Information Security Policy
[ORGANIZATION NAME]
1. Purpose & Scope
Purpose: This policy establishes [ORGANIZATION]'s commitment to protecting information assets and maintaining the confidentiality, integrity, and availability of network and information systems. It serves as the master security policy governing all cybersecurity activities.
Scope: This policy applies to all employees, contractors, third parties, and systems that process, store, or transmit [ORGANIZATION] information or support essential services.
2. Regulatory Alignment
This policy satisfies requirements from:
 •	NIS2 Directive: Article 21(2)(a) - Risk analysis and information system security policies
 •	GDPR: Article 32 - Security of processing
 •	ISO 27001:2022: Control 5.1 - Information security policies
3. Roles & Responsibilities
Role	Responsibilities	
Management Body	Approve policy; oversee implementation; ensure adequate resources; accountability per NIS2 Article 20	
CISO / Security Officer	Develop and maintain policy; implement security controls; monitor compliance; report to management	
IT Operations	Implement technical controls; maintain systems; support security operations	
All Personnel	Comply with policy; report security incidents; complete security training; protect information assets	

4. Policy Statements
4.1 Information Security Governance
 1.	Management shall approve this policy and review it at least annually
 2.	Security responsibilities shall be clearly defined and assigned
 3.	Security objectives shall align with business objectives and regulatory requirements
4.2 Risk Management
 4.	Risk assessments shall be conducted at least annually and following significant changes
 5.	Identified risks shall be documented, prioritized, and assigned treatment plans
 6.	Risk treatment decisions shall be approved by management
4.3 Asset Management
 7.	All information assets shall be identified, inventoried, and classified
 8.	Asset owners shall be assigned and documented
 9.	Assets shall be protected according to their classification level
4.4 Access Control
 10.	Access to information systems shall be granted based on business need and least privilege
 11.	Multi-factor authentication shall be required for remote access and privileged accounts
 12.	Access rights shall be reviewed periodically and revoked when no longer required
4.5 Incident Management
 13.	Security incidents shall be reported immediately via designated channels
 14.	Incident response procedures shall be maintained and tested regularly
 15.	Significant incidents shall be reported to regulatory authorities per NIS2 requirements
4.6 Security Awareness & Training
 16.	All personnel shall complete security awareness training upon hire and annually thereafter
 17.	Specialized training shall be provided to personnel with security responsibilities
4.7 Third-Party Security
 18.	Third parties with access to systems or data shall be assessed for security risks
 19.	Security requirements shall be included in third-party agreements

5. Implementation Guidance
Area	Baseline	Enhanced	
Risk Assessment	Annual qualitative assessment; spreadsheet-based tracking	Continuous monitoring; quantitative analysis (e.g., FAIR); integrated GRC platform	
Governance	Annual management review; quarterly security updates	Board-level security committee; monthly executive dashboards; security scorecards	
Training	Annual e-learning; completion tracking	Role-based training; simulated phishing; security champions program; effectiveness metrics	
Note: Organizations designing risk assessment frameworks or governance structures often engage virtual CISO expertise to ensure methodology aligns with regulatory expectations and business context.
6. Exceptions
Exceptions to this policy require:
 20.	Written business justification documenting compensating controls
 21.	Risk assessment demonstrating acceptable risk level
 22.	Approval from [CISO/Security Officer] and relevant management
 23.	Annual review to confirm continued validity
7. Compliance & Review
Review Frequency: This policy shall be reviewed annually or following significant incidents, regulatory changes, or organizational changes.
Compliance Monitoring: Policy compliance shall be monitored through security audits, control testing, and incident analysis.
Non-Compliance: Policy violations may result in disciplinary action up to and including termination, in accordance with applicable employment laws.
8. Related Documents
 •	Risk Management Policy
 •	Incident Management Policy
 •	Access Control Policy
 •	Business Continuity & Disaster Recovery Policy
 •	Acceptable Use Policy
 •	NIS2 Incident Response Playbook

9. Document Control
Policy Owner:	[Chief Information Security Officer]	
Approval Authority:	[Management Body / Board]	
Effective Date:	[Date]	
Next Review Date:	[Date + 12 months]	
Version:	1.0	

Revision History
Version	Date	Author	Changes	
1.0	Dec 2025	Paolo Carner, BARE Consulting	Initial template release