ISO 27001 Annex A 5.23: Information security for use of cloud services

What Control 5.23 means in practice

Govern cloud selection, shared responsibility, secure use, material change and exit. The useful question is not whether a policy mentions the topic, but whether scope, decisions, ownership and records show a repeatable response to actual risk.

Design should fit the organization’s services and dependencies. A smaller team can use lightweight records and existing platforms; a complex environment normally needs clearer separation of duties, automated coverage checks and governed exceptions.

Implementation steps

1. Step 1. Define ownership, scope and operating criteria for information security for use of cloud services.
2. Step 2. Implement cloud governance process that fits the organization’s risks, services and working practices.
3. Step 3. Integrate the activity with relevant change, exception and review processes.
4. Step 4. Review performance and improve the arrangement when risks, technology or obligations change.

Translate each step into an owner, trigger, expected record and review rule. This makes the activity testable and prevents an attractive document from becoming the whole implementation.

What good implementation looks like

• configuration findings resolved or risk accepted
• current cloud inventory reconciled with billing and identity
• tested recovery or export evidence for critical services

These outcomes should be observable in normal work, not only during audit preparation. Owners should be able to explain weak results, accepted exceptions and the next improvement action.

Implementation evidence and effectiveness evidence

Implementation evidence shows that the arrangement exists. Effectiveness evidence shows whether it produces the intended result across the relevant scope and over time. Auditors commonly corroborate both.

How an auditor may test Control 5.23

1. Select a representative in-scope service, asset or process.
2. Confirm the accountable owner and expected operation.
3. Trace a recent example: A SaaS service has a named owner, approved data use and configured administrator controls.
4. Inspect the operating record and corroborating technical evidence.
5. Compare the design with evidence that the control operated effectively.
6. Follow an exception or adverse result through decision and closure.
7. Review trends, metrics and improvement decisions.

Questions to prepare for

• How is information security for use of cloud services implemented in practice?
• Who owns the activity and how are decisions approved?
• Show me a recent example from operation through review.
• How are exceptions, changes or overdue actions handled?

Practical examples

Useful performance and coverage measures

• unowned cloud services
• critical configuration drift
• inactive privileged cloud identities

Use measures to expose coverage, timeliness, recurrence and exception age. Raw activity volume is not success; a metric should help an owner decide or investigate.

Approach for smaller and mature organizations

Smaller organization

Use a clear owner, a proportionate working record, built-in platform capability and a scheduled review. Sample real activity instead of creating duplicate paperwork for information security for use of cloud services.

Mature or complex organization

Define service-level ownership, automated coverage reporting, integrated workflow, risk-based exceptions and independent assurance across business units and technology platforms.

Practical implementation checklist

• □ Define ownership, scope and operating criteria for information security for use of cloud services.
• □ Implement cloud governance process that fits the organization’s risks, services and working practices.
• □ Integrate the activity with relevant change, exception and review processes.
• □ Review performance and improve the arrangement when risks, technology or obligations change.
• □ Sample evidence has been checked for operation and effectiveness.
• □ Exceptions have owners, rationale, review dates and closure evidence.

Common implementation mistakes

• documenting information security for use of cloud services without consistent operation
• unclear ownership or review frequency
• evidence that does not cover the full ISMS scope
• exceptions accepted without risk-based approval or follow-up

Related controls, clauses and resources