First 90 Days Security Leader Checklist
Week-by-week actions across people, risk, controls, incidents, suppliers and reporting.
Available soon
- Format
- Excel
- Size
- 83 KB
- Length
- 12 sheets
- Version
- 1.0
- Updated
What's inside
What changed
- 1.0
Published.
Preview
The workbook's sheets as you will receive them, with its example rows and the values its formulas calculate. Highlighted [[text]] is for you to replace; rows marked EXAMPLE are for you to delete. Wide sheets scroll sideways. The cover, document control and changelog sheets are in the file.
Instructions
How to use this workbook
| Step | What to do |
|---|---|
| 1 | Use this workbook with the New Security Leader First 90 Days — Guide. The new security leader completes one copy, from the first day. The executive sponsor reads it at the reviews on day 30, day 60 and day 90. |
| 2 | On the 90 Days sheet, enter the start date, the as-at date and the names. Day 1 is the first day at work. Change the as-at date each time you open the workbook. The sheet works out the day, the week and the phase. |
| 3 | Start with the eight week 1 must-dos. Then work down the actions one week at a time. Promise nothing until it is checked (TR-04). Change nothing until discovery ends at the close of week 7, except to stop harm, to meet a legal duty or to take an action that is needed whatever the plan turns out to be (TR-01). |
| 4 | For each action choose a state. When an action is Done, enter the date and say where the record that shows it is kept. The column Record that shows it was done says what to keep. A statement alone is not a record. |
| 5 | An action past the end of its week shows as Overdue. Add a note and a new date. The sheet counts overdue actions. It does not turn them into a score. |
| 6 | On the Requirements sheet, choose a state for each of the sixteen requirements. Met needs the place where the evidence is kept. Not met needs a note and a name. The time limits at the top are house defaults. Change them to your own, and the latest dates change with them. |
| 7 | Read the risks table below the requirements. It shows, for each of the ten risks, how many of the requirements that answer it are met. |
| 8 | Before you act on anything in the first seven weeks, read the Not Early sheet. On the Who Does What sheet, write the name of each person who holds a role, and agree who is accountable for each activity. The decision-rights arrangement itself is in the Transition Decision Rights Matrix. |
| 9 | Review the checklist at day 30, day 60 and day 90, and the baseline and the calendar at the first anniversary (TR-15). Enter the reviewer and the date at the foot of the 90 Days sheet. Keep the completed workbook for the records period (TR-16). To clear the EXAMPLE, delete the EXAMPLE sheet. |
Legend
Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.
| EXAMPLE | Rows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval. |
The idea of this pack: Learn before you promise. Find out what is real, not what is claimed. Decide who decides. Show the starting position, so that progress can be shown.
TR-01: Change no policy, tool, team structure or priority until discovery ends at the close of week 7, except to stop harm, to act on a legal duty or to take a no-regret action. Spend the first three weeks listening.
TR-04: Promise nothing until it is checked. A commitment is recorded as Committed only after the new leader has checked that it can be kept, and says how. Anything else is recorded as Noted, not committed, or Declined, with the reason.
Related documents: Inherited Security Programme Discovery Workbook (what the programme really does), Stakeholder Interview Guide & Record, Security Function Handover Document, Transition Decision Rights Matrix, 100-Day Security Plan, First-Year Security Operating Calendar, First Executive Briefing Deck for a New Security Leader and Security Posture Baseline Scorecard.
This document helps a new head of security, and the one who is leaving, to hand over and take over a security function. It is not legal advice and not advice on employment. It does not say that you comply with NIS2 or any standard. What liability means for a member of a management body, what an outgoing leader may be asked to hand over under their contract, and whether your organisation is an essential or an important entity are for counsel to confirm.
EXAMPLE: Kestrel Components B.V. (EXAMPLE), a manufacturer of industrial pumps and valves in an EU Member State, with about 600 staff and two plants, as at 2026-09-30. The EXAMPLE sheet shows nine of the actions and six of the requirements, each tied to a dated fact.
Hidden columns hold the workings of the counts and the lists. Leave them as they are.
Adapting this template.
Small organisation: one person often holds several of the roles on the Who Does What sheet. The head of security may report to the chief executive, who is then also the executive sponsor. Where one person has two roles, write the name against both roles. Where a role does not exist, choose Not applicable and say why, and do not delete the row.
Regulated organisation: add columns to the right of the calculated ones for what your regulator asks of a change of security leader, such as a notification of the appointment. Do not insert columns inside the tables, because the formulas read them by position. Move the time limits on the Requirements sheet to your own.
Service provider or outsourced IT: where an outsourced provider runs your IT or your security service, send the actions that ask for an extract, a log or a test record to the provider in writing, and keep its reply as the record. Record what it could not show as Not met, with the name of the person who will chase it.
Where the outgoing leader has already gone, the handover is built from records (TR-06). Mark WK-06 In progress until the gaps are listed, and do not mark an action Done on the strength of what a colleague remembers.
Replace the [[placeholders]]. Delete the EXAMPLE sheet before use. Keep the formulas.
The time limits on the Requirements sheet are house defaults. Change them to your own, and the latest dates change with them.
90 Days
First 90 days: the weekly actions
Enter the start date and the as-at date. Yellow cells are yours. The due dates, the status, the counts and the Check column calculate. Counts only, never a score.
The start
| Start date (day 1) | [[YYYY-MM-DD]] | |||
| As at date | [[YYYY-MM-DD]] | |||
| New security leader | [[name of the new Head of Information Security or CISO]] | |||
| Executive sponsor | [[e.g. chief executive or chief operating officer]] | |||
| Outgoing security leader | [[name of the predecessor]] | |||
Where you are
Today
This phase is for
| Actions | 0 of 40 applicable actions done; 0 in progress, 40 not started, 0 not applicable, 0 overdue | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Overdue | None | |||||||||
| Week 1 must-dos | 0 of 8 week 1 must-dos done | |||||||||
| Requirements | 0 of 16 applicable requirements met; 0 not met, 16 not checked; 0 past their dates | |||||||||
By phase
| Phase and weeks | What the phase is for | Actions | Done | In progress | Not started | Not applicable | Overdue | |||
|---|---|---|---|---|---|---|---|---|---|---|
| Listen (weeks 1 to 3) | Meet people, read what exists, and promise nothing. Learn who expects what. | 18 | 0 | 0 | 18 | 0 | 0 | |||
| Verify (weeks 4 to 7) | Check what you were told against a record, a test or a system. End with the first executive briefing. | 15 | 0 | 0 | 15 | 0 | 0 | |||
| Decide (weeks 8 to 10) | Choose the few priorities the findings support, agree the decision rights, and settle the plan. | 5 | 0 | 0 | 5 | 0 | 0 | |||
| Propose (weeks 11 to 13) | Take the plan, the reporting rhythm and the asks to the executives and the management body. | 2 | 0 | 0 | 2 | 0 | 0 | |||
| All actions | 40 | 0 | 0 | 40 | 0 | 0 | ||||
By area
| Area | Actions | Done | In progress | Not started | Not applicable | Overdue | ||||
|---|---|---|---|---|---|---|---|---|---|---|
| People | 9 | 0 | 0 | 9 | 0 | 0 | ||||
| Risk | 5 | 0 | 0 | 5 | 0 | 0 | ||||
| Controls | 8 | 0 | 0 | 8 | 0 | 0 | ||||
| Incidents | 4 | 0 | 0 | 4 | 0 | 0 | ||||
| Suppliers | 4 | 0 | 0 | 4 | 0 | 0 | ||||
| Reporting | 10 | 0 | 0 | 10 | 0 | 0 | ||||
| All actions | 40 | 0 | 0 | 40 | 0 | 0 | ||||
Counts of actions, never a share.
The actions, WK-01 to WK-40
| ID | Week | Phase | Area | Action | Due (end of its week) | State | State now | Date done | Status | Carries out | Week 1 must-do | Record that shows it was done | Where the record is kept | Note | Check |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| WK-01 | 1 | Listen | People | Meet the executive sponsor. Ask what they expect in 90 days, what worries them, and what was promised. | Not started | TR-03 | Yes | Interview record (A04) | Choose a state | ||||||
| WK-02 | 1 | Listen | People | Agree your appointment, reporting line and authority in writing, and ask for the role description. | Not started | TR-05 | Yes | A signed or emailed note from the sponsor | Choose a state | ||||||
| WK-03 | 1 | Listen | Incidents | List every open incident and every open reporting duty. Confirm in writing who holds each incident role and who deputises. | Not started | TR-09 | Yes | The list, and a note naming the role holders | Choose a state | ||||||
| WK-04 | 1 | Listen | Controls | Confirm that the outgoing leader's accounts, administrator rights, tokens and vendor portal logins are removed. | Not started | TR-08 | Yes | A fresh extract that shows the removal | Choose a state | ||||||
| WK-05 | 1 | Listen | Reporting | Read the last board report, the risk register, the exception register and the last audit report. Change nothing. | Not started | TR-01 | Yes | Your reading notes | Choose a state | ||||||
| WK-06 | 1 | Listen | People | Collect the handover document the outgoing leader left, or build it from records, and mark every gap. | Not started | TR-06 | Yes | The handover document (A05) with its gaps | Choose a state | ||||||
| WK-07 | 1 | Listen | Suppliers | List the critical suppliers, the incident responders, the insurer and the regulator contacts, to confirm one by one. | Not started | TR-10 | Yes | A contact list with a confirmed-on column | Choose a state | ||||||
| WK-08 | 1 | Listen | Reporting | List every deadline in the next 90 days: audits, reports, renewals, regulator dates and customer commitments. | Not started | TR-04 | Yes | A dated list (start of A08) | Choose a state | ||||||
| WK-09 | 2 | Listen | People | Interview the executives and the chair of the management body. | Not started | TR-03 | Interview records (A04, IV-01 and IV-02) | Choose a state | |||||||
| WK-10 | 2 | Listen | People | Interview the heads of IT, legal, HR and finance. | Not started | TR-03 | Interview records (A04, IV-03 to IV-06) | Choose a state | |||||||
| WK-11 | 2 | Listen | Risk | Read the risk register end to end. Note who owns each risk and when it was last reviewed. | Not started | TR-02 | Notes against the register | Choose a state | |||||||
| WK-12 | 2 | Listen | Controls | Ask for the policy register and the open findings of the last internal or external audit. | Not started | TR-02 | Both documents, as received | Choose a state | |||||||
| WK-13 | 2 | Listen | Incidents | Read the incident log for the last 12 months and the incident response plan. Note what was learnt and what stayed open. | Not started | TR-09 | Notes against the log | Choose a state | |||||||
| WK-14 | 3 | Listen | People | Interview the business owners, internal audit and your own team. | Not started | TR-03 | Interview records (A04, IV-07, IV-09 and IV-10) | Choose a state | |||||||
| WK-15 | 3 | Listen | Suppliers | Read the supplier register. List suppliers by tier and book the interviews with the critical ones. | Not started | TR-10 | The list and the bookings | Choose a state | |||||||
| WK-16 | 3 | Listen | Risk | List every inherited exception and risk acceptance with its review date. Mark those past it. | Not started | TR-07 | The list, with past-review items marked | Choose a state | |||||||
| WK-17 | 3 | Listen | Reporting | Meet the board secretary. Learn the board calendar and the format of the papers. | Not started | TR-11 | The calendar dates in A08 | Choose a state | |||||||
| WK-18 | 3 | Listen | Controls | Open the discovery workbook (A03). Start with the areas the interviews raised. | Not started | TR-02 | Findings entered, each with what was seen | Choose a state | |||||||
| WK-19 | 4 | Verify | Controls | Check access. Take an extract of leavers and of privileged accounts and compare it with the HR record. | Not started | TR-02 | The extract and the comparison | Choose a state | |||||||
| WK-20 | 4 | Verify | Risk | Review every inherited exception and acceptance that is past its review date. Renew, change or close each, by the approver its band sets. | Not started | TR-07 | A decision on each, in the register | Choose a state | |||||||
| WK-21 | 4 | Verify | Incidents | Check the record of the last incident exercise and the post-incident review of the latest incident. | Not started | TR-02 | The two records, or a finding of Not found | Choose a state | |||||||
| WK-22 | 4 | Verify | Suppliers | Interview the critical suppliers and confirm each contact by a call. Check the last assessment of each Tier 1 supplier. | Not started | TR-10 | Contacts confirmed; assessment dates | Choose a state | |||||||
| WK-23 | 5 | Verify | Controls | Ask for evidence of vulnerability handling: the last scan, the patch records and the overdue exposure. | Not started | TR-02 | The records, or a finding of Not found | Choose a state | |||||||
| WK-24 | 5 | Verify | Controls | Ask for the last backup restore test. Check which critical systems have had one. | Not started | TR-02 | The test record, or a finding of Not found | Choose a state | |||||||
| WK-25 | 5 | Verify | People | Check the awareness completion records, and the training records of the management body. | Not started | TR-02 | The completion register | Choose a state | |||||||
| WK-26 | 5 | Verify | Reporting | Find what the organisation has promised to regulators, customers and auditors. Build the commitments list. | Not started | TR-04, TR-06 | The list, with a due date and an owner for each | Choose a state | |||||||
| WK-27 | 6 | Verify | Risk | Test two controls the programme says it runs. Take a sample of records and inspect each against what the control says. | Not started | TR-02 | The sample and the result | Choose a state | |||||||
| WK-28 | 6 | Verify | Controls | Review the policy register: documents past their review date, and documents in force without approval. | Not started | TR-02 | The two counts, and the documents | Choose a state | |||||||
| WK-29 | 6 | Verify | Reporting | Record the baseline from the findings: counts, levels in words, and Unknown with a reason. | Not started | TR-12 | The baseline (A10) | Choose a state | |||||||
| WK-30 | 6 | Verify | Suppliers | Check the supplier register against what you now know. Note any critical supplier not in it. | Not started | TR-02 | A note, and a finding for each difference | Choose a state | |||||||
| WK-31 | 7 | Verify | Reporting | Close discovery. Count the findings in the four words and list every contradiction. Write the first briefing. | Not started | TR-13 | The counts and the briefing deck (A09) | Choose a state | |||||||
| WK-32 | 7 | Verify | People | Tell each group you interviewed what you heard. Promise nothing new. | Not started | TR-04 | A short message to each group | Choose a state | |||||||
| WK-33 | 7 | Verify | Reporting | Hold the first executive briefing, at the end of the week. | Not started | TR-13 | The decisions asked and the answers | Choose a state | |||||||
| WK-34 | 8 | Decide | Risk | Choose the few top risks the findings support. Put each on the register with an owner. | Not started | TR-14 | Register entries | Choose a state | |||||||
| WK-35 | 8 | Decide | People | Settle the transition arrangement for decision rights with the sponsor, and review it at day 60. | Not started | TR-05 | The arrangement (A06), agreed in writing | Choose a state | |||||||
| WK-36 | 8 | Decide | Reporting | Tell the management body, through the sponsor, what NIS2 Article 20 asks of it. | Not started | TR-11 | A short briefing note and a minute | Choose a state | |||||||
| WK-37 | 9 | Decide | Controls | Draft the 100-day plan from the findings. Mark quick wins, stabilisation and strategic decisions. | Not started | TR-14 | The plan (A07) | Choose a state | |||||||
| WK-38 | 10 | Decide | Incidents | Decide whether the incident plan needs an update or a new exercise, as P09 IM-12 asks. | Not started | TR-14 | A decision in the plan | Choose a state | |||||||
| WK-39 | 11 | Propose | Reporting | Take the plan, the reporting rhythm and the asks to the executives. Agree the plan in writing. | Not started | TR-14 | The agreed plan | Choose a state | |||||||
| WK-40 | 13 | Propose | Reporting | Review the checklist, the findings and the plan at day 90. Set the calendar for the first year. | Not started | TR-15 | The review notes and the calendar (A08) | Choose a state |
Reviews
| Review | What to review | Due | Reviewed by (name) | Date reviewed | Note | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Day 30 review (TR-15) | The checklist, the discovery findings and the plan | [[Name]] | [[YYYY-MM-DD]] | ||||||||||
| Day 60 review (TR-15) | The checklist, the discovery findings and the plan | [[Name]] | [[YYYY-MM-DD]] | ||||||||||
| Day 90 review (TR-15) | The checklist, the discovery findings and the plan | [[Name]] | [[YYYY-MM-DD]] | ||||||||||
| First anniversary (TR-15) | The baseline and the calendar | [[Name]] | [[YYYY-MM-DD]] | ||||||||||
Requirements
The sixteen requirements, and the ten risks they answer
Choose a state for each requirement. Yellow cells are yours. The latest dates, the date status, the counts and the Check column calculate. The time limits below are house defaults: change them to your own.
Your time limits (house defaults)
| Decision rights agreed in writing, within this many working days of the start (TR-05) | 10 | Days count from the start date as day 1. Working days are Monday to Friday; add any public holidays by hand. | ||
| Inherited exceptions and acceptances reviewed, within this many days of the start (TR-07) | 30 | |||
| Contacts confirmed, within this many days of the start (TR-10) | 30 | |||
| Management body told what it must approve, within this many days of the start (TR-11) | 60 | |||
| Baseline recorded, within this many days of the start (TR-12) | 60 | |||
| Outgoing leader's access confirmed removed, within this many working days (TR-08) | 2 | |||
Where the requirements stand
| Requirements | 0 of 16 applicable requirements met; 0 not met, 16 not checked; 0 past their dates | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Not met | None | |||||||||
| Not checked | TR-01, TR-02, TR-03, TR-04, TR-05, TR-06, TR-07, TR-08, TR-09, TR-10, TR-11, TR-12, TR-13, TR-14, TR-15, TR-16 | |||||||||
| Past their dates | None | |||||||||
The requirements, TR-01 to TR-16
| ID | Area | Requirement | Risks it answers | Actions that carry it out | Actions done | Time limit | Latest date | State | State now | Evidence: what it is and where it is kept | Date checked | Put right by (name) | Note | Date status | Check |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| TR-01 | Learn first | Change no policy, tool, team structure or priority until discovery ends at the close of week 7, except to stop harm, to act on a legal duty or to take a no-regret action. Spend the first three weeks listening. | RK-01, RK-02, RK-08 | WK-05 | 0 of 1 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-02 | Evidence | Every discovery finding states what was seen: a record, a test result or a system view. A statement alone is Described only. A finding is checked again after [[6]] months, or on a material change. | RK-02, RK-01 | WK-11, WK-12, WK-18, WK-19, WK-21, WK-23, WK-24, WK-25, WK-27, WK-28, WK-30 | 0 of 11 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-03 | Interviews | Book an interview with every stakeholder group in A04 during the Listen phase and hold it by the end of week 4, with the same core questions, and record each interview in the record format: expectation, concern, commitment and follow-up. Interview before judging. | RK-08, RK-02 | WK-01, WK-09, WK-10, WK-14 | 0 of 4 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-04 | Commitments | Promise nothing until it is checked. A commitment is recorded as Committed only after the new leader has checked that it can be kept, and says how. Anything else is recorded as Noted, not committed, or Declined, with the reason. | RK-01, RK-05 | WK-08, WK-26, WK-32 | 0 of 3 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-05 | Decision rights | Agree the transition arrangement for decision rights in writing with the executive sponsor within [[10]] working days of the start, and review it at day 30, day 60 and day 90. The arrangement gives no right that the packs which set each right do not give. | RK-06, RK-01 | WK-02, WK-35 | 0 of 2 actions done | Within 10 working days of the start | Not checked | Choose a state | |||||||
| TR-06 | Handover | The outgoing leader completes the handover document (A05) before they leave. Where they have gone, the new leader builds it from records and writes down what is missing. A section with nothing in it says None, with a date, and who said so. | RK-05, RK-09, RK-04, RK-03 | WK-06, WK-26 | 0 of 2 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-07 | Inherited exceptions | Review every inherited exception and risk acceptance within [[30]] days of the start. One that is past its review date is renewed, changed or closed by the approver its band sets (P02 EX-05, P05 RM-08). Nothing continues by default. | RK-03, RK-06 | WK-16, WK-20 | 0 of 2 actions done | Within 30 days of the start | Not checked | Choose a state | |||||||
| TR-08 | Access | Remove the outgoing leader's access on the day they leave: accounts, administrator rights, tokens, shared secrets, vendor portals and any personal account used for work. Confirm the removal against a fresh extract within [[2]] working days, as P07 AR-07 asks of any removal. | RK-04, RK-09 | WK-04 | 0 of 1 actions done | On the day they leave; confirmed within 2 working days | Not checked | Choose a state | |||||||
| TR-09 | Incidents | In week 1, list every open incident and every open reporting duty, and confirm in writing who holds each incident role and who deputises (P09 IM-03). The roles, decision rights and clocks are P09's and P18's, unchanged. | RK-05, RK-06 | WK-03, WK-13 | 0 of 2 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-10 | Contacts | Confirm, by a call or a message and not from a list, the contacts at the regulator, the CSIRT, the insurer, the responders and each critical supplier within [[30]] days of the start. Record the date of each confirmation. | RK-09, RK-05 | WK-07, WK-15, WK-22 | 0 of 3 actions done | Within 30 days of the start | Not checked | Choose a state | |||||||
| TR-11 | Management body | Within [[60]] days of the start, tell the management body, through the executive sponsor, what NIS2 Article 20 asks of it: to approve the measures, to oversee their implementation and to follow training, and that it can be held liable. Counsel confirms what liability means. | RK-07, RK-06 | WK-17, WK-36 | 0 of 2 actions done | Within 60 days of the start | Not checked | Choose a state | |||||||
| TR-12 | Baseline | Record the baseline within [[60]] days of the start, in counts and in levels in words. Record an unknown value as Unknown, with a reason and the plan item that will find it out. Repeat the baseline in month 12, so that the comparison is ready at the first anniversary. | RK-10, RK-02 | WK-29 | 0 of 1 actions done | Within 60 days of the start | Not checked | Choose a state | |||||||
| TR-13 | First briefing | Brief the executives at the end of discovery with the findings in the four words, the top risks, the baseline and the asks. Make each ask as P03 BR-06 sets out: options, a recommendation, the cost and the risk of not deciding. | RK-01, RK-06, RK-07 | WK-31, WK-33 | 0 of 2 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-14 | Plan | Every item in the 100-day plan traces to a finding, an interview record, a handover gap or an inherited exception. The plan lists what was dropped and why. A promise outside the organisation follows the plan, and never leads it. | RK-01, RK-10 | WK-34, WK-37, WK-38, WK-39 | 0 of 4 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-15 | Review | Review this checklist, the discovery findings and the plan at day 30, day 60 and day 90, and the baseline and the calendar at the first anniversary. Record what changed and why. | RK-10, RK-03 | WK-40 | 0 of 1 actions done | No set limit | Not checked | Choose a state | |||||||
| TR-16 | Records | Keep the handover document, the interview records, the decision-rights arrangement and the plan for [[3]] years, the P22 records period, or longer where a contract or a law asks. | RK-05, RK-06 | No weekly action | No weekly action | No set limit | Not checked | Choose a state |
The ten risks, and how many of the requirements that answer each are met
| Risk | What could go wrong | Answered by | How many are met | ||
|---|---|---|---|---|---|
| RK-01 | The new leader promises a date, a budget or a result before learning what is real, and cannot keep it. | TR-01, TR-02, TR-04, TR-05, TR-13, TR-14 | 0 of 6 requirements met | ||
| RK-02 | The programme is described as doing more than it does, and the new leader builds on the description. | TR-01, TR-02, TR-03, TR-12 | 0 of 4 requirements met | ||
| RK-03 | Inherited exceptions and risk acceptances run past their review dates without anyone seeing them. | TR-06, TR-07, TR-15 | 0 of 3 requirements met | ||
| RK-04 | The outgoing leader's access, accounts or tokens stay live after they have gone. | TR-06, TR-08 | 0 of 2 requirements met | ||
| RK-05 | An open incident, a notification or a commitment to a customer, auditor or regulator is dropped at the handover. | TR-04, TR-06, TR-09, TR-10, TR-16 | 0 of 5 requirements met | ||
| RK-06 | Nobody is sure who decides, so a decision is taken twice, taken by the wrong person or not taken. | TR-05, TR-07, TR-09, TR-11, TR-13, TR-16 | 0 of 6 requirements met | ||
| RK-07 | The management body does not know what it must approve and oversee, or that it can be held liable (NIS2 Article 20). | TR-11, TR-13 | 0 of 2 requirements met | ||
| RK-08 | The new leader hears only one or two voices, and misses the people who know how the programme really runs. | TR-01, TR-03 | 0 of 2 requirements met | ||
| RK-09 | Contacts at the regulator, the responders, the insurer and the critical suppliers go with the outgoing leader. | TR-06, TR-08, TR-10 | 0 of 3 requirements met | ||
| RK-10 | In a year nobody can show what changed, because nobody recorded where the programme started. | TR-12, TR-14, TR-15 | 0 of 3 requirements met | ||
Counts of requirements, never a score. Each requirement answers at least one risk, and each risk is answered by at least two requirements.
Not Early
What not to do early, and the pitfalls
Read this before you act on anything in the first seven weeks. Learn before you promise. Nothing here changes a decision right: the earlier packs and the Transition Decision Rights Matrix own those.
What not to do early, NE-1 to NE-9
| ID | Do not | Until | Why | Your note |
|---|---|---|---|---|
| NE-1 | Announce a reorganisation, a new strategy or a new tool. | The Decide phase (week 8) | You do not yet know what works, who does it, or what it cost to get there. | |
| NE-2 | Rewrite or withdraw a policy, a standard or a procedure. | The Decide phase (week 8) | Policies are approved at a set level (P04 PF-03), and a change needs the reasons discovery gives. | |
| NE-3 | Promise a date, a budget or a result to the executives, a customer, an auditor or a regulator. | The plan is agreed (week 11) | Learn before you promise. A promise made in week 2 rests on what you were told. | |
| NE-4 | Accept or renew an inherited exception or risk acceptance without reading it. | Never. Read it first | Nothing continues by default (TR-07). Read the reason, the date and who approved it. | |
| NE-5 | Sign a statement or a form to a regulator or an auditor that you have not checked. | You have seen the evidence | A statement is held against the organisation and against you. | |
| NE-6 | Change who holds an incident role or how an incident decision is taken. | P09's own review of the plan | The roles and decision rights belong to the incident plan (P09 IM-03). Confirm them, and change nothing in a crisis. | |
| NE-7 | Criticise the outgoing leader or the earlier programme in front of others. | Never | The people who built it will tell you the most. Record what you find, not who is to blame. | |
| NE-8 | Buy a tool to fix a problem you have not yet shown to exist. | The Decide phase (week 8) | The finding comes first, then the choice, then the money. | |
| NE-9 | Treat what you were told as a finding. | You have seen a record, a test or a system view | A statement alone is Described only (TR-02). |
The ten pitfalls, NP-1 to NP-10
| ID | Pitfall | What to do instead | Your note | |
|---|---|---|---|---|
| NP-1 | Treating the handover document as the truth. | It is what the outgoing leader believed. Check each part against a record, a test or a system view (TR-02). | ||
| NP-2 | Promising a date, a budget or a result in the first weeks. | Note it, check it can be kept, and say so before you commit (TR-04). | ||
| NP-3 | Interviewing only the executives. | The team, IT, audit and the business owners know how the programme really runs (TR-03). | ||
| NP-4 | Changing things early for a quick, visible win. | Take only the no-regret actions. Everything else waits for the findings (TR-01). | ||
| NP-5 | Letting an inherited exception run because someone signed it. | Read it, check its date and band, and renew, change or close it by the right approver (TR-07). | ||
| NP-6 | Forgetting the outgoing leader's accounts, tokens and portal logins. | Remove them on the day they leave and confirm against a fresh extract (TR-08). | ||
| NP-7 | Assuming you hold every right the last leader held. | Read what each earlier pack gives the role, and agree the arrangement in writing (TR-05). | ||
| NP-8 | Blaming the outgoing leader in front of others. | Record what you find, not who is to blame. The people who built it will tell you the most. | ||
| NP-9 | Adding the baseline up into one number. | Record counts and levels in words, and the unknowns with their reasons (BL-01). | ||
| NP-10 | Briefing the management body in jargon, or not telling it what it must approve. | Say in plain words what NIS2 Article 20 asks of it, and ask counsel what liability means (TR-11). | ||
Who Does What
Who does what in the handover and the first 90 days
R is responsible, A is accountable (one for each activity), C is consulted and I is informed. Write the name of each person who holds a role. The roles that hold the decision rights are those the earlier packs name. This sheet gives none.
The activities, TX-01 to TX-13
| ID | Activity | Rule | New security leader | Outgoing security leader | Executive sponsor | Management body | HR | Legal | Data Protection Officer | Head of IT |
|---|---|---|---|---|---|---|---|---|---|---|
| TX-01 | Agree the appointment and the decision-rights arrangement | TR-05 | R | A | I | C | C | |||
| TX-02 | Complete the handover document | TR-06 | C | A | I | C | C | C | ||
| TX-03 | Remove the outgoing leader's access and confirm it | TR-08 | A | I | C | R | ||||
| TX-04 | Interview the stakeholder groups | TR-03 | A | C | ||||||
| TX-05 | Look for the proof and record the findings | TR-02 | A | C | C | C | C | |||
| TX-06 | Review the inherited exceptions and risk acceptances | TR-07 | A | C | I | C | ||||
| TX-07 | Confirm the incident roles and list the open incidents and duties | TR-09 | A | C | I | C | C | |||
| TX-08 | Confirm the regulator, responder and supplier contacts | TR-10 | A | C | R | |||||
| TX-09 | Tell the management body what NIS2 Article 20 asks of it | TR-11 | R | A | I | C | ||||
| TX-10 | Record the baseline | TR-12 | A | I | C | |||||
| TX-11 | Give the first executive briefing | TR-13 | R | A | I | C | ||||
| TX-12 | Agree the 100-day plan | TR-14 | R | A | C | C | C | |||
| TX-13 | Review the checklist, the findings and the plan at day 30, 60 and 90 | TR-15 | A | C | I |
The roles, and who holds each
| No. | Role | Name | What the role does | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| 1 | New security leader | [[name of the new Head of Information Security or CISO]] | Learns the programme, interviews the stakeholders, verifies what is claimed, keeps the discovery workbook, agrees the decision rights, proposes the plan and reports counts. Promises nothing until it is checked. | ||||||||
| 2 | Outgoing security leader | [[name of the predecessor]] | Completes the handover document, lists what they hold and have promised, introduces the new leader to contacts and hands over access and accounts. Where they have gone, the new leader builds the handover from records. | ||||||||
| 3 | Executive sponsor | [[e.g. chief executive or chief operating officer]] | Agrees the decision-rights arrangement and the plan in writing, opens doors to the other executives and the management body, and decides what only an executive may decide. | ||||||||
| 4 | Management body | [[the board, or the equivalent]] | Approves the cybersecurity risk-management measures and oversees their implementation (NIS2 Article 20), follows training, and receives the reports. | ||||||||
| 5 | HR | [[HR lead]] | Confirms the leaver and joiner records, the outgoing leader's departure date and notice terms, and the new leader's training and onboarding. | ||||||||
| 6 | Legal | [[in-house or external counsel]] | Confirms what the outgoing leader must hand over, what commitments to customers and regulators exist, and what the management body's liability means. | ||||||||
| 7 | Data Protection Officer | [[or the privacy lead where no DPO is appointed]] | Gives the new leader the records of processing, breach decisions and open data protection matters. | ||||||||
| 8 | Head of IT | [[Head of IT]] | Gives the new leader system views, the account inventory and the change calendar, and removes access. | ||||||||
Where one person holds two roles, write the name against both. Where a role does not exist in your organisation, say so in the name cell and agree who covers it.
EXAMPLE
EXAMPLE: Kestrel, three weeks into the role
Kestrel Components B.V. (EXAMPLE), a manufacturer of industrial pumps and valves in an EU Member State, with about 600 staff and two plants, as at 2026-09-30. Every value is made up. Nine of the forty actions and six of the sixteen requirements are shown. Delete this sheet before use.
The organisation and the day
| Organisation | Kestrel Components B.V. (EXAMPLE) | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| New security leader | Sam Okafor, Head of Information Security | |||||||||
| Start date (day 1) | 14 Sep 2026 | |||||||||
| As at date | 30 Sep 2026 | |||||||||
| Today | Day 17, week 3, Listen phase | |||||||||
Nine actions from the first weeks, as the new leader recorded them
| ID | Week | Phase | Area | Action | Due (end of its week) | State | State now | Date done | Status | Carries out | Week 1 must-do | Record that shows it was done | Where the record is kept | Note | Check |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| WK-01 | 1 | Listen | People | Meet the executive sponsor. Ask what they expect in 90 days, what worries them, and what was promised. | 20 Sep 2026 | Done | Done | 16 Sep 2026 | Done | TR-03 | Yes | Interview record (A04) | Interview record IR-01 | Met on 2026-09-15. The interview record is dated 2026-09-16. | OK |
| WK-04 | 1 | Listen | Controls | Confirm that the outgoing leader's accounts, administrator rights, tokens and vendor portal logins are removed. | 20 Sep 2026 | Done | Done | 16 Sep 2026 | Done | TR-08 | Yes | A fresh extract that shows the removal | A fresh extract of accounts, kept with the handover file | OK | |
| WK-09 | 2 | Listen | People | Interview the executives and the chair of the management body. | 27 Sep 2026 | Done | Done | 17 Sep 2026 | Done | TR-03 | Interview records (A04, IV-01 and IV-02) | Interview records IR-01 and IR-02 | OK | ||
| WK-10 | 2 | Listen | People | Interview the heads of IT, legal, HR and finance. | 27 Sep 2026 | Done | Done | 22 Sep 2026 | Done | TR-03 | Interview records (A04, IV-03 to IV-06) | Interview records IR-03 to IR-06 | OK | ||
| WK-14 | 3 | Listen | People | Interview the business owners, internal audit and your own team. | 4 Oct 2026 | Done | Done | 29 Sep 2026 | Done | TR-03 | Interview records (A04, IV-07, IV-09 and IV-10) | Interview records IR-07 to IR-09 | OK | ||
| WK-18 | 3 | Listen | Controls | Open the discovery workbook (A03). Start with the areas the interviews raised. | 4 Oct 2026 | In progress | In progress | Due this week | TR-02 | Findings entered, each with what was seen | Discovery workbook | 14 of 20 items looked at: 6 Evidenced, 5 Described only, 2 Not found, 1 Contradicted; 6 not yet looked at | OK | ||
| WK-19 | 4 | Verify | Controls | Check access. Take an extract of leavers and of privileged accounts and compare it with the HR record. | 11 Oct 2026 | Done | Done | 24 Sep 2026 | Done | TR-02 | The extract and the comparison | Discovery workbook, DS-04-1 and DS-04-2 | Done in week 2, ahead of its week. Leavers are described as removed in the window. An extract compared with the HR list shows 11 leaver accounts still active. | OK | |
| WK-20 | 4 | Verify | Risk | Review every inherited exception and acceptance that is past its review date. Renew, change or close each, by the approver its band sets. | 11 Oct 2026 | In progress | In progress | Later | TR-07 | A decision on each, in the register | 2 inherited exceptions are past their review dates (IE-1 and IE-2). The review is in progress (PI-02). | OK | |||
| WK-22 | 4 | Verify | Suppliers | Interview the critical suppliers and confirm each contact by a call. Check the last assessment of each Tier 1 supplier. | 11 Oct 2026 | Not started | Not started | Later | TR-10 | Contacts confirmed; assessment dates | The critical suppliers are booked for 6 Oct. | OK | |||
| In this extract | 6 of 9 actions shown are done; 2 in progress, 1 not started, 0 overdue | ||||||||||||||
| Each row is tied to a dated fact: the interview records, the access extract and the discovery workbook. WK-19 was done in week 2, ahead of its own week. The other thirty-one actions are not in the example. | |||||||||||||||
Six requirements, as at the same date
| ID | Area | Requirement | Latest date | State | Date status | Date checked | Evidence | Note | Put right by | Check | |||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| TR-03 | Interviews | Book an interview with every stakeholder group in A04 during the Listen phase and hold it by the end of week 4, with the same core questions, and record each interview in the record format: expectation, concern, commitment and follow-up. Interview before judging. | Not met | 9 of 10 groups interviewed. The critical suppliers (IV-08) are booked and not yet interviewed. | Sam Okafor | OK | |||||||||
| TR-05 | Decision rights | Agree the transition arrangement for decision rights in writing with the executive sponsor within [[10]] working days of the start, and review it at day 30, day 60 and day 90. The arrangement gives no right that the packs which set each right do not give. | 28 Sep 2026 | Met | 23 Sep 2026 | The arrangement (A06), agreed in writing with the chief executive | OK | ||||||||
| TR-07 | Inherited exceptions | Review every inherited exception and risk acceptance within [[30]] days of the start. One that is past its review date is renewed, changed or closed by the approver its band sets (P02 EX-05, P05 RM-08). Nothing continues by default. | 13 Oct 2026 | Not met | Within its date | IE-1 and IE-2 are past their review dates. The review is in progress (PI-02). | Sam Okafor | OK | |||||||
| TR-08 | Access | Remove the outgoing leader's access on the day they leave: accounts, administrator rights, tokens, shared secrets, vendor portals and any personal account used for work. Confirm the removal against a fresh extract within [[2]] working days, as P07 AR-07 asks of any removal. | Met | 16 Sep 2026 | A fresh extract that shows the removal | OK | |||||||||
| TR-10 | Contacts | Confirm, by a call or a message and not from a list, the contacts at the regulator, the CSIRT, the insurer, the responders and each critical supplier within [[30]] days of the start. Record the date of each confirmation. | 13 Oct 2026 | Not met | Within its date | Confirming the contacts by a call is not started (PI-05, due 2026-10-13). | Sam Okafor | OK | |||||||
| TR-11 | Management body | Within [[60]] days of the start, tell the management body, through the executive sponsor, what NIS2 Article 20 asks of it: to approve the measures, to oversee their implementation and to follow training, and that it can be held liable. Counsel confirms what liability means. | 12 Nov 2026 | Not met | Within its date | Brief the board through the chief executive. Due 2026-10-30 (IR-02). | Sam Okafor | OK | |||||||
| 9 of 10 groups interviewed. The requirements not yet met are still within their dates. TR-03 and TR-08 have no latest date, and TR-08 runs from the day the outgoing leader leaves. The other ten requirements are not in the example. | |||||||||||||||
Lists
| ActionState | ItemState |
|---|---|
| Not started | Met |
| In progress | Not met |
| Done | Not checked |
| Not applicable | Not applicable |
Definitions
Definitions
| Term | Meaning in this workbook |
|---|---|
| New security leader | The head of security, security manager or CISO who has just taken the role. They hold the role that the earlier packs call the Head of Information Security. |
| Outgoing security leader | The person who held the role before. They may still be at work, may be serving a notice period, or may already have gone. |
| Executive sponsor | The executive the new leader reports to, who agrees the arrangement and the plan, and who speaks for the leader to the management body. |
| Management body | The board, or the equivalent, that NIS2 Article 20 says approves the cybersecurity risk-management measures and oversees their implementation. |
| Handover | The passing of what the outgoing leader knows, holds and has promised to the new leader, in writing. |
| Discovery | The work of finding out what the inherited programme does, what it only says it does and what it does not do, by asking for a record, a test or a system view. |
| Inherited | Held, accepted or promised before the new leader started: an exception, a risk acceptance, a contract, a commitment to a customer or a regulator, or an open incident. |
| Baseline | The starting position, recorded as counts and as levels in words, with a reason wherever a value is unknown. It is never one score. |
| Listen (weeks 1 to 3) | Meet people, read what exists, and promise nothing. Learn who expects what. |
| Verify (weeks 4 to 7) | Check what you were told against a record, a test or a system. End with the first executive briefing. |
| Decide (weeks 8 to 10) | Choose the few priorities the findings support, agree the decision rights, and settle the plan. |
| Propose (weeks 11 to 13) | Take the plan, the reporting rhythm and the asks to the executives and the management body. |
| Week | Seven days, counted from the start date as day 1. Week 1 is days 1 to 7. The 13 weeks cover days 1 to 91. |
| Due | The last day of the action's week: day 7 for week 1, day 14 for week 2, and so on. |
| Overdue | The due date has passed and the action is not Done and not Not applicable. An action due today is not overdue. |
| Due this week | The as-at date falls in the action's own week, and the action is not yet done. |
| Week 1 must-do | One of the eight actions that cannot wait for discovery. They confirm your authority, the open incidents, the outgoing leader's access, what to read, the handover document, the contacts and the dates ahead. |
| Not started | Nothing has been done yet. A blank state counts as Not started. |
| In progress | Work has begun and is not finished. |
| Done | The action is finished and the record that shows it is kept. Say where, and enter the date. |
| Not applicable | The action cannot apply here. Say why in the note. |
| Met | You looked, and the evidence shows the requirement holds. Say where the evidence is. |
| Not met | The requirement does not hold yet. Say what is missing, and name who puts it right. |
| Not checked | Nobody has looked yet. The sheet counts it apart, and it is never counted as met. |
| WK-nn, TR-nn, RK-nn | One of the forty weekly actions, one of the sixteen requirements, and one of the ten risks the requirements answer. |
| Requirement limits | The days and working days a requirement allows, read from the settings at the top of the Requirements sheet. They are house defaults. |
| Hidden columns | The workings behind the counts and the lists. They stay hidden. Do not overwrite them. |
| EXAMPLE | An illustration: Kestrel Components B.V. (EXAMPLE), as at 2026-09-30. Every name and value is made up. |
Framework References
Framework references
These references indicate relevance only and do not reproduce the text of any standard.
| Framework | Reference | Supported by |
|---|---|---|
| ISO/IEC 27001:2022 | Clause 4.1 — Understanding the organization and its context | 90 Days sheet: the first weeks learn the organisation and the programme it inherits, from the people and the records, before anything changes |
| ISO/IEC 27001:2022 | Clause 5.3 — Organizational roles, responsibilities and authorities | Who Does What sheet and Requirements sheet, TR-05: roles, responsibilities and authorities are written down and agreed with the executive sponsor |
| NIST CSF 2.0 | GV.RR-02 — “Roles, responsibilities, and authorities related to cybersecurity risk management are established, communicated, understood, and enforced” | Who Does What sheet and Requirements sheet, TR-05: who holds which role in the transition is set out, agreed in writing and reviewed at day 30, 60 and 90 |
| NIS2 — Directive (EU) 2022/2555 | Article 20(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 paragraph is “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” | Requirements sheet, TR-11, and 90 Days sheet, WK-36: Article 20 asks that the management body approves the measures and oversees their implementation, so the new leader tells it so within the set limit. Counsel confirms what liability means |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(a) — “policies on risk analysis and information system security” | 90 Days sheet, WK-11, WK-28 and WK-34: the new leader reads the risk register and the policy register before changing either |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(b) — the cybersecurity risk-management measures include “incident handling” | 90 Days sheet, WK-03, WK-13 and WK-21, and Requirements sheet, TR-09: open incidents are listed and the incident roles confirmed in the first week. The roles and decisions stay with the incident plan |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(d) — “supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers” | 90 Days sheet, WK-07, WK-15, WK-22 and WK-30, and Requirements sheet, TR-10: the critical suppliers and their contacts are listed, called and checked against the register |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(f) — “policies and procedures to assess the effectiveness of cybersecurity risk-management measures” | 90 Days sheet, WK-27, WK-29 and WK-31: two controls are tested, the baseline is recorded and each finding says what was seen |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(g) — “basic cyber hygiene practices and cybersecurity training” | 90 Days sheet, WK-25: the awareness completion records and the training records of the management body are checked |
| NIS2 — Directive (EU) 2022/2555 | Article 21(2)(i) — “human resources security, access control policies and asset management” | 90 Days sheet, WK-04 and WK-19, and Requirements sheet, TR-08: the outgoing leader's access is removed and confirmed, and leaver accounts are compared with the HR record |
Editions referenced: Directive (EU) 2022/2555 (NIS2); NIST CSF 2.0; ISO/IEC 27001:2022 incl. Amd 1:2024 (by number and title only); UK NCSC board guidance and the ENISA skills framework, as their publishers state them; as published and read on 10 October 2026
Directive (EU) 2022/2555 is addressed to the Member States, and binds essential and important entities through their national law. Article 20 asks the Member States to ensure that the management body approves the cybersecurity risk-management measures, oversees their implementation, can be held liable for infringements of Article 21, and is required to follow training. What liability means for a member of a management body depends on national law, and counsel confirms it. Whether your organisation is an essential or an important entity comes from its scope assessment and from counsel, and this pack does not decide it.
The NCSC's Code and toolkit and the ENISA skills framework are voluntary guidance. They are not law. They say what boards might expect and what roles typically do. They do not say what a new security leader must do, and no law named here says how a handover must be run. Following them is not a statement that your organisation complies with NIS2 or any standard.
This pack does not say which document, record or practice meets a requirement of NIS2. Each reference says what its source asks of the management body or the organisation and which CISO Times document helps with that work. Using a document does not by itself show that a requirement is met.
A reference says what its source asks of the management body or the organisation, and which CISO Times document helps with that work. It does not say that a document from this pack meets a requirement of NIS2.
ISO/IEC 27001 references name the clause or control this document relates to, by number and title only. No text of the standard is reproduced. A reference does not say that meeting a clause or control meets any requirement of NIS2, or that your organisation holds a certificate.
These references show where this document supports an external framework. They indicate relevance only and do not reproduce the text of any standard.