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ISO 27001:2022
ISO 27001 Incident Response Requirements
Complete guide to ISO 27001 information security incident management: Controls, implementation, documentation, and audit preparation.
15 min read
ISO 27001:2022
Why ISO 27001 IR Matters
ISO 27001 is the international standard for information security management systems (ISMS). Annex A, Control A.16 specifically addresses information security incident management. Proper incident response is required for ISO 27001 certificationand demonstrates to customers, partners, and regulators that your organization handles security incidents systematically.
A.16
Control section
7
Required controls
100%
Audit coverage
ISO 27001:2022 Control A.16 Overview
ISO 27001:2022 Annex A, Section 16 defines "Information Security Incident Management" with seven specific controls that organizations must implement:
Control A.16: Information Security Incident Management
"To ensure a consistent and effective approach to the management of information security incidents, including communication on security events and weaknesses."
The 7 ISO 27001 Incident Response Controls
Detailed breakdown of each control requirement
A.16.1.1
Responsibilities and Procedures
Objective:
Establish management responsibilities and procedures to ensure a quick, effective, and orderly response
Implementation Requirements:
- Define roles and responsibilities for incident management
- Establish incident response procedures and playbooks
- Define what constitutes an "information security event" and "incident"
- Create incident categorization and prioritization criteria
- Document escalation procedures
Audit Evidence Needed:
Incident response policy documentRACI matrix for incident response rolesIncident response playbooksIncident categorization matrix
A.16.1.2
Reporting Information Security Events
Objective:
Ensure events are reported quickly through appropriate management channels
Implementation Requirements:
- Establish multiple reporting channels (email, phone, portal)
- Communicate reporting procedures to all personnel
- Define what types of events should be reported
- Ensure 24/7 reporting capability
- Track and acknowledge all reported events
Audit Evidence Needed:
Reporting procedure documentationSecurity awareness training materialsEvent reporting logs/ticketsAcknowledgment confirmations
A.16.1.3
Reporting Information Security Weaknesses
Objective:
Require personnel to note and report any observed or suspected weaknesses
Implementation Requirements:
- Create process for reporting vulnerabilities
- Establish vulnerability disclosure program
- Train staff to recognize weaknesses
- Provide safe reporting mechanism (no retaliation)
- Track and respond to all weakness reports
Audit Evidence Needed:
Weakness reporting procedureVulnerability disclosure policyTraining completion recordsWeakness report logs
A.16.1.4
Assessment and Decision on Information Security Events
Objective:
Assess events and decide if they should be classified as incidents
Implementation Requirements:
- Define criteria for event vs. incident classification
- Establish triage and assessment procedures
- Create severity/priority matrix
- Document decision-making authority
- Track assessment decisions
Audit Evidence Needed:
Event assessment criteriaTriage proceduresIncident classification matrixAssessment decision logs
A.16.1.5
Response to Information Security Incidents
Objective:
Respond to incidents in accordance with documented procedures
Implementation Requirements:
- Develop incident-specific response playbooks
- Define containment, eradication, recovery procedures
- Establish communication protocols
- Coordinate with external parties (legal, law enforcement)
- Document all response actions
Audit Evidence Needed:
Response playbooksIncident response logsCommunication recordsExternal coordination documentation
A.16.1.6
Learning from Information Security Incidents
Objective:
Use knowledge gained from incidents to strengthen controls
Implementation Requirements:
- Conduct post-incident reviews for all incidents
- Identify root causes and contributing factors
- Generate actionable recommendations
- Track remediation actions to completion
- Update procedures based on lessons learned
Audit Evidence Needed:
Post-incident review reportsLessons learned documentationAction item trackingProcedure update history
A.16.1.7
Collection of Evidence
Objective:
Define and apply procedures for identification, collection, acquisition, and preservation of evidence
Implementation Requirements:
- Establish evidence handling procedures
- Define chain of custody requirements
- Ensure forensically sound collection methods
- Coordinate with legal on admissibility requirements
- Train incident responders on evidence preservation
Audit Evidence Needed:
Evidence collection proceduresChain of custody formsForensics tools and capabilitiesTraining records
Phase 1: Documentation
Weeks 1-4- Draft information security incident management policy
- Create incident response procedures and playbooks
- Define event and incident categorization criteria
- Document roles and responsibilities (RACI)
- Establish reporting channels and procedures
- Develop evidence collection procedures
Phase 2: Process Establishment
Weeks 5-8- Set up incident tracking system/ticketing
- Establish 24/7 reporting capability
- Create communication templates
- Deploy forensics tools if needed
- Coordinate with legal, HR, PR teams
- Establish external relationships (law enforcement, vendors)
Phase 3: Training
Weeks 9-10- Train incident response team on procedures
- Conduct awareness training for all personnel
- Train on reporting mechanisms
- Educate on evidence preservation
- Document training completion
Phase 4: Testing
Weeks 11-12- Conduct tabletop exercise
- Test reporting channels
- Validate escalation procedures
- Review and update documentation based on results
- Document testing evidence for auditors
ISO 27001 auditors will verify that your incident response controls are not just documented, but actually implemented and effective:
Documentation Review
What Auditors Check:
- Incident response policy exists and is approved
- Procedures are comprehensive and current
- Roles and responsibilities are clearly defined
- Evidence collection procedures are documented
- Training materials are available
Your Preparation:
- Ensure all documents are version-controlled
- Review and update documents before audit
- Prepare document index for easy access
- Have approval signatures/dates visible
Implementation Evidence
What Auditors Check:
- Incident logs show procedures are followed
- Personnel know how to report events
- Incidents are categorized and prioritized
- Post-incident reviews are conducted
- Lessons learned drive improvements
Your Preparation:
- Maintain complete incident logs
- Conduct mock interviews with staff
- Document all post-incident reviews
- Track action items to completion
Training Verification
What Auditors Check:
- All personnel trained on reporting
- IR team trained on procedures
- Training records are maintained
- Refresher training occurs regularly
Your Preparation:
- Maintain training attendance records
- Keep training materials and dates
- Document training schedule
- Show evidence of awareness campaigns
Testing Evidence
What Auditors Check:
- Procedures are tested regularly
- Tabletop exercises are conducted
- Testing results are documented
- Improvements are implemented post-test
Your Preparation:
- Conduct exercises at least annually
- Document exercise scope and results
- Show before/after procedure updates
- Prepare exercise attendance records
Incident response procedures not followed
MajorFix: Train team, simplify procedures, conduct regular exercises
No evidence of testing (no exercises conducted)
MajorFix: Schedule quarterly tabletop exercises, document results
Incidents not logged properly
MajorFix: Implement ticketing system, enforce logging procedures
No post-incident reviews conducted
MajorFix: Make lessons learned mandatory, assign responsibility
Outdated contact lists in procedures
MinorFix: Review and update contact lists quarterly
Training records incomplete
MinorFix: Maintain centralized training records, track completion
Evidence collection procedures not forensically sound
MajorFix: Engage forensics expert, update procedures, train team
Escalation criteria unclear or not followed
MinorFix: Define clear escalation triggers, communicate widely
ISO 27035
Dedicated incident management standard - provides detailed implementation guidance for A.16
NIST 800-61
Can be used to satisfy ISO 27001 incident response requirements with gap mapping
SOC 2
IR testing evidence for ISO 27001 can be reused for SOC 2 common criteria
Prepare for Your ISO 27001 Audit
Breakpoint helps you test and document your ISO 27001 incident response controls with guided tabletop exercises, evidence collection, and audit-ready reports.