ISO 27001 Annex A 5.3: Segregation of duties

What auditors look for

Auditors check that 5.3 is either justified as not applicable in your Statement of Applicability or implemented and working. Typical evidence includes:

• Segregation matrix for critical processes
• Access reviews showing conflicting rights removed
• Compensating controls where separation is not possible

How to implement 5.3 in practice

1. Focus first on payments, privileged access and production changes
2. Use approvals in tools to enforce separation
3. Document compensating monitoring in small teams
4. Name an owner for 5.3, decide how often it runs and file evidence each time, so the control is audit-ready all year.

Recording 5.3 in the Statement of Applicability

List 5.3 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

• ISO 27001 and GDPR readiness assessment
• 10 steps to implement ISO 27001
• Remote ISO 27001 consultant

More organizational controls

• 5.1 Policies for information security
• 5.2 Information security roles and responsibilities
• 5.4 Management responsibilities
• 5.5 Contact with authorities
• 5.6 Contact with special interest groups
• 5.7 Threat intelligence
• 5.8 Information security in project management
• 5.9 Inventory of information and other associated assets