ISO 27001:2022 Clause 5.3: Organisational Roles, Responsibilities and Authorities

ISO27001-2022 Clause 5.3 Organisational Roles, Responsibilities and Authorities

The Definitive Governance Requirement.

Clause 5.3 mandates that Top Management must ensure that the responsibilities and authorities for roles relevant to information security are assigned and communicated. You cannot have a “shadow” security team. Accountability must be formalised, documented, and understood.

The Mandate

A policy without an owner is just paper. The standard requires you to explicitly define who is running the ship. Top management cannot simply say “IT handles it.” They must assign specific authorities to:

  1. Ensure Conformance: Someone must be accountable for ensuring the ISMS conforms to the ISO 27001 standard.
  2. Report Performance: Someone must be accountable for reporting on the performance of the ISMS to Top Management.

The Verdict: This does not require you to hire a CISO. It requires you to assign the function of a CISO to a competent individual.

The Implementation Strategy

Clarity is your defense. Ambiguity is your liability.

  1. Define the Hierarchy: Create an organizational chart that clearly visualizes the reporting lines for information security.
  2. Update Job Descriptions: You must modify the contract or job description of the relevant individuals. Add “Responsibility for ISMS maintenance” explicitly.
  3. Segregation of Duties: Ensure that the person checking the work is not the person doing the work. The “Auditor” cannot be the “Implementer.”
  4. Communication: Announce these roles to the organization. If a staff member spots a breach, they must know exactly who to call.

The Auditor’s Trap

[The Auditor’s View] The most common Major Non-Conformance here is the “Universal Scapegoat.” We often see organizations claim “Security is everyone’s responsibility.” While philosophically true, legally it is nonsense. If everyone is responsible, no one is accountable. I need to see a specific name attached to the specific duty of ‘ISMS Performance Reporting’.

Required Evidence

An auditor looks for the “Chain of Command.”

  • Organizational Chart: Visual proof of the hierarchy.
  • Job Descriptions / Roles Matrix: Signed documents detailing specific security duties.
  • Appointment Letters: Formal designations for roles like “Information Security Manager” or “Privacy Officer.”
  • RACI Matrix: A chart showing who is Responsible, Accountable, Consulted, and Informed.

Strategic Acceleration

Defining roles from scratch usually leads to gaps in coverage or overlapping duties. You need a structure that ensures nothing falls through the cracks.

The Hightable™ Roles & Responsibilities Matrix is pre-configured to cover all ISO 27001 requirements. It maps the standard’s clauses to specific job titles, ensuring 100% coverage.

The Next Move: Deploy the Roles Matrix