ISO 27001 Annex A 5.26: Response to information security incidents

What auditors look for

Auditors check that 5.26 is either justified as not applicable in your Statement of Applicability or implemented and working. Typical evidence includes:

• Incident tickets and timelines
• Containment and recovery records
• Communications and notifications sent

How to implement 5.26 in practice

1. Use playbooks for common incidents such as phishing and ransomware
2. Keep a timeline as you go
3. Assign a single incident lead
4. Name an owner for 5.26, decide how often it runs and file evidence each time, so the control is audit-ready all year.

How 5.26 supports GDPR

This control helps demonstrate GDPR Art. 33-34. Map it once in your control matrix so the same evidence supports both ISO 27001 and GDPR accountability. See the GDPR compliance checklist.

Recording 5.26 in the Statement of Applicability

List 5.26 with whether it applies, the reason (usually the risks it treats or a legal or contractual requirement), its implementation status and where the evidence lives. If you exclude it, explain why none of your risks or obligations require it.

Free resources

• GDPR data breach log template
• ISO 27001 and GDPR readiness assessment
• 10 steps to implement ISO 27001
• Remote ISO 27001 consultant

More organizational controls

• 5.22 Monitoring, review and change management of supplier services
• 5.23 Information security for use of cloud services
• 5.24 Information security incident management planning and preparation
• 5.25 Assessment and decision on information security events
• 5.27 Learning from information security incidents
• 5.28 Collection of evidence
• 5.29 Information security during disruption
• 5.30 ICT readiness for business continuity