ISO 27001:2022 Annex A 5.2 – Information Security Roles and Responsibilities Explained

Information security fails far more often because of unclear ownership than weak technology. Annex A 5.2 exists to address that problem.

This control focuses on ensuring that information security responsibilities are clearly defined, understood, and applied across the organisation.

Not concentrated in IT. Not assumed. And not left to interpretation when something goes wrong.When roles are unclear, accountability disappears. When accountability disappears, risk increases quietly.

ISO 27001

Quick Guide: Annex A 5.2 at a Glance

Annex A 5.2 of ISO 27001:2022 is concerned with defining and assigning information security roles and responsibilities in a way that fits the organisation’s size, structure, and risk profile.

At a practical level, this means:

  • Making it clear who is responsible for information security activities
  • Ensuring responsibilities are assigned at both a general and specific level
  • Aligning security responsibilities with existing job roles
  • Avoiding assumptions that “security belongs to IT”
  • Ensuring people understand what they are accountable for

The control does not prescribe job titles, reporting lines, or organisational charts. It also does not require dedicated security roles in every organisation.

Instead, it focuses on clarity and ownership.

In smaller organisations, information security responsibilities are often distributed across existing roles. In larger organisations, responsibilities may be more specialised. Both approaches are valid if accountability is clear and proportionate.

The outcome Annex A 5.2 is aiming for is simple:
people know what they are responsible for, and security tasks do not fall through gaps.

In-Depth Guide to Annex A 5.2

What Is Annex A 5.2 and Why Does It Matter?

Annex A 5.2 is a governance control that underpins how information security is implemented day to day.

Security controls do not operate themselves. They rely on people to:

  • Design them
  • Apply them
  • Maintain them
  • Review them
  • Challenge them when something changes

Without clearly defined roles and responsibilities:

  • Security decisions are delayed or avoided
  • Tasks are duplicated or missed
  • Incidents escalate because no one is sure who owns the response
  • Risk acceptance becomes informal and undocumented

A common real-world issue is organisations assuming that security ownership sits entirely with IT. In practice, information security spans HR, operations, finance, legal, development, and leadership.

Annex A 5.2 helps ensure that security is treated as an organisational responsibility, not a technical afterthought.

How to Implement Annex A 5.2 Effectively

A pragmatic approach to Annex A 5.2 usually involves the following steps.

1. Identify Information Security Responsibilities

Start by identifying the activities that need ownership, such as:

  • Information asset ownership
  • Access management
  • Incident reporting and response
  • Risk management and acceptance
  • Policy ownership and review

The goal is not to list every task, but to identify where accountability sits.

2. Align Responsibilities to Existing Roles

Rather than creating new roles, most organisations assign security responsibilities to existing job functions.

For example:

  • Senior leadership providing overall direction and oversight
  • Managers ensuring security expectations are applied within their teams
  • System or asset owners being accountable for protection decisions
  • All staff being responsible for protecting information they handle

This approach keeps security integrated into business-as-usual operations.

3. Distinguish General and Specific Responsibilities

Annex A 5.2 recognises two levels of responsibility:

  • General responsibilities, such as protecting information and following policies
  • Specific responsibilities, such as approving access or managing systems

Both need to be understood, even if they are documented differently.

4. Document and Communicate Responsibilities

Responsibilities should be documented in a way that is:

  • Proportionate
  • Understandable
  • Accessible

This may be done through job descriptions, role profiles, responsibility matrices, or policy statements. The format matters less than the clarity.

Communication is critical — undocumented responsibilities tend to be forgotten.

5. Review When Things Change

As the organisation evolves, roles often change faster than documentation.

Triggers for review typically include:

  • Organisational change
  • New systems or services
  • Changes in risk profile
  • Significant incidents

Keeping responsibilities aligned with reality is key to keeping this control effective.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Common Challenges and How to Overcome Them

  • Assuming security is “owned by IT”
  • Recognise that information security spans the whole organisation
  • Over-engineering roles for small organisations
  • Keep responsibilities proportionate and aligned to existing roles
  • Responsibilities documented but not understood
  • Reinforce expectations through onboarding, awareness, and management behaviour
  • Unclear ownership during incidents
  • Ensure accountability is clear before an incident occurs

These challenges are usually governance issues, not technical ones.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Final Recommendations

Annex A 5.2 is about clarity, not complexity.

When roles and responsibilities are clear:

  • Security decisions are made faster
  • Accountability is visible
  • Incidents are handled more effectively
  • Security becomes part of normal operations

If people are unsure who owns security tasks, that uncertainty will surface at the worst possible moment.

Define ownership early, keep it proportionate, and review it when the organisation changes.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

The Annex Control Table

ISO 27001:2022 Organisational Controls
ISO 27001:2022 Technological Controls