Annex A 5.24: Information Security Incident Management Planning and Preparation

Annex a 5.24: information security incident management planning and preparation requirement expects you to pre-plan incident handling so response is consistent, timely, and testable, not improvised. Operationalize it by documenting roles, escalation paths, tools, communications, and readiness activities (training, exercises, logging) and by retaining recurring evidence that the plan is maintained and practiced. ¹

Key takeaways:

• Build a prepared incident management capability: defined roles, runbooks, escalation, communications, and tooling mapped to incident types.
• Prove it runs: keep evidence of exercises, training, on-call readiness, and post-incident improvements.
• Treat third parties as part of the plan: notification triggers, coordination steps, and contract hooks.

Annex A 5.24 sits in the “Organizational” controls of ISO/IEC 27001:2022 and focuses on readiness. Assessors will look for two things: (1) a planned, repeatable approach to manage information security incidents, and (2) proof that the approach is prepared in advance, maintained, and actually works under pressure. The control is less about writing an “incident response policy” and more about building the operational muscle to execute it.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to define the minimum viable incident management “system”: governance (who decides), workflow (how incidents move from detection to closure), communications (who must be told and when), and preparedness (training, exercises, and tooling). Then, capture evidence on a schedule so you can pass an ISO audit without scrambling.

This page gives requirement-level implementation guidance you can hand to security operations, IT, privacy, legal, and key third parties. It also includes audit questions you should pre-answer, and a practical 30/60/90-day plan to stand up and stabilize compliance. ²

Regulatory text

Provided excerpt: “ISO/IEC 27001:2022 Annex A control 5.24 implementation expectation (Information Security Incident Management Planning and Preparation).” ¹

Operator interpretation (what you must do): You must plan and prepare how your organization manages information security incidents before they occur. That means you define the incident management approach, the people and responsibilities, the escalation and communications paths, and the supporting resources (tools, access, contacts, templates). You also maintain readiness through training, exercises, and continual improvement so incident handling is consistent and not dependent on individual heroics. ²

Plain-English interpretation of the requirement

Annex A 5.24 expects a “ready-to-run” incident management capability:

• Planned: You have documented processes and playbooks for common incident scenarios.
• Prepared: The right people can be reached, have access, know what to do, and have tools/templates ready.
• Repeatable and governable: Triage, severity rating, escalation, approvals, and communications follow a defined pattern.
• Maintained: The plan is reviewed, tested, and improved based on incidents and exercises.

A clean way to explain it to executives: “We can detect, assess, respond to, communicate about, and learn from security incidents using an established workflow, not ad hoc decision-making.” ¹

Who it applies to (entity and operational context)

Applies to: Any organization implementing ISO/IEC 27001:2022, including service organizations handling customer data, production systems, regulated data, or business-critical services. ¹

Operational contexts where assessors press hardest:

• Customer-facing services (SaaS, managed services, platforms): You must coordinate communications, containment, and recovery without extended downtime.
• Hybrid environments: Cloud + endpoints + identity systems require cross-team playbooks and shared logging.
• Third-party dependencies: If your service relies on cloud providers, MSPs, payment processors, or critical software suppliers, incident planning must include coordination and notification steps with those third parties.

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

1) Define your incident management scope and trigger criteria

• Write a short scope statement: which systems, data types, and business units are in scope.
• Define what counts as an “information security incident” for your organization (examples: confirmed malware, unauthorized access, data exposure, lost device with sensitive data, compromised credentials, DDoS that impacts availability).
• Create intake channels: ticket category, hotline/Slack channel, email alias, and SOC/SIEM alert routing.

Audit-ready output: Incident Management Standard (1–3 pages) with scope, definitions, and entry points.

2) Establish governance: roles, responsibilities, and decision rights

Create a RACI that includes:

• Incident Commander / Response Lead (overall coordination)
• Security Operations (triage/containment/forensics coordination)
• IT/Cloud Ops (system changes, isolation, restores)
• Legal (privilege, liability, law enforcement interface where applicable)
• Privacy (personal data impact assessment where applicable)
• Comms/PR (external statements, customer messaging)
• Customer Success / Account teams (customer coordination)
• Executives (severity-based notification and approvals)

Document explicit decision rights: who can declare severity, who can approve customer notification language, who can authorize emergency changes. ¹

Operator tip: If you do not name a primary and backup for each critical role, you do not have preparedness.

3) Build severity levels and escalation paths

• Define severity levels with clear criteria (impact scope, data sensitivity, service availability, likelihood of active exploitation).
• Define time-based internal escalation expectations as policy guidance (do not invent regulatory timelines). What matters is that you can show timely escalation aligned to risk.
• Map each severity to required participants (war room roster) and executive notification thresholds.

Artifact: Severity matrix + escalation tree (including after-hours).

4) Pre-stage communications and coordination (internal + external)

Prepare templates:

• Internal incident update format (what happened, what’s impacted, what’s done, next steps, owner, next update time).
• Customer notification template(s) for service impact and security exposure scenarios.
• Third-party notification template(s): what logs/artifacts you request, points of contact, escalation route.

Maintain a current contact directory:

• On-call rotations
• Third-party security contacts (cloud provider support, key software providers)
• Cyber insurance contact (if applicable)
• External forensics firm (if retained)

Common hangup: Teams draft templates but never approve them. Get Legal/Comms review up front so you are not negotiating language mid-incident.

5) Create scenario-based playbooks (runbooks) for your top incident types

Minimum set is environment-dependent, but common playbooks include:

• Credential compromise / identity takeover
• Malware / ransomware suspicion
• Cloud key exposure
• Data exposure / misconfiguration
• Insider misuse suspicion
• Third-party breach affecting your service

Each playbook should include:

• Detection signals and data sources
• Immediate containment actions (with safeguards to avoid destructive steps)
• Evidence preservation steps (logs, snapshots, chain-of-custody approach)
• Investigation checklist
• Recovery steps and validation
• Communications checkpoints
• Closure criteria and post-incident review steps

Daydream fit (earned mention): Teams often fail audits because they cannot show recurring evidence that playbooks are maintained and exercised. A system like Daydream helps map Annex A 5.24 to control operations and schedules evidence capture so readiness is continuously provable, not reconstructed at audit time. ²

6) Verify tooling and access readiness

Preparedness is practical:

• Confirm log sources and retention are adequate for investigations (you should at least know what logs exist, where they live, and who can query them).
• Confirm emergency access paths (break-glass accounts, privileged access workflows).
• Confirm secure collaboration channels for incident response (restricted chat, doc space).
• Confirm ability to isolate hosts, rotate keys, revoke sessions, and block indicators.

Evidence: Access review for incident responders; list of tools and owners; screenshots/config exports where appropriate.

7) Train, exercise, and improve

• Train responders and supporting functions on roles, escalation, and playbooks.
• Run tabletop exercises that test decision-making and communications, not just technical containment.
• After real incidents and exercises, capture lessons learned and track remediation actions to closure.

Assessor expectation: You can show a feedback loop: plan → practice → improve. ¹

Required evidence and artifacts to retain

Keep artifacts in a controlled repository with version history:

• Incident Management Policy/Standard and incident handling procedure
• RACI, on-call roster, and contact directory (including third parties)
• Severity matrix and escalation paths
• Approved communication templates (internal and external)
• Playbooks/runbooks for major scenarios
• Training records (agenda, attendance, materials)
• Exercise records (tabletop plan, participants, results, action items)
• Post-incident reviews (PIRs) and corrective action tracking
• Sample incident tickets showing workflow fields (classification, severity, timestamps, approvals, closure)

Evidence strategy: “Recurring evidence capture” matters. A single policy PDF does not prove preparedness over time. ¹

Common exam/audit questions and hangups

Auditors commonly probe:

• “Show me how an alert becomes an incident, who decides severity, and where that is documented.”
• “How do you ensure after-hours coverage and backups for key roles?”
• “Show evidence of at least one exercise and the resulting improvements.”
• “How do you coordinate incidents involving third parties? Where are contacts and notification steps documented?”
• “How do you preserve evidence and control access to incident records?”

Hangups that trigger nonconformities:

• Playbooks exist but are outdated, unapproved, or not accessible to responders.
• No proof of exercises or training.
• Incidents tracked in informal chat without a system of record.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Writing a high-level policy only	Policy does not equal preparedness	Add playbooks, contacts, access readiness checks, and exercises
No clear incident commander	Decisions stall during escalation	Assign primary/backup; document decision rights
Third parties excluded	You cannot investigate supply-chain incidents quickly	Add third-party contact list and notification runbook
No evidence retention plan	You cannot prove operation	Define required artifacts; store in one repository with retention
Exercises are “technical only”	Communications and governance fail under pressure	Include Legal, Privacy, Comms, execs in tabletops

Enforcement context and risk implications

ISO 27001 is a certifiable standard; “enforcement” typically occurs through certification audits, customer requirements, and contractual remedies rather than regulator penalties. The operational risk is straightforward: weak planning increases containment time, increases the chance of inconsistent external communications, and increases evidentiary gaps that complicate root cause analysis and customer/regulatory notification decisions. ¹

Practical 30/60/90-day execution plan

Days 0–30: Stand up minimum viable readiness

• Publish Incident Management Standard with scope, definitions, and intake channels.
• Create RACI, name incident commander backups, and approve decision rights.
• Build severity matrix and escalation tree.
• Create a controlled repository for incident artifacts and templates.

Exit criteria: You can explain the workflow end-to-end and show where every artifact lives.

Days 31–60: Operationalize playbooks and communications

• Draft and approve top incident playbooks (priority based on your threat model and architecture).
• Finalize internal and external comms templates with Legal/Comms approval.
• Validate tooling readiness: logging access, break-glass, isolation, key rotation, ticketing workflow fields.
• Add third-party coordination: contacts, notification triggers, and contract hooks (where possible).

Exit criteria: Responders can follow a written runbook and know who to call, including third parties.

Days 61–90: Prove it works and close gaps

• Run at least one cross-functional tabletop exercise.
• Capture lessons learned and track corrective actions to completion.
• Train new responders and stakeholders; refresh the on-call/contact lists.
• Start recurring evidence capture (exercise cadence, policy review cadence, contact list validation).

Exit criteria: You have dated evidence of preparedness activities and improvement actions tied back to Annex A 5.24. ²

Frequently Asked Questions

Do we need a separate “Incident Management Planning and Preparation” policy for Annex A 5.24?

You need documented planning and preparation elements, but they can live in one Incident Management Standard plus supporting playbooks, templates, and rosters. Auditors care that the requirements are covered, approved, and maintained. ¹

How do we show preparedness if we have not had a major incident?

Use evidence from tabletops, training, and access/tooling readiness checks. Assessors accept exercises and simulations as proof that planning exists and is actionable. ¹

What’s the minimum set of playbooks to start with?

Start with the scenarios most likely to hit your environment: credential compromise, malware/ransomware suspicion, data exposure/misconfiguration, and third-party service compromise. Add more playbooks as your environment and threat model mature. ²

How should third parties be included under Annex A 5.24?

Maintain a third-party incident contact list, define notification triggers, and include coordination steps in your playbooks (what you ask them for, how you escalate, who approves communications). Tie this back to contract language where you can. ¹

What evidence is most likely to be missing in an ISO audit for 5.24?

Exercise records, training logs, and proof that contact lists and playbooks are reviewed and updated. Teams often have a policy but cannot show ongoing preparation activities. ¹

Can Daydream help without replacing our ticketing or SIEM?

Yes. The common gap is audit-ready evidence and control mapping, not the operational tools. Daydream can track the Annex A 5.24 control operation, assign owners, and prompt recurring evidence capture while your SOC keeps using existing systems. ²

Footnotes

1. ISO/IEC 27001 overview

2. ISMS.online Annex A control index