BSI C5:2020 SP-02 — Review and Approval of Policies and Instructions

What this control requires

Annually reviews information security policies for adequacy, considering organizational, technical, and legal changes. Ensures revised policies are approved before implementation to maintain alignment with CSP's security objectives and protect cloud customer data from emerging risks effectively.

In plain English

Annually reviews information security policies for adequacy, considering organizational, technical, and legal changes. 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.

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 Policy Management, the assessor will trace your implementation back to the catalogue reference (Criterion SP-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.

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

• Information. Document the trigger, the owner and the cadence.
• Risk. Document the trigger, the owner and the cadence.
• Review. 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.
• Scope: security policy, cloud customer data, changes, management.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Signed policy or standard documents the safeguard. Focus: Review and Approval of Policies and Instructions.

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.
• 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.

• HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
• ISO/IEC 27001:2022 A.5.23 — Information security for use of cloud services
• NIST SP 800-53 Rev. 5 CM-3(7) — Review System Changes
• NIST SP 800-171 Rev. 3 3.12.3 — Continuous Monitoring
• CIS Controls v8 3.5 — Securely Dispose of Data

Related controls in BSI C5:2020

• Criterion SP-03 — Exceptions from Existing Policies and Instructions
• Criterion SP-01 — Documentation, communication and provision of policies and instructions
• Criterion OIS-05 — Contact with Relevant Government Agencies and Interest Groups
• Criterion OIS-06 — Risk Management Policy
• 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 SP-02

Topics: governance riskcloud posturepolicy management