In-Depth Guide to Annex A 5.23
What Is Annex A 5.23 and Why Does It Matter?
Cloud services are widely adopted because they offer:
- Scalability
- Availability
- Reduced operational overhead
- Speed of deployment
However, they also introduce challenges:
- Limited contractual flexibility
- Reduced visibility of underlying infrastructure
- Shared responsibility for security controls
- Dependency on provider resilience and governance
Annex A 5.23 ensures organisations do not assume security is automatically handled by the cloud provider, and instead define how security responsibilities are split, managed, and assured.
This control builds directly on supplier and ICT supply chain controls but addresses cloud-specific characteristics.
In-Depth Guide to Annex A 5.1
What is Annex A 5.1 and Why Does It Matter?
Annex A 5.1 is a foundational governance control. It sets the tone for the entire Information Security Management System (ISMS).
Policies define:
- What the organisation values
- How security decisions are approached
- Where accountability sits
Without clear policies, security becomes inconsistent. Teams improvise. Decisions vary depending on who’s involved. Risk acceptance becomes informal and undocumented.
From a security perspective, that inconsistency is often where incidents start.
From a business perspective, unclear policies lead to friction — security teams blocking work, delivery teams bypassing controls, and leadership stepping in only when something breaks.
A well-designed policy framework:
- Aligns security with business objectives
- Supports proportionate, risk-based decisions
- Provides a reference point during incidents and disputes
- Creates consistency without bureaucracy
A common real-world scenario we see is organisations with technically strong controls but weak policy direction. When an exception arises — a supplier request, a new platform, a rushed delivery — there’s no agreed framework to guide the decision. That’s when risk is introduced quietly and unintentionally.
How to Implement Annex A 5.1 Effectively
A practical, security-first approach usually includes the following steps.
1. Define a Comprehensive Information Security Policy
Policies exist to set direction, not to document every control.Start by being clear about what your policies are there to achieve:
- 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
Leadership support is critical. Without it, policies remain words on paper without real enforcement. Senior executives should:
- Review and approve policies.
- Ensure resources are allocated for implementation.
- Lead by example in enforcing security policies.
3. Communicate and Train Employees
A policy is useless if no one reads or understands it.
- 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
Information security threats evolve, and so should your policies.
- 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
Your information security policy should be the backbone of your ISMS (Information Security Management System).
- 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
|
| Control Structure | Two separate controls: 5.1.1 & 5.1.2 | Merged into one control (5.1) |
| Implementation Guidance | Less prescriptive | More detailed guidance for policy creation and alignment |
| Awareness & Training | Not explicitly mentioned | Explicitly requires policies to be part of training programmes |
| Attributes Table | Not included | ew attributes table for mapping policies to industry terms |
The new approach in ISO 27001:2022 ensures that policies are not just created but actively integrated into business operations, improving security culture across organisations.
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.
By embedding strong security policies into your business operations, you don’t just tick a compliance box—you build a robust security posture that protects your organisation from real-world threats.
