ASD ISM 1478 CISO Management of Cyber Security Compliance
What it says
The CISO oversees their organisation's cyber security program and ensures their organisation's compliance with cyber security policy, standards, regulations and legislation.
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What it means
In plain EnglishThe CISO is responsible for managing the organisation's cyber security and ensuring compliance with relevant standards and laws.
The Chief Information Security Officer (CISO) is like the captain of a ship when it comes to steering an organisation's cyber security. They are tasked with ensuring that the company follows all the rules and laws to protect its digital assets. If this isn't done correctly, the organisation risks facing fines, loss of customer trust, or even legal action if they fail to protect their information properly.
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Why it matters
Without CISO oversight of cyber security compliance, policy and regulatory gaps persist, increasing breach likelihood, audit findings, and penalties.
How to implement
CISO or head of IT should regularly meet with the legal team to review current cyber security laws and regulations.
This can be done by scheduling a quarterly meeting to go over any changes in legislation and assess how these impact the organisation.
The IT manager should establish a clear cyber security policy that aligns with local regulations.
This involves writing a policy document that outlines procedures for data protection, incident response, and employee responsibilities.
HR should ensure that all employees receive regular training about cyber security policies and compliance.
This can be achieved by organising annual training sessions and quizzes to reinforce key principles and policies.
The CISO or compliance officer should perform regular audits of the organisation's IT systems to ensure compliance.
They can do this by setting a schedule for auditing systems against established standards and documenting any findings.
The procurement team should make sure that any software or tech solutions purchased meet compliance requirements.
This involves reviewing vendor contracts and certifications that guarantee compliance with relevant standards.
Keep it running
Define CISO accountability for compliance, keep a policy/standards compliance register, and require periodic CISO-led reviews and audit remediation reporting.
Evidence and audit
- Check 1 of 5What an auditor asks for
Ask for
The latest cyber security policy document: Request to see the current version of the policy to ensure it includes all necessary compliance details.
Look at
Sections that reference specific laws and standards that apply to the organisation.
Good evidence
Includes a detailed policy aligned with current regulations and dated updates.
- Check 2 of 5What an auditor asks for
Ask for
Records showing attendance and completion of cyber security training.
Look at
The attendance list and training content to verify they cover key compliance topics.
Good evidence
Includes comprehensive records and evidence of recent sessions.
- Check 3 of 5What an auditor asks for
Look at
The listed items to see if past issues were addressed and check the audit frequency.
Good evidence
Audit is detailed, with clear follow-up actions and evidence of resolution.
- Check 4 of 5What an auditor asks for
Ask for
Procurement guidelines for technology purchases: Review documents that outline how tech purchases are evaluated for compliance.
Look at
Criteria that assess vendor adherence to standards.
Good evidence
Will be guidelines that include a vendor compliance check as a mandatory step.
- Check 5 of 5What an auditor asks for
Ask for
To see how incident response procedures ensure compliance with laws.
Look at
When the plan was last updated and what steps are taken after an incident.
Good evidence
Has an up-to-date plan that includes steps for regulatory reporting.
Mappings
Closest match in ISO/IEC 27001: A.5.1, Policies for information security, which partially overlaps with this control.
ISO/IEC 27001: 5 mappings
This control partially overlaps A.5.1.
ISM-1478 requires the CISO to oversee the cyber security program and ensure compliance with cyber security policy, standards, regulations and legislation. Annex A 5.1 relates by requiring information security policies to be defined, management-approved, communicated, acknowledged and reviewed, which are key artefacts and processes used to drive and evidence compliance. ISM-1478 is broader in encompassing compliance to external obligations and overall program oversight, while Annex A 5.1 is focused on the lifecycle and governance of policy documentation and communication.
This control partially overlaps A.5.2.
Annex A 5.2 requires information security roles and responsibilities to be defined and allocated according to organisational needs. ISM-1478 overlaps by assigning the CISO responsibility to oversee the cyber security program and ensure compliance with obligations, which is an explicit allocation of security governance accountability. ISM-1478 is narrower (CISO oversight and compliance assurance), while Annex A 5.2 is broader and covers all roles, not only the CISO.
This control partially overlaps A.5.4.
ISM-1478 makes the CISO accountable for overseeing the cyber security program and ensuring organisational compliance with cyber security requirements. Annex A 5.4 supports this by placing responsibility on management to require personnel to follow the organisation's information security policies and procedures, which is a key operational driver of compliance outcomes the CISO oversees. Annex A 5.4 is narrower because it focuses on management direction to personnel, while ISM-1478 encompasses broader compliance obligations (including legislation and regulations) and program governance.
This control partially overlaps A.5.31.
ISM-1478 requires the CISO to oversee the cyber security program and ensure the organisation complies with applicable policy, standards, regulations and legislation. Annex A 5.31 relates by requiring the organisation to identify, document and keep up to date legal, statutory, regulatory and contractual information security requirements and how they will be met. ISM-1478 is broader in assigning oversight/accountability for compliance, while Annex A 5.31 is more specific to maintaining a register/understanding of requirements rather than governing compliance execution end-to-end.
This control partially overlaps A.5.36.
ISM-1478 requires the CISO to oversee the organisation's cyber security program and ensure compliance with cyber security policies, standards, regulations and legislation. Annex A 5.36 supports this by requiring regular reviews of compliance with information security policies, rules and standards, providing an evidence-based mechanism the CISO can use to demonstrate and track compliance. Annex A 5.36 is narrower in that it focuses on periodic policy compliance review activities rather than overall compliance accountability across laws, regulations and the whole cyber security program.
ISO/IEC 42001: 1 mapping
This control partially overlaps A.8.5.
Annex A 8.5 requires the organisation to determine and document obligations to report AI systems information. ISM-1478 places accountability on the CISO for compliance, which may include AI-related disclosures. The overlap is on governance-driven compliance, but Annex A 8.5 is AI-specific, whereas ISM-1478 is broader.
ASD Essential Eight: 1 mapping
This control supports E8-RA-ML2.11.
ISM-1478 requires the CISO to oversee the cyber security program and ensure compliance with cyber security policy and related obligations. E8-RA-ML2.11 supports this by requiring cyber security incidents to be reported promptly to the CISO (or delegate), enabling governance, decision-making, and compliance actions such as notification, containment and reporting. E8-RA-ML2.11 is narrower because it only addresses incident reporting workflow, while ISM-1478 encompasses overall compliance management across the organisation.
Mappings show how controls relate across frameworks. They do not imply full equivalence or certification.