Everyone working with data protection and information security knows it: management plays a key role.
But what do the actual regulations say? In this article, we explore the key frameworks – ISO 27001, NIS2 and the GDPR – and what they require from management.
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To understand management’s role under ISO 27001, look to Clause 5.
Here, management is given three core responsibilities. They must:
The NIS2 Directive makes it crystal clear: information security is the responsibility of top management.
According to the directive, leaders are required to:
Members of the governing body can even be held personally liable for failing to meet these obligations.
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The GDPR doesn’t explicitly state that management is responsible. But the regulation imposes a wide range of obligations on organisations, and it is naturally the leadership that carries the overarching accountability.
Management obligations are outlined in Article 20 of the NIS2 Directive, which states:
1.Member States shall ensure that the management bodies of essential and important entities approve the cybersecurity risk-management measures taken by those entities in order to comply with Article 21, oversee its implementation and can be held liable for infringements by the entities of that Article.
The application of this paragraph shall be without prejudice to national law as regards the liability rules applicable to public institutions, as well as the liability of public servants and elected or appointed officials.
2. Member States shall ensure that the members of the management bodies of essential and important entities are required to follow training, and shall encourage essential and important entities to offer similar training to their employees on a regular basis, in order that they gain sufficient knowledge and skills to enable them to identify risks and assess cybersecurity risk-management practices and their impact on the services provided by the entity.
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