors compensate for weak governance by sampling deeper into operational controls. ²

Practical execution plan (30/60/90-day)

You asked for speed, but ISO implementations vary. Use phases as a delivery mechanism, then set your own dates based on resourcing.

First 30 days (Immediate)

• Stand up a policy register with owners, approvers, and publication location.
• Confirm ISMS scope boundaries and align which policies are “in scope.”
• Draft or revise the umbrella Information Security Policy and two high-impact supporting policies (typically Acceptable Use and Access Control).
• Implement document control: versioning, approvals, and controlled publishing.
• Define the exceptions workflow and create an exceptions register. ²

Days 31–60 (Near-term)

• Complete the remaining core policy set needed for your environment (data handling/classification, incident response, third party security, etc.).
• Create a communications plan: onboarding, workforce acknowledgment, and targeted training for privileged roles.
• Run a policy-to-procedure mapping workshop with control owners to ensure each “must” has an execution path.
• Perform the first control health check and open remediation items. ²

Days 61–90 (Operationalize)

• Execute your first full policy review cycle for at least one policy to prove “maintained” operation.
• Sample test: verify a handful of staff can find the current policy and describe their obligations.
• Review exception records for expiry and compensating controls; close or renew deliberately.
• Package the evidence bundle for auditors: register, approvals, communications, review records, and exception log exports. ²

Frequently Asked Questions

Do we need multiple policies, or is one Information Security Policy enough for annex a 5.1: policies for information security requirement?

Annex A 5.1 expects policies for information security, which commonly means an umbrella policy plus supporting policies for key domains. Keep the set small, but make each policy testable and owned. ¹

Who should approve information security policies?

Approval should come from a role or body with authority to enforce compliance across functions (often executive leadership). Auditors care that approval is explicit and traceable, not informal. ²

What counts as “communicated” to employees?

Publication alone is usually weak evidence. Pair publication with onboarding, training tie-ins, and acknowledgments so you can show the intended audience received and understood the current version. ²

How do we handle policy exceptions without creating audit problems?

Use a documented exception process with a defined approver, compensating controls, and an expiry date so risk acceptance is deliberate and time-bound. Keep an exceptions register and show periodic review. ²

How do we prove policies are “maintained” over time?

Track planned reviews and trigger-based updates with a tasking system, then retain review outcomes and version history. Auditors typically want to see evidence of at least one completed review cycle. ²

Can we use a policy template from another company?

You can start from templates, but you must reconcile every requirement with your actual systems, roles, and processes. Template language that conflicts with operations creates audit findings because it proves the policy is not implemented. ²

Footnotes

1. ISO/IEC 27001 overview; ISMS.online Annex A control index

2. ISO/IEC 27001 overview