BSI C5:2020 SIM-01 — Policy for security incident management

What this control requires

Documents incident management policies per SP-01, defining classification, escalation, and CERT coordination. Ensures timely customer notification and effective response to incidents, protecting cloud customer data from security breaches.

In plain English

Documents incident management policies per SP-01, defining classification, escalation, and CERT coordination. In practice, this means you can prove you risk cloud customer data-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 Security Incident Management, the assessor will trace your implementation back to the catalogue reference (Criterion SIM-01) and look for objective evidence on the latest two assessment cycles.

How to implement

Incident Response

Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.

Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.

Cloud Posture

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

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Risk. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Policy. Document the trigger, the owner and the cadence.
• Scope: cloud customer data, security incident management.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Policy for security incident management.

Common pitfalls

• Runbooks that name a role but no person, or list a paging channel that no longer exists.
• Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.
• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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.

• ISO/IEC 27001:2022 A.5.24 — Information security incident management planning and preparation
• HIPAA (45 CFR Part 164) 164.308(a)(6)(i) — Security Incident Procedures
• NIST SP 800-171 Rev. 3 3.12.3 — Continuous Monitoring
• CIS Controls v8 17.4 — Establish and Maintain an Incident Response Process
• ISO/IEC 42001:2023 A.3.3 — Reporting of concerns

Related controls in BSI C5:2020

• Criterion SIM-05 — Evaluation and learning process
• Criterion SIM-02 — Processing of security incidents
• Criterion SIM-04 — Duty of the users to report security incidents to a central body
• Criterion SP-03 — Exceptions from Existing Policies and Instructions
• Criterion HR-02 — Employment terms and conditions
• Criterion PI-01 — Documentation and safety of input and output interfaces

References

• Bundesamt für Sicherheit in der Informationstechnik (BSI) — BSI C5:2020
• Catalogue identifier: Criterion SIM-01

Topics: governance riskincident responsecloud posturepolicy management