ISO 27001 controls

An incident plan earns its keep in the first hour. Annex A asks you to prove it would.

Five organizational controls and one people control cover security incidents: preparing, deciding what counts, responding, learning, and keeping evidence, plus a way for anyone to report what they see. An auditor will not wait for a real incident. They read the plan, sample the log, and look for a drill.

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01 · The controls

Six controls along one timeline

From the report that starts it to the lesson that ends it.

  1. 6.8
    Information security event reportingGive everyone a simple, known route to report something that looks wrong, quickly.
  2. 5.24
    Information security incident management planning and preparationDecide roles, procedures and contacts before anything happens.
  3. 5.25
    Assessment and decision on information security eventsLook at each reported event and decide whether it is an incident, and how serious.
  4. 5.26
    Response to information security incidentsContain, fix and recover according to the procedures you wrote.
  5. 5.27
    Learning from information security incidentsFeed what each incident taught back into controls and risk.
  6. 5.28
    Collection of evidenceGather and keep evidence in a way that holds up if it is needed later.

An event is anything worth a look: an odd login, a lost laptop, an alert. An incident is an event you have judged to harm, or to threaten, the confidentiality, integrity or availability of information. Control 5.25 is the gate between them, and auditors check that the gate has written criteria.

02 · Roles

Who does what when it starts

Names in advance, deputies included.

Incident lead
Owns the response from triage to closure, makes the calls, keeps the timeline.
Technical responders
Investigate, contain and restore. Usually engineering or an outside response firm.
Communications owner
Speaks for the company to staff, customers and partners, using approved wording.
Legal and privacy
Decides on regulatory and contractual notices, and on handling of evidence.
Executive sponsor
Approves spending, shutdowns and external statements above the lead's authority.

In a small company one person may wear three of these hats. That is fine if the plan says so and names a deputy for each.

03 · Severity

Severity levels that drive decisions

Illustrative levels; set yours by impact, not by alarm.

LevelIllustrative triggerWho is involvedNotice duties to check
Severity 1Confirmed access to customer or regulated data, or a core service down for customersFull team and executive sponsorCustomers, regulators and any authority with a reporting rule
Severity 2Likely compromise of an internal system, contained, no confirmed data access yetIncident lead and technical responders, legal informedAssess against contracts and regulation; keep the decision record
Severity 3Malware caught on one device, a phishing click with no credential useIncident lead or on-call engineerUsually none; record the reasoning
Severity 4Event reviewed and found harmlessTriage onlyNone

In India, the CERT-In directions issued under the IT Act set a short window for reporting certain incident types. Check them when you set Severity 1 and 2 notice rules; the CERT-In page in this library covers them.

04 · Response flow

A response flow, start to close

Seven steps; each leaves a line in the incident record.

  1. Report: someone sees something and uses the known route (6.8).
  2. Triage: the on-call person assesses it against written criteria and sets a severity (5.25).
  3. Mobilise: the incident lead opens a record and calls the people the severity requires.
  4. Contain: limit the spread, preserving evidence before wiping or rebuilding (5.26, 5.28).
  5. Eradicate and recover: remove the cause, restore service, watch for return.
  6. Notify: decide and send the notices that contracts and law require, with the decision recorded.
  7. Review and close: hold the post-incident review and track its actions to completion (5.27).

The post-incident review

Hold it soon, while memory is fresh, and keep it blameless: the aim is the cause, not a culprit. Cover what happened, when it was noticed and why not earlier, what worked, what slowed the team, and which controls or risks should change. Actions get owners and dates in the same tracker as other corrective work.

05 · Preserving evidence

Keeping evidence that holds up

Control 5.28, in practical terms.

  • Capture before you clean. Take disk images, memory captures or log exports before rebuilding a machine, where the severity warrants it.
  • Record the chain of custody. Who collected what, when, from where, and who has held it since.
  • Protect integrity. Hash collected files and store them where they cannot be altered.
  • Keep logs long enough. Retention that reaches back past the likely start of an intrusion.
  • Know when to call specialists. If legal action or a regulator is likely, bring in forensic help early.

Small company

Lean but written

  • A two-page plan with roles, severity table and contact list
  • A shared incident channel and a simple incident log
  • A retainer or named contact for outside forensic help
  • One tabletop exercise a year with the founders and engineering

Large company

Staffed and rehearsed

  • A security operations function with on-call rotation
  • Playbooks per incident type, linked to the ticketing system
  • Forensic tooling and evidence storage in-house
  • Regular exercises across business units, including executives

06 · Tabletop drill

A tabletop drill in five parts

Proof the plan works, without waiting for an attacker.

  1. Scenario: an illustrative case such as a support engineer's account used from an unknown country to export customer tickets.
  2. First injects: the alert arrives on a weekend. Who sees it, who is called, what severity is set?
  3. Escalation: evidence suggests data left the system. Who decides on customer notice, and on what facts?
  4. Complication: the incident lead is unreachable, or a journalist emails. Does the deputy and the comms owner act?
  5. Debrief: list gaps in the plan, contacts and tools, and log each as an action with an owner.

What an auditor samples

  • The incident plan, with roles, criteria and contacts current
  • The event and incident log, and a sample of entries traced from report to closure
  • A post-incident review and evidence that its actions were finished
  • A drill record: scenario, attendees, findings, actions
  • Proof that staff know how to report, such as awareness material or a reporting channel in use
  • An empty log. No events recorded at all usually means nobody reports, not that nothing happened.
  • Severity set by feel. Without written criteria, triage cannot be tested and 5.25 is weak.
  • Reviews with no follow-through. Actions agreed and never closed undo the point of 5.27.
  • Contacts out of date. A plan listing someone who left is the first thing a drill or an auditor finds.
  • Evidence wiped in the rush. Rebuilding before capturing leaves nothing to examine later.

Sources: ISO/IEC 27001:2022 Annex A control names 5.24 to 5.28 and 6.8; ISO/IEC 27002:2022 as background (not quoted); NIST SP 800-61 on computer security incident handling and response; the ISO/IEC 27035 series on incident management; ISO/IEC 27037 on handling digital evidence; CERT-In directions under section 70B of the IT Act, 2000, named only. Severity levels, flow and drill are our own illustration.

Incident management questions

Do we need a real incident before the certification audit?

No. A drill shows the plan works.

Auditors cannot demand an incident. They look for a plan, a log of events, and evidence that the plan has been exercised, for example a tabletop drill with recorded findings.

Is every phishing email an incident?

No. It is an event until triage says otherwise.

A reported phishing email is an event. If no one clicked or entered credentials, triage may close it as harmless. Record the decision either way so the log shows that 5.25 works.

Can we outsource incident response?

The work, yes. The ownership, no.

Many companies keep a retainer with a response firm. The plan must still say when and how you call them, and someone inside must lead decisions about notice and recovery.

How long should incident records be kept?

As long as your retention rules and the law require.

Set a period in your records policy that covers legal claims, contracts and regulators. Keep evidence collected under 5.28 at least as long as any related proceeding could run.

Test the incident plan before an attacker or an auditor does.

An ISO 27001 gap analysis reviews your plan, log and drills against 5.24 to 5.28 and 6.8, and can include a facilitated tabletop.