Markdown Editor

Cloud Services Security Policy Template (ISO/IEC 27001 A.5.23)

Cloud policy for A.5.23: shared responsibility, tiers, due diligence, contract terms, configuration, monitoring, exit, shadow IT, cloud register

ISMS und ISO/IEC 27001VollständigISO/IEC 27001:2022 A.5.23 (cited only); ISO/IEC 27002:2022; ISO/IEC 27017:2026; ISO/IEC 27036-4:2016cloudservicessecuritypolicy

Anleitung: Use it when the organization buys or runs any IaaS, PaaS or SaaS service and needs one policy for acquiring, using, managing and exiting cloud services. Fill the approval tiers and the cloud service register first. The main pitfall is covering only the main IaaS platform and forgetting SaaS, free tools and AI services.

Vorschau

Cloud Services Security Policy: [Organization name]

Sets the rules for acquiring, using, managing and exiting cloud services (IaaS, PaaS and SaaS) so that information processed in them stays protected under the shared responsibility model. It supports ISO/IEC 27001:2022 + Amd 1:2024 Annex A control A.5.23 (security for cloud service use, new in the 2022 edition), with guidance from ISO/IEC 27002:2022, ISO/IEC 27017:2026 and ISO/IEC 27036-4:2016. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice.

Document control

FieldValue
Document IDDOC-ISMS-044
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Owner[@isms-manager]
Approvers/reviewers[@cto], [@head-of-procurement], [@legal-counsel], [@dpo]
Last updatedYYYY-MM-DD
Classification[Internal]
Standard and editionISO/IEC 27001:2022 + Amd 1:2024 (A.5.23); ISO/IEC 27002:2022; ISO/IEC 27017:2026; ISO/IEC 27036-4:2016
Next scheduled reviewYYYY-MM-DD (at least every 12 months and after any major cloud incident or provider change)
Applies to[All employees, contractors and business units that buy, configure or use cloud services]
Parent policyInformation security policy DOC-ISMS-001
Related recordsCloud service register (section 12), supplier register DOC-ISMS-066, cloud exit plan DOC-ISMS-076

Approvals

RoleNameDecisionDate
Policy owner[@isms-manager][Prepared]YYYY-MM-DD
Top management sponsor[@cto][Approved / Approved with changes]YYYY-MM-DD
Procurement[@head-of-procurement][Reviewed]YYYY-MM-DD
Legal and privacy[@legal-counsel], [@dpo][Reviewed]YYYY-MM-DD

Revision history

VersionDateAuthorChange
0.1YYYY-MM-DD[@author]First draft
1.0YYYY-MM-DD[@author]Approved for issue
[x.y]YYYY-MM-DD[@author][Change summary]

Contents

1. Purpose and scope

This policy defines how [Organization name] selects, contracts, configures, operates, monitors and leaves cloud services so that the confidentiality, integrity and availability of information processed in them meet the organization's risk criteria (DOC-ISMS-010) and legal, regulatory and contractual obligations (DOC-ISMS-014).

For this policy, a cloud service is any on-demand, network-accessed computing capability provided by a third party: infrastructure (IaaS), platform (PaaS), software (SaaS), and specialised services such as managed databases, identity providers, content delivery networks, backup as a service and hosted AI models. The NIST definition (SP 800-145) is a useful reference for the service and deployment models.

ItemIn scopeOut of scope
Service typesIaaS, PaaS, SaaS, managed security services, AI and machine learning APIs, free or trial services used with company dataPurely personal accounts with no company data
DataAll information classified Internal or above (see data/data-classification-policy)Public information already published
UsersEmployees, contractors, interns, suppliers acting on our behalfCustomers using our own product (covered by product security documents)
RoleThe organization as a cloud service customerThe organization as a cloud service provider (use isms/cloud-27017-controls)

If the organization also provides cloud services to customers, apply this policy to the services it consumes and document the provider side in the ISO/IEC 27017 control set.

2. Policy statements

  1. Only cloud services recorded as Approved in the cloud service register (section 12) may process information classified Internal or above.
  2. Every cloud service has a named business owner and a named technical owner, recorded in the register.
  3. Before acquisition, each service is categorised (section 4) and assessed in proportion to its tier (section 5).
  4. Contracts for Tier 1 and Tier 2 services include the security terms in section 6, or the gap is recorded as an accepted risk.
  5. The shared responsibility split is documented for each Tier 1 and Tier 2 service (section 3), and customer-side duties are assigned.
  6. Cloud services are configured against an approved baseline, with single sign-on and multi-factor authentication wherever the service supports them (section 7).
  7. Cloud administrative access is privileged access and follows security/privileged-access-standard.
  8. Logs from Tier 1 services are collected and reviewed under the security monitoring procedure (DOC-ISMS-064).
  9. Each Tier 1 service has a documented, tested exit approach (DOC-ISMS-076); each Tier 2 service has at least a data export method.
  10. Shadow IT is detected and handled under section 11; it is not tolerated silently.
  11. Cloud risks are assessed under DOC-ISMS-010 and recorded in the risk register DOC-ISMS-016.

3. Shared responsibility

Security responsibilities are split between the cloud service provider (CSP) and [Organization name] as cloud service customer. The split moves with the service model. The table below is the organization's default view; record any service-specific difference in the register.

LayerIaaSPaaSSaaS
Physical data centre, hardware, hypervisorProviderProviderProvider
Network infrastructure of the providerProviderProviderProvider
Guest operating system, patchingCustomerProviderProvider
Runtime, middleware, managed database engineCustomerProviderProvider
Application code and its configurationCustomerCustomerProvider (configuration settings: Customer)
Identity, accounts, roles, MFACustomerCustomerCustomer
Data classification, retention, deletion settingsCustomerCustomerCustomer
Encryption key choice and managementCustomer (provider tools)SharedShared or Provider
Network controls inside the tenant (security groups, private endpoints)CustomerSharedProvider (IP allow lists: Customer)
Logging enablement and log reviewCustomerCustomerCustomer (provider supplies logs)
Backup of customer dataCustomerSharedCustomer unless contract says otherwise
Incident detection in customer configurationCustomerCustomerCustomer
Incident notification to customerProviderProviderProvider

The customer is always responsible for identity, data and configuration. No contract transfers accountability for the information itself.

4. Cloud service categories and approval tiers

Each cloud service is placed in one tier using the highest criterion that applies.

TierCriteria (any one is enough)Assessment depthApprover
Tier 1, criticalHosts production systems or customer data; processes Confidential or Restricted data at scale; outage stops a critical business process (BIA, DOC-ISMS-120); identity provider or security toolingFull due diligence (section 5), contract review, shared responsibility matrix, exit plan, annual reassessmentISMS manager and top management sponsor
Tier 2, importantProcesses Internal or Confidential data for a department; personal data in limited volume; outage hurts but has a workaroundStandard questionnaire, assurance report review, contract security terms, data export method, two-yearly reassessmentISMS manager or delegate
Tier 3, lowPublic or Internal data only, no personal data beyond user accounts, easy to replaceShort checklist (SSO, MFA, data location, terms of use), register entryLine manager and IT
ProhibitedFails a mandatory requirement (for example no MFA for a Tier 1 use, data location not allowed by contract or law, provider refuses breach notification)Not approved; alternative proposedNot applicable

Service categories used in the register: IaaS, PaaS, SaaS business application, SaaS collaboration, identity and access, security service, developer tooling, AI service, backup and storage.

5. Acquisition and due diligence

5.1 Request to approval flow

Every new cloud service, including free tiers and trials used with company data, follows this path before any Internal or higher data is placed in it.

5.2 Due diligence checklist

AreaTier 1Tier 2Tier 3Evidence to collect
Independent assurance (ISO/IEC 27001 certificate with scope covering the service, SOC 2 Type 2 report, CSA STAR entry)RequiredRequired or questionnaireOptionalCertificate, scope statement, report period, bridge letter
Certificate validity checked (certification body accredited by a signatory of the Global ACI MRA, formerly the IAF MLA; scope matches the service; not expired)RequiredRequiredNot applicableScreenshot of the IAF CertSearch result (check that the database is still the current one) or of the accreditation body's register
Security questionnaire (compliance/supplier-security-assessment, or a CAIQ v4.1 response)RequiredShort formNot applicableCompleted questionnaire
Data location and transfers (regions, sub-processors, transfer mechanism)RequiredRequiredBasic checkRegion list, sub-processor list, transfer assessment (compliance/transfer-impact-assessment)
Identity: SSO with the corporate identity provider, MFA, role-based adminRequiredRequiredMFA requiredConfiguration screenshot or test
Encryption in transit and at rest, key management optionsRequiredRequiredBasic checkProvider documentation
Logging available to the customer (admin activity, data access, retention)RequiredRequiredNot applicableLog types and retention
Incident notification commitment and timeRequiredRequiredBasic checkContract clause
Resilience (availability commitment, regions, backup, provider DR testing)RequiredBasic checkNot applicableSLA, architecture notes
Data export and deletion on exitRequiredRequiredBasic checkExport format, deletion confirmation process
Financial and concentration risk (provider viability, dependence on one provider)RequiredOptionalNot applicableNote in risk assessment
Sub-processor and supply chain transparencyRequiredRequiredNot applicableSub-processor list, change notice terms

5.3 Worked example

FieldValue
Request IDCLD-REQ-014 (Example)
ServiceManaged analytics data warehouse (PaaS) for Quillmere Analytics Ltd
DataCustomer analytics data including personal data (processor role); classification Confidential
TierTier 1 (customer data at scale, production dependency)
AssuranceISO/IEC 27001 certificate covering the service, SOC 2 Type 2 report for a 12-month period ending 3 months ago
Data locationSame two regions as the main platform (primary and DR)
Gaps foundCustomer-managed keys only on a higher plan; admin activity logs kept 90 days by default
RiskRISK-031 (Example): likelihood 2, impact 4, score 8 (Medium) after treatment
TreatmentBuy the plan with customer-managed keys; export admin logs to the central log store (365-day retention)
DecisionApproved by ISMS manager and CTO on YYYY-MM-DD

6. Contract requirements

Contracts or accepted standard terms for Tier 1 and Tier 2 services must address the points below. Where the provider's standard terms do not cover a point and cannot be changed, record the gap, assess the risk and obtain acceptance under section 2.4 of DOC-ISMS-010.

RefRequirementTier 1Tier 2
CON-01Provider security obligations, including maintenance of a recognised security certification or audit report for the serviceRequiredRequired
CON-02Right to receive assurance reports, certificates and summaries of penetration testsRequiredRequired
CON-03Incident and personal data breach notification without undue delay, with a stated maximum timeRequiredRequired
CON-04Data processing agreement with processor duties where personal data is processedRequiredRequired
CON-05Data location commitments and notice of changes to regions or sub-processorsRequiredRequired
CON-06Ownership of customer data stays with the customer; provider use of data limited to service delivery (including any AI model training restrictions)RequiredRequired
CON-07Availability commitment, service credits and maintenance noticeRequiredRecommended
CON-08Data export in a usable format during the term and for a defined period after terminationRequiredRequired
CON-09Secure deletion of customer data after exit, with confirmationRequiredRequired
CON-10Notice of material changes to the service that affect securityRequiredRecommended
CON-11Cooperation with customer audits, regulators and investigations, including access to logsRequiredRecommended
CON-12Liability and insurance appropriate to the data at riskRequiredRecommended

For regulated sectors, map these terms to the sector rules (for example DORA contractual requirements for ICT third-party services in EU financial entities) and keep the mapping in isms/supplier-security-agreement-27036.

7. Secure configuration and use

7.1 Configuration rules

  1. Configure every Tier 1 and Tier 2 service against a documented baseline before production use: isms/secure-configuration-baseline for IaaS and PaaS, isms/saas-productivity-security-baseline for the collaboration suite, or the vendor hardening guide recorded in the register.
  2. Connect the service to the corporate identity provider using single sign-on. Local accounts are limited to documented break-glass accounts.
  3. Enforce MFA for all users; phishing-resistant MFA for administrators of Tier 1 services.
  4. Grant administrative roles by named individual, with least privilege, and review them in the quarterly access review (ops/access-review).
  5. Manage infrastructure as code for IaaS and PaaS where practical, with peer review of changes.
  6. Block public exposure of storage and databases by default; any public resource needs a recorded business reason.
  7. Use separate accounts, subscriptions or projects for production and non-production, with no production personal data in non-production unless masked (see isms/data-masking-dlp-standard).
  8. Store secrets in a secrets manager, never in code or configuration files (security/secrets-management-standard).
  9. Apply encryption according to security/cryptography-standard, and record the key ownership model in the register.
  10. Enable the provider's security posture tooling or an equivalent cloud security posture management (CSPM) capability for Tier 1 IaaS and PaaS.

7.2 Use of AI cloud services

Cloud-hosted AI services follow the same tiering. In addition, users must not submit Confidential or Restricted data to an AI service unless the register shows that the contract excludes model training on customer data and the data location is acceptable. See ai-data/ai-usage-policy.

8. Monitoring and ongoing assurance

ActivityFrequency (Example)TierOwnerOutput
Collect admin and security logs into the central log platformContinuousTier 1Platform teamLog source inventory entry
Review posture findings (CSPM or provider security centre)WeeklyTier 1 IaaS and PaaSPlatform teamTicket per finding, trend in monthly report
Review provider status and security bulletinsWeeklyTier 1 and 2Technical ownerNotes in change or incident record
Review new or expiring certificates and assurance reportsAnnually, or at report expiryTier 1 and 2ISMS managerUpdated register fields
Reassess due diligenceTier 1 annually, Tier 2 every 24 monthsTier 1 and 2ISMS manager with business ownerUpdated assessment and risk entries
Posture review (security/cloud-security-posture-review)Twice a yearTier 1 IaaS and PaaSSecurity teamReview report and actions
Review admin role assignmentsQuarterlyTier 1 and 2Technical ownerAccess review record
Check usage and cost anomalies that may indicate compromiseMonthlyTier 1 IaaSPlatform teamAnomaly log

Monitoring findings that indicate an incident go to the security event reporting procedure (DOC-ISMS-023) and the incident response plan (DOC-ISMS-020).

9. Change management for cloud services

Customer-side changes to Tier 1 services follow the change process (ops/change-enablement-policy). Provider-side changes are handled as follows.

Provider changeActionOwner
New sub-processor or regionCheck against data location rules; object within the contractual window if neededDPO and technical owner
New feature enabled by default that touches data sharing, AI or external accessAssess and disable or configure before it reaches usersTechnical owner
Change to terms, data processing agreement or security commitmentsLegal review; update the register and risk entryLegal counsel
Deprecation of a security feature or servicePlan replacement; risk entry if the gap exceeds 30 days (Example)Technical owner
Provider security incident affecting the serviceHandle under DOC-ISMS-020; reassess tier and riskISMS manager
Provider acquisition or change of controlReassess due diligence and concentration riskISMS manager and procurement

10. Exit and termination

  1. Each Tier 1 service has an exit plan in DOC-ISMS-076 covering exit triggers, data export, alternative provider or in-house option, timeline, roles and verification of deletion.
  2. Each Tier 2 service has a recorded data export method and a named person who has tried it.
  3. On termination: export data, verify completeness and integrity, revoke all integrations, API keys and federated trust, remove user accounts, request deletion and keep the provider's deletion confirmation.
  4. Update the register status to Retired, with the exit date and the location of the deletion confirmation.
  5. Keep exported data under the retention rules in data/data-retention-deletion-standard.

11. Shadow IT and unapproved services

Shadow IT is any cloud service used with company data that is not in the register. The organization detects and handles it as follows.

Detection sourceHowFrequency (Example)
Identity provider sign-in logs and OAuth app grantsReview third-party apps users have authorised against corporate accountsMonthly
Expense and card statementsFinance flags software and cloud subscriptionsMonthly
Network or secure web gateway logsReport on cloud application categories in useMonthly
Endpoint software inventoryDesktop clients for cloud servicesQuarterly
Staff declarationAnnual awareness reminder and amnestyAnnually

Handling: the ISMS manager contacts the user, assigns a tier, and either starts the approval path (section 5), replaces the service with an approved one, or blocks it and arranges data recovery and account deletion. Repeated or deliberate use of a prohibited service is handled under the disciplinary process (DOC-ISMS-052). Free AI tools and browser extensions with access to company data are treated as cloud services.

12. Cloud service register

IDService and categoryBusiness ownerTechnical ownerTierData classificationPersonal dataRegionsAssurance and expirySSO and MFAExit approachLast assessedStatus
CLD-001 (Example)Public cloud IaaS and PaaS (production platform)CTOHead of Engineering Operations1ConfidentialYes, processorPrimary and DR regionISO/IEC 27001 cert, SOC 2 Type 2, expires 2027-06-30SSO, phishing-resistant MFA for adminsExit plan DOC-ISMS-076 (platform copy)2026-09-15Approved
CLD-002 (Example)Collaboration suite (mail, files, chat), SaaS collaborationCOOIT lead1ConfidentialYes, controller and processorProvider region set by tenantISO/IEC 27001 cert, expires 2027-03-31SSO, MFAExit plan DOC-ISMS-076 (collaboration suite copy)2026-08-02Approved
CLD-003 (Example)CRM, SaaS business applicationHead of SalesIT lead2ConfidentialYes, controllerSingle regionSOC 2 Type 2, period ends 2026-12-31SSO, MFACSV and API export, tested 2026-05-102026-05-10Approved
CLD-004 (Example)Diagramming tool, SaaS collaborationHead of ProductIT lead3InternalNoNot applicableChecklist onlySSOExport to files2026-02-01Approved
CLD-005 (Example)Free online file converterNot applicableNot applicableProhibitedNot applicableNot applicableUnknownNoneNoneNot applicable2026-07-20Blocked

Status values: Requested, Approved, Approved with conditions, Rejected, Blocked, Exiting, Retired.

13. Roles and responsibilities

RoleResponsibility
Top management sponsorApproves Tier 1 services and accepts High residual cloud risks
ISMS managerOwns this policy and the register, runs due diligence, reports cloud risk to management review
Business ownerRequests the service, justifies it, owns the data decisions and the budget for required controls
Technical ownerConfigures to baseline, manages admin access, monitors posture and provider changes, maintains the exit approach
ProcurementEnsures no cloud purchase is completed without a register entry and approval
Legal counsel and DPOReview contract terms, data processing agreements, transfers and sub-processor changes
Security teamPosture reviews, log monitoring, shadow IT detection, incident handling
All usersUse only approved services, report suspected unapproved use and incidents

14. Size tiers

AspectSmall: Quillmere Analytics Ltd (46 staff)Medium: Quillmere Health Systems (320 staff)Large: Quillmere Group (2,400 staff, 6 sites)
Typical estate (Example)One public cloud provider in two regions (primary and DR), one collaboration suite, about 25 SaaS toolsColocation suite plus one public cloud, about 80 SaaS tools, clinical customer integrationsSeveral cloud providers across 4 countries, regional tenants, OT vendor cloud portals, over 300 SaaS tools
RegisterSpreadsheet owned by the 0.5 FTE ISMS manager (Head of Engineering Operations)Register in the GRC or ticketing tool, linked to the supplier registerCentral register fed by procurement workflow and identity provider app catalogue, regional owners
ApprovalTier 1 by ISMS manager and CTO; Tier 3 self-service checklistTier 1 by ISMS manager and steering committee; Tier 2 by security teamTier 1 by group CISO and regional business head; architecture board for new platforms
Due diligenceAssurance report review and short questionnaire, reuse of provider trust pagesFull questionnaire for Tier 1, healthcare contract terms, data location review for hospital contractsThird-party risk team, tiered questionnaires, concentration risk across group, sector rules per country
Posture monitoringProvider-native security centre, weekly reviewCSPM tool across cloud and colocation-hosted workloads, SIEM integrationCentral CSPM across all tenants, security operations centre, policy as code guardrails
Shadow IT detectionMonthly review of identity provider app grants and card statementsSecure web gateway reports and expense reviewCloud access security broker, procurement controls, regional reviews
Exit testingAnnual export test for the platform and the collaboration suiteAnnual export test for all Tier 1 services, exit plan per hospital-facing serviceExit plans per Tier 1 provider per region, tested on a rotating schedule

15. Records and evidence

RecordProvesOwnerLocationRetention (Example)
Cloud service registerServices are known, tiered, owned and assessedISMS manager[GRC tool / register file]Current plus 3 years of history
Due diligence assessments and decisionsAcquisition followed the policyISMS manager[Supplier folder per service]Life of service plus 3 years
Contract and DPA gap reviewsContract requirements were checkedLegal counsel[Contract repository]Life of contract plus 6 years
Shared responsibility matricesCustomer duties are assignedTechnical owner[Architecture repository]Life of service
Baseline configuration evidence and posture reportsServices are configured and monitoredTechnical owner, security team[CSPM tool exports, tickets]2 years
Admin access reviewsPrivileged cloud access is controlledTechnical owner[Access review records]3 years
Shadow IT review recordsUnapproved use is detected and handledISMS manager[Review log]3 years
Exit tests and deletion confirmationsExit is possible and data is removedTechnical owner[Exit plan annex]6 years after exit

Map each record to control A.5.23 in isms/control-evidence-matrix and reference the policy in the Statement of Applicability (DOC-ISMS-011).

16. Compliance, exceptions and review

  • Compliance is checked through the internal audit programme (DOC-ISMS-082), the posture reviews in section 8 and the shadow IT reviews in section 11.
  • Exceptions are requested with security/security-exception-request (DOC-ISMS-122), assessed under DOC-ISMS-010 and approved at the authority the risk methodology (DOC-ISMS-010 section 2.4) sets for the residual risk: the risk owner for Low; the risk owner and department head for Medium (top management if the risk category is Averse, DOC-ISMS-015 section 9 rule 1); top management with a treatment decision for High, recorded in the risk acceptance record (DOC-ISMS-019). Critical residual risk is not approvable as an exception: treat it or stop the activity. Maximum duration is 12 months for Low or Medium and 6 months for High; at expiry the exception is reassessed, and a renewal is a new decision (DOC-ISMS-122 section 7).
  • Breaches of this policy are handled under DOC-ISMS-052.
  • This policy is reviewed at least every 12 months, and after a major cloud incident, a new Tier 1 provider, a change in law affecting data location, or a relevant audit finding.

17. References

ReferenceEditionUse
ISO/IEC 27001:2022 + Amd 1:2024, https://www.iso.org/standard/82875.html and https://www.iso.org/standard/88435.htmlCurrentA.5.23 and related supplier controls A.5.19 to A.5.22
ISO/IEC 27002:2022, https://www.iso.org/standard/75652.htmlCurrentControl guidance for cloud service use
ISO/IEC 27017:2026, https://www.iso.org/standard/82878.htmlNew edition July 2026; check the control setCloud-specific controls for customers and providers
ISO/IEC 27018:2025, https://www.iso.org/standard/88150.htmlCurrentPII protection in public clouds acting as processors
ISO/IEC 27036-4:2016, https://www.iso.org/standard/59689.htmlCurrentSupplier relationships, security of cloud services
NIST SP 800-145, The NIST Definition of Cloud ComputingSeptember 2011, https://csrc.nist.gov/pubs/sp/800/145/finalService and deployment model definitions
CSA Cloud Controls Matrix v4.1 and CAIQ v4.1Released January 2026 (names only)Optional questionnaire format for providers
Related templatesisms/cloud-exit-plan, isms/cloud-27017-controls, isms/cloud-pii-27018-processor, isms/supplier-register, compliance/supplier-security-assessment, isms/supplier-security-agreement-27036, isms/saas-productivity-security-baseline, security/cloud-security-posture-review, isms/control-evidence-matrix, compliance/statement-of-applicability

Standard and licence note

Structure aligned with ISO/IEC 27001:2022 + Amd 1:2024 (Annex A control A.5.23), ISO/IEC 27002:2022, ISO/IEC 27017:2026 and ISO/IEC 27036-4:2016. Control numbers are cited with original short labels; the policy statements, tables, tiers and examples are original text, and no text from ISO/IEC standards is reproduced. Obtain the official standards from ISO, IEC or your national standards body to implement the requirements. NIST SP 800-145 is a US government publication; the CSA Cloud Controls Matrix and CAIQ are cited by name only. Check the current edition of each standard before use: ISO/IEC 27017 was republished in 2026.

Template licence: MIT.

Ähnliche Vorlagen