ISO 27001:2022 Annex A 5.29 – Information Security During Disruption Explained

Disruption changes priorities — security must not be one of them.

Annex A 5.29 exists to ensure organisations maintain and restore information security during business disruptions, rather than allowing controls to weaken at the moment risk is highest.

This control connects information security directly to business continuity, recognising that disruption increases exposure, uncertainty, and the likelihood of error.

ISO 27001

Quick Guide: Annex A 5.29 at a Glance

Annex A 5.29 of ISO 27001:2022 focuses on maintaining information security during disruptive events.

At a practical level, this means:

  • Integrating information security into business continuity planning
  • Maintaining appropriate security controls during disruption
  • Applying alternative or substitute controls where normal controls cannot operate
  • Protecting confidentiality, integrity, and availability under abnormal conditions
  • Restoring security levels promptly after disruption

The control does not prescribe a single continuity model or detailed recovery steps. It expects organisations to consider how information security is sustained when normal operations are disrupted.

In-Depth Guide to Annex A 5.29

What Is Annex A 5.29 and Why Does It Matter?

Business disruptions can arise from many causes, including:

  • System failures
  • Cyber incidents
  • Physical incidents
  • Loss of facilities or staff
  • Supply chain disruption

During these periods:

  • Controls may be bypassed to restore operations
  • Oversight may be reduced
  • Temporary processes may be introduced
  • Information may be handled outside normal environments

Annex A 5.29 ensures that information security remains a deliberate consideration, even when continuity and recovery pressures are high.

Without this focus, disruption often becomes the trigger for secondary security incidents.

How to Implement Annex A 5.29 Effectively

A pragmatic approach to Annex A 5.29 typically includes the following elements.

1. Integrate Information Security into Continuity Planning

Information security should form part of the organisation’s broader business continuity and resilience planning.

This includes considering:

  • How core security controls operate during disruption
  • Which controls are critical and must be sustained
  • Which controls may require alternative approaches

Security should be designed into continuity, not added later.

2. Identify Security Risks Introduced by Disruption

Disruption often introduces specific security risks, such as:

  • Increased remote or emergency access
  • Use of temporary systems or locations
  • Reduced segregation of duties
  • Increased reliance on third parties

Identifying these risks in advance supports proportionate planning.

3. Define Substitute or Compensating Controls

Some controls may not be sustainable during disruption.

Where this occurs, organisations should consider:

  • Temporary or compensating controls
  • Increased monitoring or oversight
  • Restricted scope or duration of emergency access

Substitute controls should be planned, not improvised.

4. Maintain Protection of Confidentiality and Integrity

ISO 27001:2022 Annex A 5.29 places particular emphasis on:

  • Preventing unauthorised disclosure of information
  • Maintaining accuracy, reliability, and integrity of information

Disruption increases the likelihood of accidental disclosure and data integrity errors if controls are weakened without oversight.

5. Restore Security Levels Promptly After Disruption

Once disruption is resolved, security controls should be:

  • Reviewed
  • Reinstated
  • Verified

Temporary measures should not become permanent by default. Restoration is a defined activity, not an assumption.

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.

Practical Considerations

Continuity planning varies widely between organisations.

Annex A 5.29 deliberately allows flexibility, but expects organisations to consider:

  • Different disruption scenarios
  • Varying durations and severity
  • The impact on information handling and systems

The control does not require identical treatment for every scenario, but it does require conscious design and decision-making.

Common Challenges and How to Overcome Them

  • Focusing only on availability during disruption
  • Consider confidentiality and integrity as well
  • Bypassing controls without oversight
  • Plan substitute controls in advance
  • Allowing temporary access to persist
  • Review and remove emergency access promptly
  • Treating security restoration as automatic
  • Actively verify post-disruption security state

Disruption amplifies weaknesses — planning reduces that amplification.

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 5.29 is about maintaining security discipline under abnormal conditions.

When information security is embedded into continuity planning:

  • Disruption does not automatically increase exposure
  • Emergency actions remain controlled
  • Recovery is cleaner and faster
  • Secondary incidents are less likely

Disruption is inevitable.
Loss of information security does not have to be.

Annex A 5.29 ensures organisations protect information when conditions are least forgiving.

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