Annex A 5.2: Information Security Roles and Responsibilities

Annex a 5.2: information security roles and responsibilities requirement means you must clearly define, assign, and maintain security responsibilities across the organization so security work has accountable owners, delegated authority, and repeatable execution. Operationalize it by publishing a roles-and-responsibilities model (often RACI), mapping it to ISMS processes and assets, and keeping evidence that assignments are current and used.

Key takeaways:

• Assign named owners for security decisions and recurring security operations, not just “the IT team.”
• Tie responsibilities to processes (risk, incidents, access, third-party) and to job roles, then make them auditable.
• Keep evidence of approvals, communications, and periodic reviews so you can prove the control operates over time.

A 27001 audit rarely fails because a team has “no security.” It fails because nobody can prove who is responsible for specific security outcomes, who has authority to approve exceptions, and who must act when conditions change. Annex A 5.2 exists to remove that ambiguity.

For a Compliance Officer, CCO, or GRC lead, this control is a coordination requirement. Your job is to turn security responsibilities into an operating model that withstands personnel changes, reorganizations, and outsourcing. That means named accountability, documented delegation, and a way to show the assignments are reviewed and used in day-to-day workflows.

This page gives requirement-level implementation guidance you can apply quickly: who needs to be on the hook, what “good” evidence looks like, how auditors test it, and the common failure modes (for example, a generic RACI that doesn’t match how incidents, access approvals, and third-party onboarding actually work). References: ISO/IEC 27001 overview; ISMS.online Annex A control index.

Regulatory text

Control focus (provided excerpt): “ISO/IEC 27001:2022 Annex A control 5.2 implementation expectation (Information Security Roles and Responsibilities).” ¹

Operator interpretation: You must define and assign information security roles and responsibilities, communicate them to the relevant parties, and maintain them so they stay accurate as the organization changes. Practically, you need (1) a documented model of responsibilities, (2) named role owners, (3) evidence that people know their responsibilities, and (4) an operating cadence to keep the model current. ²

Plain-English interpretation (what the requirement is asking)

Annex A 5.2 expects your security program to have clear accountability. If an auditor asks, “Who approves firewall rule exceptions?”, “Who owns incident severity decisions?”, “Who accepts third-party risk?”, “Who is responsible for reviewing privileged access?”, you should be able to answer with a named role, not an ad hoc chat thread.

This is broader than an org chart. It covers:

• Decision rights (who can approve, who can grant exceptions, who can accept risk).
• Operational responsibilities (who runs access reviews, incident response, vulnerability management).
• Governance responsibilities (who owns the ISMS, who maintains policies, who reports to leadership).

Who it applies to

Entity scope: Any organization implementing an ISMS aligned to ISO/IEC 27001, especially service organizations that must demonstrate consistent control operation to customers and auditors. ²

Operational contexts where this control is tested hard:

• Rapid growth, reorganizations, or M&A where responsibilities drift.
• Material reliance on third parties for hosting, SOC, IT, or development (shared responsibility confusion).
• Multiple product lines or environments (prod vs. non-prod) with unclear ownership.
• Regulated customers (financial services, healthcare) that ask for specific accountability proof in diligence.

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

1) Define the minimum set of security roles you must explicitly assign

Start with roles that map to how security work is executed. A practical baseline:

• ISMS owner (overall accountability for the management system)
• Information Security Officer / Security Lead (security program execution)
• Risk owner(s) by domain (product, infrastructure, corporate IT)
• Asset owners (systems, applications, data sets)
• Data owner / business owner for sensitive data domains
• Incident manager (and backups)
• Access approvers for privileged access and key systems
• Third-party relationship owners (business owners) and third-party risk approvers
• Change management approvers (for security-impacting changes)

Write down names or position titles, but make sure there is a path to a person in your HR directory.

2) Build a RACI that connects roles to security processes (not just documents)

Auditors test “operation,” so map responsibilities to the workflows that generate evidence. Cover, at minimum:

• Policy management (draft, review, approve, exceptions)
• Risk assessment and risk treatment decisions
• Security incident intake, triage, escalation, external communications
• Access management (provisioning, deprovisioning, privileged access)
• Vulnerability management (triage, patching SLAs, exception acceptance)
• Secure change management (security review gates, emergency change handling)
• Third-party onboarding, monitoring, and offboarding

Deliverable: a one-page matrix that shows Responsible / Accountable / Consulted / Informed for each workflow step. Keep it readable; if it becomes a spreadsheet nobody uses, it will fail in practice.

3) Assign decision rights and exception authority explicitly

This is where many programs break. Define:

• Who can approve security exceptions (by type: access, vulnerability, encryption, logging).
• Who can accept residual risk for a given system or third party.
• What happens when the “Accountable” role disagrees with “Responsible.”

Make the decision rights discoverable (policy section, intranet page, or GRC system record).

4) Align role assignments with HR/job descriptions and onboarding

To make roles “real,” connect them to:

• Job descriptions for security leadership and key operational roles.
• Onboarding checklists for managers: “You are the asset owner for X; here are your responsibilities.”
• Role-based training where needed (incident commander training, access approver training).

Evidence that matters: emails/announcements, onboarding acknowledgments, training completion records where applicable.

5) Embed responsibilities into the tools people already use

Good operators wire responsibilities into workflows:

• Ticketing queues with assigned owners for incidents and vulnerabilities.
• Access request systems with named approvers.
• Third-party intake forms that require a business owner and risk approver before procurement proceeds.
• Change management templates with a “security impact” field and required security approver for defined triggers.

This makes your RACI provable because approvals and assignments become system records.

6) Create a control card and minimum evidence bundle (make it auditable)

Use a “control card” format so Annex A 5.2 is runnable, not aspirational. Recommended structure:

• Objective
• Scope (entities, systems, third parties)
• Control owner
• Inputs (org chart, system inventory, third-party list)
• Trigger events (reorg, new system, new third party, key role departure)
• Operating steps
• Exception rules
• Evidence produced and where it is stored This aligns to common audit expectations for clear ownership and traceable operation. ²

Then define the minimum evidence bundle you will produce each cycle:

• Current roles & responsibilities matrix (versioned)
• Approval record (who approved, when)
• Communication record (who was notified)
• Review log (periodic review outcomes, changes made)
• List of role holders (or link to HR directory entries) This reduces “scramble evidence” during audits. ²

7) Run recurring control health checks and track remediation to closure

You need a cadence to prove maintenance, not a one-time document drop. A lightweight health check asks:

• Are named role holders still in-seat?
• Do workflows still route to correct approvers?
• Have we added systems/third parties without assigning owners?
• Are exception approvals happening outside the defined authority?

Track gaps as remediation items with owners and closure evidence. This supports sustained operation. ²

Required evidence and artifacts to retain

Keep artifacts in a single, audit-friendly location (GRC tool, ISMS repository). Minimum set:

• Roles & responsibilities document (or RACI), version-controlled
• ISMS governance charter (or equivalent) showing accountability structure
• Approval evidence (meeting minutes, signed approval, ticket approvals)
• Communication evidence (announcement, intranet update, training notice)
• Role assignment roster (names/titles for key responsibilities, with backups)
• Process/workflow configuration evidence (screenshots or exports from ticketing/access tools showing assigned approvers/queues)
• Periodic review record and change log
• Open/closed remediation log for gaps found in health checks ²

Common exam/audit questions and hangups

Auditors and customer assessors tend to press on these points:

• “Show me who is accountable for the ISMS and how that accountability is exercised.” ²
• “Pick a critical system: who is the asset owner, who approves access, who accepts vulnerability exceptions?”
• “How do you keep role assignments current after org changes?”
• “Do third parties change your responsibilities? Who owns the relationship and security outcomes?”
• “Prove people follow the model: show recent access approvals, incident escalation, and exception approvals.”

Hangups that trigger findings:

• RACI exists, but tickets show different approvers or ad hoc decisions.
• No backup roles; vacations become control failures.
• Responsibilities are assigned to committees with no accountable individual.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: “Shared responsibility” as a substitute for assignment.
   Fix: map responsibilities across internal teams and third parties, then name the internal accountable owner for each outcome (incident response, logging, access).

2. Mistake: RACI that covers policies but not operations.
   Fix: include end-to-end workflows (access, incident, vuln, third-party) and tie them to system records.

3. Mistake: No trigger-based updates.
   Fix: define trigger events (role departures, new system, new third party) and require a roles review as part of those workflows.

4. Mistake: Titles without people.
   Fix: keep a roster that resolves titles to current incumbents and backups, with a review log.

5. Mistake: Evidence scattered across inboxes.
   Fix: define the evidence bundle and store it centrally each time the control is executed. ²

Enforcement context and risk implications

ISO 27001 is a certifiable standard, not a regulator. Your exposure shows up as:

• Certification risk: auditors issue nonconformities when accountability and maintenance can’t be demonstrated. ²
• Contract and customer risk: enterprise customers often ask who owns incident response, data protection, and third-party risk; unclear answers slow deals and raise security addenda requirements.
• Operational risk: unclear decision rights delay containment during incidents and increase the chance of unapproved exceptions becoming “permanent.”

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

Time boxes are guidance for sequencing, not guaranteed durations.

First 30 days (Immediate stabilization)

• Identify the control owner for Annex A 5.2 and publish a draft control card. ²
• Inventory critical workflows: incident, access, change, vulnerability, third-party intake.
• Draft a RACI limited to those workflows; assign accountable owners and backups.
• Pick one system (high-impact) and validate the RACI against real approvals in tickets.

By 60 days (Operational wiring)

• Update policy/ISMS governance docs to reference the responsibility model and exception authority.
• Configure tooling so tickets and access requests route to the named approvers/queues.
• Roll out communications: managers and role holders get a short responsibilities brief and where to find it.
• Define the minimum evidence bundle and create a repeatable storage location. ²

By 90 days (Prove operation and maintenance)

• Run the first control health check; log gaps and remediation owners. ²
• Perform a tabletop test: incident escalation and decision rights, capturing artifacts.
• Review third-party relationships: confirm internal relationship owners and security accountability for each key third party.
• Prepare an audit packet: latest RACI, approvals, communications, workflow screenshots, health check results.

Where Daydream fits naturally: If you are struggling to keep ownership, triggers, and evidence consistent across teams, Daydream can house the Annex A 5.2 control card, enforce the minimum evidence bundle, and track health-check remediation to closure so audits don’t turn into a document hunt.

Frequently Asked Questions

Do we need a CISO to meet annex a 5.2: information security roles and responsibilities requirement?

No. You need clearly assigned responsibilities and decision rights, including an accountable owner for the ISMS and security operations. A security lead or equivalent role can meet the requirement if authority and accountability are explicit. ²

How detailed should the RACI be?

Detailed enough that a specific security outcome has a single accountable role and the workflow shows who approves what. If you cannot use it to answer “who approves this exception” or “who escalates this incident,” it is too high-level.

Can we assign responsibilities to a team instead of an individual?

You can list a team as “Responsible” for execution, but assign “Accountable” to a single role that resolves to a person. Audits commonly fail where accountability is diffuse and approvals are inconsistent. ²

How do third parties affect this control?

Outsourcing does not outsource accountability. Document what the third party does, then name the internal owner who is accountable for the outcome and who monitors performance, incidents, and exceptions.

What evidence is most persuasive in an audit?

System records that show responsibilities in action: access approvals, incident escalations, exception approvals, and change records mapped to the RACI. Pair those with a version-controlled responsibility matrix and review log. ²

How often should we review roles and responsibilities?

Review on trigger events (role changes, reorg, new critical system, new key third party) and on a recurring cadence that fits your governance rhythm. Keep a review log so you can prove the control is maintained. ²

Footnotes

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

2. ISO/IEC 27001 overview