ISO 27001 Incident Management Workflow: A Practical Template for SMEs

Illustration of SME team managing an ISO 27001 incident workflow with laptops, dashboards, incident logs, and checklists for structured information security handling.

For SMEs and startups, information security incidents are a realistic operational risk that may arise as systems scale, teams grow, or third parties are introduced. ISO/IEC 27001:2022 suggests that organisations may benefit from demonstrating that information security incidents are identified, assessed, documented, escalated, and reviewed using a structured and repeatable approach.

Organisations often utilise structured templates to assist in consistent handling during incidents, support contractual and regulatory reporting expectations, and maintain clearer evidence of how incidents are handled – without necessarily requiring enterprise-grade tooling.

This guide explores a practical incident management workflow step by step, outlines how it typically aligns with ISO 27001 expectations during certification audits, and highlights pragmatic implementation approaches that may be suitable for lean teams. Suitability depends on the organisation’s context and risk profile.

What ISO 27001 Means by “Incident Management”

In ISO/IEC 27001:2022, incident management refers to how an organisation identifies, assesses, responds to, and learns from information security incidents over time. The Standard places emphasis on having a defined and repeatable approach, rather than advanced tooling or a dedicated security operations centre.

In practice, ISO 27001 focuses on whether an organisation can demonstrate that:

  • Security-related events are identified and assessed in a consistent manner
  • Confirmed information security incidents are handled using an agreed process
  • Roles and responsibilities for incident handling are understood
  • Relevant evidence is collected and retained appropriately
  • Insights from incidents are used to support continual improvement of the ISMS, consistent with the PDCA cycle

Key ISO/IEC 27001:2022 Controls Commonly Involved

The following Annex A controls are typically associated with incident management activities:

  • A.5.5 – Contact with authorities
  • A.5.24 – Information security incident management planning and preparation
  • A.5.25 – Assessment and decisions on information security events
  • A.5.26 – Response to information security incidents
  • A.5.27 – Learning from information security incidents
  • A.5.28 – Collection of evidence
  • A.8.15 – Logging
  • A.8.16 – Monitoring activities

Event vs Incident

In the context of ISO/IEC 27001:2022, a clear distinction between events and incidents is commonly examined during audits, as it influences how organisations assess, escalate, and respond to security-related occurrences.

  • Event: An observable occurrence that may have information security relevance (for example, a suspicious log entry, a phishing email, or a lost device).
  • Incident: An event that has been assessed and is considered to have an actual or potential impact on the confidentiality, integrity, or availability of information.

A commonly used incident management workflow typically describes how events are reviewed and, where appropriate, escalated into incidents. Treating all events as incidents may lead to unnecessary escalation, while failing to assess events could result in inconsistent handling or delayed response to actual security issues.

Step 0 – Training and Awareness

Before security incidents occur, organisations may choose to provide staff with a basic understanding of how to recognise and report potential security-related events. Training and awareness activities are often used to support consistent incident identification and escalation.

Training content may include:

  • How to recognise common information security events
  • How and where to report suspected events
  • Actions that are generally discouraged during an incident (for example, deleting logs or altering systems)
  • General escalation expectations

Examples of records that are commonly used as supporting evidence include:

  • Training attendance or completion records
  • Onboarding or induction materials
  • Periodic refresher confirmation

These activities are commonly aligned with Clause 7.2 (Competence) and may support consistent identification and handling of events and incidents.

Step 1 – Identification and Detection

Information security incidents are typically identified through a combination of technical signals and human observation. Detection activities may originate from multiple sources, including:

  • System alerts or logs entries
  • Reports from users or staff
  • Notifications from suppliers or service providers
  • Feedback or complaints from clients

For small and medium-sized organisations, detection activities often rely on proportionate and practical mechanisms rather than specialised security tooling. Examples may include:

  • Cloud service audit logs
  • Automated email or platform alerts
  • Manual reporting by staff or contractors

In ISO 27001, the focus is generally on awareness, timely identification, and proportionate follow-up, rather than the use of specific technologies or tools.

Step 2 – Reporting

Clear and simple reporting mechanisms are commonly used to encourage timely notification of potential information security events. Many organisations make use of a standard incident reporting template to support consistency and reduce uncertainty during reporting.

Pre-Reporting Checklist

Before submitting a report, the reporter may be asked to provide basic contextual information, such as:

  1. What was observed
  2. When the observation occurred
  3. Which systems, services, or data may be involved
  4. Any actions taken since the observation was made

Practice Note:

  • Logging minor or low-impact events is commonly viewed as helpful for demonstrating awareness and continuous improvement, but organisations should determine the approach that fits their risk profile.
  • Extended periods with no recorded events may prompt further questions during reviews.

Step 3 – Triage and Classification (A.5.25)

Following initial reporting, organisations commonly perform a triage and classification step to understand the nature and potential significance of the reported occurrence. This activity supports consistent handling of events and incidents.

Common factors organisations may evaluate during triage include:

  • Impact (for example, low, medium, high, or critical)
  • Scope, including affected systems, data, process, or users
  • Potential regulatory or contractual exposure

Based on this assessment, decisions are typically made regarding:

  • Whether the occurrence remains an event or is classified as a confirmed incident
  • Whether immediate containment actions may be appropriate
  • Whether escalation to additional roles or functions is warranted

Triage and classification practices may be documented to support a repeatable process within an incident management approach.

Step 4 – Investigation and Containment (A.5.26)

During this step, organisations typically investigate confirmed incidents and take containment actions to limit potential impact. Roles or responsibilities may be assigned to manage the investigation, depending on available staff and expertise.

Typical containment actions for SMEs or startups may include:

  • Revoking access for affected accounts or users
  • Resetting passwords to prevent further unauthorised access
  • Isolating compromised accounts or devices
  • Temporarily suspending affected services

The specific containment actions required depend entirely on the technical nature of the incident and the organisation's unique risk profile.

These activities may support efforts to limit potential impact and preserve evidence for further assessment and learning. Documenting investigation and containment actions may support ISO 27001 clauses on incident response and evidence collection, and can help teams follow a repeatable approach.

Chain of Custody – Collection of Evidence (A.5.28)

When evidence is needed, organisations may take steps to preserve it without alteration:

  • Avoid unnecessary system reboots
  • Do not overwrite or delete logs
  • Capture screenshots, logs, and timestamps
  • Store evidence securely and restrict access to authorised staff

Even in small environments, demonstrating preserved evidence may support the evaluation of incident management practices and related ISO 27001 controls.

Step 5 – Resolution, Recovery, and Reporting Obligations

After containment, organisations may take steps to return to normal operations:

  • Restore affected systems and services
  • Verify system integrity and monitor accounts for residual unauthorised activity as appropriate for the context
  • Document the final resolution and any lessons learned

External, Regulatory, and Contractual Reporting (A.5.5)

Reporting obligations are context-dependent and may include:

  • Enterprise clients, often via Data Processing Agreements (DPAs) with 24 – 48 hours notification expectations
  • Regulators typically require notification within 72 hours of the organisation becoming aware of the breach
  • Law enforcement, if applicable and relevant

SMEs may find that contractual notification timelines are sometimes stricter than legal obligations. As these may be reviewed during audits, organisations should verify the specific obligations within their unique contracts and jurisdictions.

Maintaining minimal records of notifications, such as timestamps, communications, and summaries of findings, may assist with documentation practices, depending on the organisation’s context.

Step 6 – Post-Incident Review and Management Review

After incidents are resolved, organisations may conduct a structured review, considering factors such as:

  • Root cause analysis
  • Evaluation of control effectiveness
  • Identification of gaps or weaknesses
  • Opportunities for process or policy improvements

Root cause analysis may be performed by individuals with suitable technical and operational competence.

Outcomes of this review may inform:

  • Updates to the Risk Register
  • Adjustments to policies or procedures
  • Discussions during the Management Review Meeting (Clause 9.3)

These activities may contribute to the PDCA cycle and support ongoing improvement of information security practices. For example, a minor data access incident may prompt a review of account deprovisioning procedures or additional staff awareness training.

Step 7 – Record-Keeping and Evidence Retention

Organisations may maintain records such as:

  • Incident log
  • Investigation notes
  • References to collected evidence
  • Reporting confirmations
  • Follow-up actions

For SMEs and startups, keeping records may be done using simple tools such as a version-controlled spreadsheet or a dedicated channel in collaboration software. This is intended to provide a traceable record without enterprise-grade systems.

Audit Reality Check: Organisations often record entries in logs and records as part of incident management practices. Even minor events can be noted to show awareness and engagement with the incident management process.

When an Incident Becomes a Non-conformity (Clause 10.1)

Not all incidents are treated as non-conformities. In some cases, incidents may be recorded as Non-conformities when they are associated with:

  • A failed internal process
  • A policy that was not followed
  • A known control gap

Where applicable, corrective actions may be tracked to support continuous improvement. This may also help demonstrate a structured approach to incident and ISMS management.

Example: If an employee’s access is not revoked after leaving the company and this leads to data exposure, this incident may be logged as a Non-conformity, with follow-up actions recorded.

Incident Management vs External Reporting

This table summarises the key distinctions between handling incidents internally and fulfilling external reporting obligations under ISO 27001.

Feature

Incident Management (A.5.24)

External Reporting (A.5.5)

Focus

Restore operations

Legal or contractual compliance

Trigger

Confirmed incident

Personal data exposure or legal / contractual breach

Output

Incident log and lessons learned

Notifications, receipts

Real-World SME Example: Lost Laptop

For illustrative purposes only, consider how a small team might handle a lost device scenario. Note that this is not a recommended response for every situation.

  1. Employee reports lost device – Reporting may occur via email, ticket system, or internal alert.
  2. Event logged immediately – Logging the event in an incident register or simple spreadsheet helps track details.
  3. Classified as high severity – Severity may be assessed based on potential client data exposure or regulatory impact.
  4. Remote wipe may be performed – If supported by available tools, remote wipe can limit data exposure.
  5. Client notified per Data Processing Agreements (DPA) – Notification timelines depend on contractual obligations, often 24 – 48 hours. Always refer to your specific signed agreements.
  6. Incident reviewed – Team may review the event to identify lessons learned or process improvements.
  7. Asset policy updated – Policies may be revised to reflect lessons learned or control enhancements.

This illustrative example demonstrates a practical approach a small team might take when handling a lost device scenario.

SME-Friendly Tooling for Incident Tracking

Small teams often use simple tools to log and manage information security events and incidents. These illustrative examples include:

  • Locked Jira board – Provides controlled access to track reported events and follow-up actions.
  • Dedicated Slack channel + form – Allows team members to report incidents quickly while maintaining an audit trail.
  • Version-controlled spreadsheet – Supports tracking of incidents, actions taken, and outcomes.
  • Secure document repository – Stores evidence, investigation notes, and related documentation in a controlled location.

For SMEs, ISO 27001 audits typically focus on processes, records, and evidence, rather than the specific software used. These tools may support compliance and structured incident tracking without requiring enterprise-grade systems. 

TL;DR – Incident Management for Small Teams

For SMEs and startups, managing information security incidents can be simplified into key practices:

  • Train people first – Build awareness so staff can recognise and report events.
  • Log events early – Capture details promptly to support follow-up and evidence collection.
  • Escalate consistently – Decide when an event becomes an incident and involve appropriate roles.
  • Preserve evidence – Record logs, screenshots, and timestamps carefully.
  • Meet client and legal deadlines – Consider contractual obligations (e.g. DPAs) and regulatory timelines.
  • Review incidents in management meetings – Use lessons learned to improve processes.
  • Keep real records – Document actions and follow-ups rather than maintaining blank templates.

These practices may help small teams maintain a structured incident workflow and support alignment with ISO 27001 principles, including event handling, reporting, and continuous improvement.

Why This Workflow May Be Helpful for ISO 27001 Audits

This incident management workflow may support small teams in aligning with ISO 27001 principles and Annex A controls:

  • Alignment with Annex A.5.24 – A.5.28 and A.5.5 – Covers planning, event assessment, incident response, evidence collection, and contact with authorities.
  • Supports key clauses – Links to Clause 7.2 (competence), Clause 9.3 (management review), and Clause 10.1 (non-conformities).
  • Suitable for lean teams – Designed to be practical without enterprise-grade tools.
  • May help provide documentation of incident management activities; suitability will depend on organisational context.
  • Flexible as the organisation grows – Can scale and adapt to additional roles or formalised processes.

Using this workflow may help teams demonstrate a repeatable approach to incident handling, while remaining mindful of contractual and regulatory obligations.

Final Note

This incident management workflow is intended to assist SMEs and startups in handling information security incidents thoughtfully and efficiently. Following these steps may help teams demonstrate a repeatable approach, support non-conformity tracking, and contribute to continuous improvement within the ISMS. While using templates and workflows cannot guarantee certification, they can support structured implementation and evidence of consistent practices.

Next Step: Discover our ISO 27001 templates to help small teams keep policies, risk registers, and essential records organised efficiently and practically.

Next Article: In Exploring Evidence Collection: A Perspective on ISO 27001 Annex A.5 for SMEs, we move from workflow theory to practice, showing SMEs how to document operations for reference for audit preparation without generating excessive paperwork.

Related Guides

Explore these ISO 27001 resources to help your SME build a practical, lean ISMS:

Start Here: Complete Guide

Practical Checklists and Essential Documents – Detailed Guides by Topic

Please Note: This article provides general information only and does not constitute legal, regulatory, or compliance advice. Using our products or following this guidance cannot guarantee certification, improved business outcomes, or regulatory compliance. Organisations remain responsible for ensuring all actions meet certification and compliance requirements.

This article also mentions examples of commonly used tools. Chill Compliance does not endorse any vendor and has no commercial or affiliate relationship with the providers listed. These examples are for general information only, and readers may wish to evaluate each tool independently, as features and pricing can vary.