BSI C5:2020 OIS-02 — Information Security Policy

What this control requires

Top management adopts and communicates an information security policy to employees and customers, detailing the importance of security, objectives aligned with business goals, key security strategy aspects, and organizational structure for ISMS implementation to safeguard cloud customer data and meet protection requirements.

In plain English

Top management adopts and communicates an information security policy to employees and customers, detailing the importance of security, objectives aligned with business goals, key security strategy aspects, and organizational structure for ISMS implementation to safeguard cloud customer data and meet protection requirements. In practice, this means you can prove you information security policy-level controls on a defined cadence.

Why it matters

BSI C5 is the default cloud-security baseline German public-sector buyers and many DAX-listed enterprises expect; gaps here directly block procurement in the DACH region and frequently appear as must-have items in EU public-tender documents.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A C5 attesting auditor (under ISAE 3000 / IDW PS 860) tests both the design and — for a Type 2 — the operating effectiveness over the attestation period. For each criterion they look for both the Basic and any in-scope Additional objectives.

Within Information Security Governance, the assessor will trace your implementation back to the catalogue reference (Criterion OIS-02) and look for objective evidence on the latest two assessment cycles.

How to implement

Cloud Posture

CSPM. Run Wiz / Prisma / Defender for Cloud / Security Command Center over every account; auto-ticket findings above your accepted-risk threshold.

Configuration Management

Policy-as-code. Codify the control as Service Control Policies (AWS), Azure Policy initiatives, or Organisation Policy (GCP) so the platform enforces what the document promises.

IaC. Gate Terraform / Pulumi / CloudFormation changes with Checkov / tfsec / OPA so misconfigurations never reach production.

Drift. Run a CSPM (Wiz / Prisma / Defender for Cloud / Security Command Center) over every account and route findings to a single risk register.

Network Security

AWS. VPC Flow Logs to S3, default-deny security groups, AWS Network Firewall for north-south, and Transit Gateway for hub-and-spoke segmentation.

Azure. NSGs with deny-by-default, Azure Firewall Premium with TLS inspection, Private Endpoints for PaaS, and Microsoft Defender for Cloud's secure score for drift.

GCP. VPC Service Controls perimeters around sensitive APIs, Cloud NGFW Enterprise for L7 inspection, Private Service Connect for managed services.

Operational checklist

• Information. Document the trigger, the owner and the cadence.
• Risk. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Protection. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Scope: security policy, protection, - configuration, cloud customer data, key management.

Evidence to collect

• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Infrastructure posture tooling (AWS Config, Azure Policy, Nessus) verifies platform hardening. Focus: Information Security Policy.

Common pitfalls

• Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.
• Manual cloud-console changes that never make it back to Terraform — drift accumulates until the next outage forces a reconciliation.
• Default-allow egress rules; East-West traffic with no segmentation; jump hosts on the public internet with password auth.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• NIST SP 800-171 Rev. 3 3.14.8 — Information Management and Retention
• NIST SP 800-53 Rev. 5 SC-7 — Boundary Protection
• ISO/IEC 27001:2022 A.5.34 — Privacy and protection of personal identifiable information (PII)
• CIS Controls v8 4.2 — Establish and Maintain a Secure Configuration Process for Network Infrastructure
• GDPR Article 25 — Data protection by design and by default

Related controls in BSI C5:2020

• Criterion CRY-04 — Secure key management
• Criterion COM-04 — Information on information security performance and management assessment of the ISMS
• Criterion CRY-02 — Encryption of data for transmission (transport encryption)
• Criterion COS-04 — Cross-network access
• Criterion AM-02 — Acceptable Use and Safe Handling of Assets Policy
• Criterion COM-03 — Internal audits of the information security management system

References

• Bundesamt für Sicherheit in der Informationstechnik (BSI) — BSI C5:2020
• Catalogue identifier: Criterion OIS-02

Topics: governance risknetwork securitycloud infrastructurecloud postureconfiguration managementkey management