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ISO 27001 controls
Control 5.23 treats a cloud service as something you enter, run and eventually leave.
The 2022 edition added a control just for cloud services. It asks you to set out how you pick a provider, how responsibility is split, how you configure and watch the service, and how you would get out. Most companies already do part of this. The gap is usually the written split of duties and a credible exit.
Back to ISO 27001 services01 · What it asks
A control for the way most companies now run IT
New in 2022, and close to the supplier controls.
- 5.23Information security for use of cloud servicesSet the rules for acquiring, using, managing and exiting cloud services, matched to your security needs.
A cloud provider is a supplier, so the supplier controls (5.19 to 5.22) still apply. Control 5.23 adds what is particular to cloud: the provider runs part of the stack, the customer runs the rest, and the line between them changes with every service model. The control wants that line written down and the customer's half actually done.
It covers every cloud service in scope, not only the main hosting platform. A single SaaS tool that holds customer records is in scope too.
02 · Lifecycle
Five phases from choosing to leaving
Each phase leaves a record an auditor can read.
Select
Decide what the service will hold and check the provider can protect it.
- What happens
- Classify the data the service will hold
- Review the provider's assurance and data locations
- Compare against your cloud policy requirements
- You get
- A short selection record with the decision and its owner
- Good practice
- Assurance scope checked against the exact service
- Watch for
- Buying on a card before anyone asks what data goes in
Agree
Fix the terms and the split of duties.
- What happens
- Read the provider's shared-responsibility statement
- Map each duty to provider, you or both
- Note gaps in standard terms
- You get
- A responsibility map
- Signed terms or a recorded risk decision
- Good practice
- Every customer duty has a named owner
- Watch for
- Assuming the provider handles backups or logging by default
Onboard
Set up the service securely before real data arrives.
- What happens
- Apply single sign-on and multi-factor sign-in
- Apply the configuration baseline
- Turn on logging and alerts
- You get
- A configured tenant that matches the baseline
- Good practice
- Admin accounts kept separate and few
- Watch for
- Production data loaded during a trial on default settings
Operate
Keep the configuration where you set it.
- What happens
- Check for drift from the baseline
- Review admin access
- Track provider notices and changes
- You get
- Drift reports, access reviews, change notices handled
- Good practice
- Automated checks where the platform offers them
- Watch for
- One-off hardening never checked again
Exit
Be able to leave without losing data or leaving copies behind.
- What happens
- Know the export format and method
- Plan the move to an alternative
- Get deletion confirmed
- You get
- An exit plan, and on exit a deletion record
- Good practice
- Export tested once, not just read about
- Watch for
- Discovering the export limits during a dispute
04 · Baselines
Configuration baselines and watching for drift
Write the settings down once; check them often.
A configuration baseline is the set of settings a service must keep: who can be an administrator, how sign-in works, whether storage is private by default, which logs are on and where they go, how long they are kept. Public benchmarks for the major platforms are a sound starting point. Adjust them to your risk and record why.
- Identity. Single sign-on, multi-factor sign-in for every human, a small set of break-glass accounts kept apart.
- Storage. Private by default, encryption on, public sharing an exception with an approval.
- Logging. Administrative activity logged to a place the service's own admins cannot erase.
- Network. Management interfaces not open to the internet without a reason that is recorded.
- Keys and secrets. Who controls encryption keys, and where secrets are stored.
05 · Small vs large
What proportionate looks like
Scale the method, not the intent.
Small company
One platform, a handful of SaaS tools
- A one-page cloud policy that names approved services and who may buy new ones
- A responsibility map per main platform, kept beside the provider's own statement
- The provider's built-in posture checks used as the drift report
- An exit note per critical service: export method, format, alternative
Large company
Several platforms and many teams
- Cloud services approved through architecture review before procurement
- Baselines written as code and enforced at deployment
- A posture management tool reporting drift to service owners
- Exit plans for critical services rehearsed, with data portability checked
06 · Evidence
Evidence and the usual gaps
What a reviewer asks to see for 5.23.
- The cloud policy or the section of the supplier policy that covers cloud
- A list of cloud services in scope, each with an owner and the data it holds
- The responsibility map for a sampled service
- The baseline and a recent drift or posture report, with fixes traced
- The exit plan for a critical service
- Only the main platform listed. SaaS tools holding customer data sit inside 5.23 too, and auditors find them in the expense records.
- Provider report treated as cover. The provider's assurance covers its half. Your half needs its own evidence.
- Exit plan as a sentence. "We would migrate" is not a plan. Name the format, method and destination.
- Baseline with no check. A written standard that no report ever compares against is an intention, not a control.
Sources: ISO/IEC 27001:2022 Annex A control name 5.23 and its supplier neighbours 5.19 to 5.22; ISO/IEC 27002:2022 as background (not quoted); ISO/IEC 27017 on information security controls for cloud services; the major cloud providers' published shared-responsibility statements for the general pattern. The table and phases are our own illustration.
Cloud control questions
Does 5.23 apply if we only use SaaS?
Yes. Every cloud service in scope counts.
The control is about using cloud services of any kind. A SaaS-only company still chooses providers, configures tenants, manages access and needs a way out. The provider simply runs more of the stack.
Do we need ISO/IEC 27017 to meet 5.23?
No. It is guidance you may use.
ISO/IEC 27017 is a code of practice for cloud security. It can help you design controls, and some providers are assessed against it. It is not required for an ISO 27001 certificate.
How detailed must the exit plan be?
Enough that someone else could follow it.
For each critical service, record how data is exported, in what format, where it would go, and how you would confirm deletion. Testing an export once makes the plan far more credible.
Is the provider's SOC 2 or ISO certificate our evidence?
For their half only.
It shows the provider runs its controls. The auditor will still look at your configuration, access and logging, because those sit on your side of the line.
Related guides
Draw the line between you and your cloud provider before an audit does.
An ISO 27001 gap analysis checks your cloud services against 5.23: the responsibility map, baselines and exit plans.