The Definitive Governance Requirement.
Clause 5 mandates that Top Management must demonstrate leadership and commitment with respect to the Information Security Management System (ISMS). This clause ends the era of “IT Security” being solely an IT problem. It is now a Board-level liability. If the C-Suite is not visibly involved, the organization cannot be certified.
The Mandate
The standard is unambiguous: Accountability cannot be delegated. While the execution of tasks can be assigned to a CISO or IT Manager, the ultimate responsibility for the ISMS resides with the highest level of management.
Clause 5 is divided into three critical sub-statutes:
- Clause 5.1 (Leadership and Commitment): The Board must ensure the ISMS aligns with strategic business objectives and provide the necessary resources.
- Clause 5.2 (Policy): Top Management must establish, sign, and publish an Information Security Policy that sets the direction for the organization.
- Clause 5.3 (Roles, Responsibilities, and Authorities): Specific roles must be assigned to ensure the ISMS conforms to requirements and performance is reported upward.
The Verdict: An absentee Board is a non-conformity. The auditor will interview the CEO. If the CEO cannot articulate the security objectives, the audit fails immediately.
The Implementation Strategy
You must construct a governance layer that sits above the technical controls.
- The Paper Trail: You need signatures. The Policy must be signed by the CEO. The Roles Matrix must be approved by the Board.
- The Alignment: Ensure that your Information Security Objectives (Clause 6.2) map directly to Business Objectives. If the business goal is “Speed,” the security goal is “Secure Velocity,” not “Bureaucracy.”
- The Communication: Leadership must speak. Town halls, emails, and internal videos from the C-Suite reinforce that security is a core value, not a side project.
The Auditor’s Trap
[The Auditor’s View] The most common Major Non-Conformance here is “The Puppet Master.” We often see the IT Manager answering questions on behalf of the CEO during the leadership interview. If the CEO looks at the IT Manager for help when asked “How do you support the ISMS?”, it proves a lack of leadership. The CEO must own the narrative.
Required Evidence
An auditor looks for proof that the “Tone from the Top” is authentic.
- Signed Information Security Policy (5.2): The constitution of the ISMS.
- Organizational Chart & Roles Matrix (5.3): Clear definition of accountability.
- Management Review Minutes (9.3): Proof that leadership is reviewing performance.
- Budget Approvals (7.1): Evidence of resources being committed by leadership.
- Job Descriptions: Updated to include security responsibilities.
Strategic Acceleration
Building a leadership governance structure that satisfies the auditor without burdening the C-Suite requires precision drafting.
The Leadership Pack provides the executive briefs, the policy templates, and the “CEO Cheat Sheet” for the audit interview. It ensures your leadership team looks like they wrote the book on governance.
The Next Move: Deploy the Leadership Pack