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The CISO Decision Brief

Information Ownership Responsibility Matrix

Distinguishes owner, custodian and user duties for classification, access approval and retention.

Available soon

Format
Excel
Size
63 KB
Length
11 sheets
Version
2.0
Updated

What's inside

What changed

  1. 2.0

    Rewritten to the depth of the other CISO Times packs: the 14 activities RS-01 to RS-14, each with the rule it serves, against 6 roles including the privacy and records roles, checked for one accountable role; role holders and deputies with their counts; the owner and custodian of every asset in the register; an ownership check; and the distributor's owners as the worked example.

  2. 1.0

    Published.

Changes across this pack

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

StepWhat to do
1Read the Responsibilities sheet. Each row is one activity, with the rule of the Information Classification & Handling Policy it serves; each column is a role. R does it, A answers for it (exactly one per row), C is consulted before it is done, I is told after.
2Keep the four core roles: information owner, custodian, user, head of information security. Add the privacy and records roles where you have them; where you do not, give their letters to the role that does the work, and keep exactly one A per row.
3On Role holders, name who holds each role in your organisation, and a deputy who acts while they are away. The counts show how many activities each role answers for, does, advises on and is told of. A deputy is bound by the same rules as the holder.
4On Asset owners, name the owner and the custodian of every asset in the Information Asset Register. The owner is a manager in a named role, never a team (CL-03); the owner and custodian may be the same person where one person runs a system, but the owner stays accountable.
5Clear every Check that does not say OK. The Ownership check then says the matrix is ready. Approve it with the Information Classification & Handling Policy and review it when a role holder changes, and at least once a year (CL-12).
6Delete the EXAMPLE rows on Asset owners and replace the EXAMPLE holders before approval. The Responsibilities rows are the content itself: tailor them, do not delete them.

Legend

Yellow cells are inputs. Everything else is calculated or fixed — do not overwrite formulas.

EXAMPLERows marked EXAMPLE in the first column show how a completed row looks. Delete them before approval.

EXAMPLE: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders. Its 17 assets have 10 owners, from the Chief Operating Officer to the Head of Marketing and Communications, and 3 custodians. The Head of Information Security owns the policy and the matrix (Executive Committee approved the policy on 14 Jul 2026).

Tailoring for a small organisation: one person may hold several roles. The Head of IT may be custodian of most systems and also hold the security role; the managing director may own most assets. Keep each activity's single A, and keep the owner and the person who checks the owner's work apart where you can.

Tailoring for a regulated entity: NIS2 and DORA expect the management body to approve and oversee the measures, and DORA expects roles and responsibilities for information assets documented (Article 8(1)). Escalations above the matrix go to the board or its equivalent.

Tailoring where a service provider runs your IT: the provider is usually the custodian of the systems it runs, under contract. It does the R work of the custodian column; the A for every activity stays inside your organisation.

Delegation: a role holder may delegate the R work to a named person, never the A. Record standing delegations in the Deputy column.

Responsibilities

R does it · A answers for it, exactly one per row · C is consulted before · I is told after. Yellow cells are yours to tailor; a blank cell means the role takes no part.

Activity IDActivityRuleInformation ownerCustodianUserHead of Information SecurityData Protection OfficerRecords managerA (calc)R (calc)Check (calc)What the rule says
RS-01Classify a new or changed information asset and record the levelCL-03ACICCI10OKInformation owners approve the level and review it when the purpose, users, law, a supplier or the risk changes, within [[15]] working days of the change.
RS-02Approve a public releaseCL-05AICCI10OKPublic information must have an owner-approved release decision. A lack of a label never makes information Public.
RS-03Apply labels, access and encryption in the systemCL-06CARC11OKApply the handling rule for the level to every action: storing, accessing, sharing inside and outside the organisation, transferring, printing, remote and mobile working, AI tools, retaining and disposing.
RS-04Grant and review access to Confidential informationCL-17ARC11OKAccess to Confidential information is granted only through an approved role profile or approved non-standard access with an expiry (P13 JML-03, JML-04), is reviewed in every access review (P07 AR-02), and administrator access to systems that hold it follows the privileged access pack (P14 PA-02, PA-06, PA-07).
RS-05Approve sharing Confidential information with a recipient outside the organisationCL-08ARCC11OKConfidential information is shared only with an approved recipient for a recorded purpose, using an approved channel, with the recipient's address checked before sending.
RS-06Check a supplier before it holds Internal or Confidential informationCL-16ACRC11OKA supplier stores, processes or receives Internal or Confidential information only under contract terms that protect it (P06 clause CL-01, P06 clause CL-07, P06 clause CL-13, and P06 clause CL-06 where it processes personal data). Confidential information goes to a supplier only after its assessment under the third-party pack has ended in a documented decision to approve it (P06 TP-05).
RS-07Advise on personal and special category dataCL-07CCAC10OKPersonal data is protected under data protection law (GDPR) regardless of the classification label, and carries the Personal data marker. The label does not decide whether processing is lawful.
RS-08Keep the retention scheduleCL-11CCCA10OKDispose of information and media using the level's disposal rule and the method for the media type. Keep a certificate for every Confidential item a provider sanitises or destroys, due within [[10]] working days of collection, and a disposal record for every item destroyed in house.
RS-09Apply and release a legal holdCL-15IRCA11OKInformation under a legal hold is not changed, deleted or disposed of, whatever its retention period, until Legal releases the hold in writing. Disposal checks for a hold first.
RS-10Sanitise or destroy media, and reconcile the certificateCL-11IACR11OKDispose of information and media using the level's disposal rule and the method for the media type. Keep a certificate for every Confidential item a provider sanitises or destroys, due within [[10]] working days of collection, and a disposal record for every item destroyed in house.
RS-11Report suspected mishandlingCL-18IRRA12OKSuspected mishandling, loss, or Confidential information found unlabelled or in the wrong place is reported at once through the incident reporting route (P09 IM-01). A suspected personal data breach follows the incident pack's GDPR reporting duties (RD-06 to RD-09).
RS-12Review the registerCL-12RRACC12OKInformation owners and custodians review the register at least every [[12]] months and after a material change.
RS-13Brief staff on the levels and the handling rulesCL-06CIAC10OKApply the handling rule for the level to every action: storing, accessing, sharing inside and outside the organisation, transferring, printing, remote and mobile working, AI tools, retaining and disposing.
RS-14Report the headline measuresCL-20ICAC10OKAny departure from these rules is a P02 exception, scored and approved by the approver its band sets (EX-05); a Critical exception is approved by the board or its equivalent. The headline measures go monthly to the security and IT leadership team.

Role holders

Each role in the matrix, what it does, who holds it and who deputises. The counts are the matrix's letters for the role. A deputy is bound by the same rules.

Role, as the matrix names itCore roleWhat the role doesHeld byDeputyR (calc)A (calc)C (calc)I (calc)Check (calc)
Information ownerYesApproves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).Each asset's owner, named on the Asset owners sheet (10 managers)[[Deputy]]1544OK
CustodianYesApplies the technical handling the level requires: access, encryption, backup, logging, labelling in the system, and disposal.Head of IT, IT Operations Manager, Transport office administrator, by asset (Asset owners sheet); suppliers that host a system under contract[[Deputy]]4231OK
UserYesFollows the label and the handling rule, checks recipients before sending, and reports suspected mishandling at once.All staff, contractors and supplier staff[[Deputy]]3002OK
Head of Information SecurityYesOwns this policy and the handling matrix, advises on impact, runs the handling checks and reports the measures.Head of Information Security[[Deputy]]1480OK
Data Protection OfficerNoAdvises on personal and special category data, retention of personal data and any personal data breach.Data Protection Officer[[Deputy]]0180OK
Records managerNoKeeps the retention schedule and the disposal records, and applies and releases legal holds on Legal's instruction.[[e.g. Company Secretary or Head of Legal]][[Deputy]]1232OK

The example holder each role suggests: Information owner, e.g. system owner or the head of the function the information serves; Custodian, e.g. Head of IT, system administrator or the supplier that hosts it; User, everyone: staff, contractors and supplier staff; Head of Information Security, e.g. Head of Information Security; Data Protection Officer, or the privacy lead where no DPO is appointed; Records manager, e.g. Company Secretary or Head of Legal.

Asset owners

The owner and custodian of every asset in the Information Asset Register. The owner answers for the asset's level, access, retention and release (CL-03); the custodian applies the handling the level requires.

ExampleAsset IDInformation assetLevelOwnerCustodianOwner's assets (calc)Check (calc)
EXAMPLEIA-01Customer accounts and order historyConfidentialChief Operating OfficerHead of IT3OK
EXAMPLEIA-02Customer price lists and discount termsConfidentialSales DirectorHead of IT2OK
EXAMPLEIA-03Online orders and customer sign-in accountsConfidentialChief Operating OfficerHead of IT3OK
EXAMPLEIA-04Payroll and staff bank detailsConfidentialChief Financial OfficerHead of IT2OK
EXAMPLEIA-05Staff HR records, including sickness absenceConfidentialHR DirectorHead of IT1OK
EXAMPLEIA-06Supplier master data and bank detailsConfidentialChief Financial OfficerHead of IT2OK
EXAMPLEIA-07Board and executive committee papersConfidentialChief ExecutiveHead of IT1OK
EXAMPLEIA-08Warehouse stock levels and dispatch plansInternalHead of LogisticsIT Operations Manager3OK
EXAMPLEIA-09Warehouse shift rotasInternalHead of LogisticsIT Operations Manager3OK
EXAMPLEIA-10Policies, standards and proceduresInternalHead of Information SecurityIT Operations Manager1OK
EXAMPLEIA-11Sales forecasts and marketing plansInternalSales DirectorIT Operations Manager2OK
EXAMPLEIA-12IT network diagrams and system documentationInternalHead of ITIT Operations Manager1OK
EXAMPLEIA-13Supplier product data: specifications, barcodes and pack sizesInternalProcurement ManagerHead of IT1OK
EXAMPLEIA-14Customer service scripts and answers to common questionsInternalChief Operating OfficerIT Operations Manager3OK
EXAMPLEIA-15Published product catalogue and website pagesPublicHead of Marketing and CommunicationsHead of IT2OK
EXAMPLEIA-16Press releases and the published annual reportPublicHead of Marketing and CommunicationsHead of IT2OK
EXAMPLEIA-17Freight rates and quotes on the rate comparison siteInternalHead of LogisticsTransport office administrator3OK

Ownership check

Ownership check

The matrix, the role holders and the asset owners against the rules. Every line should say 'Meets the check' before the matrix is approved.

Checks

CheckResultStatusWhat it means
Activities in the matrix14Meets the checkThe 14 activities of the pack, and any you add.
Activities with exactly one accountable role14Meets the checkOne A per row; an activity with two owners has none.
Core roles with a named holder4Meets the checkThe 4 core roles every asset needs: information owner, custodian, user, head of information security.
Roles with a check to resolve0Meets the checkEvery role named, in the matrix, and a core role doing or answering for something.
Assets with a named owner and custodian17Meets the checkInformation owners approve the level and review it when the purpose, users, law, a supplier or the risk changes, within [[15]] working days of the change.
Overall0Every activity and asset has an ownerThe number of checks above that do not yet say 'Meets the check'.

Assets by owner

OwnerAssetsConfidentialWhat they answer for
Chief Operating Officer32Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Sales Director21Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Chief Financial Officer22Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
HR Director11Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Chief Executive11Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Head of Logistics30Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Head of Information Security10Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Head of IT10Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Procurement Manager10Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
Head of Marketing and Communications20Approves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).

EXAMPLE owners, from the register. Replace them with your own; the counts follow the Asset owners sheet.

Lists

RACILevel
RPublic
AInternal
CConfidential

I

Definitions

Definitions

TermMeaning in this workbook
R: responsibleDoes the work. Several roles may share it.
A: accountableAnswers for the outcome and signs it off. Exactly one per activity; the A may also do the work.
C: consultedAsked for advice before the activity is done or decided.
I: informedTold after the activity is done or decided.
Information ownerApproves the level, the purpose, who may access it, the retention period and any release; reviews the classification; approves non-standard access to it (P13 JML-04).
CustodianApplies the technical handling the level requires: access, encryption, backup, logging, labelling in the system, and disposal.
UserFollows the label and the handling rule, checks recipients before sending, and reports suspected mishandling at once.
Head of Information SecurityOwns this policy and the handling matrix, advises on impact, runs the handling checks and reports the measures.
Data Protection OfficerAdvises on personal and special category data, retention of personal data and any personal data breach.
Records managerKeeps the retention schedule and the disposal records, and applies and releases legal holds on Legal's instruction.
Information ownerThe manager accountable for an information asset: decides its level, who may access it, how long it is kept and when it is released or destroyed.
CustodianThe person or team that holds and runs the information for the owner, usually IT or a supplier: applies the access, storage, backup and disposal controls the level requires.
UserAnyone who reads, creates or handles the information, staff or supplier: follows the label and the handling rule, and reports mistakes.
Core roleOne of the 4 roles every asset needs: information owner, custodian, user, head of information security.
DeputyThe person who acts for a role holder while they are away, bound by the same rules. A deputy may do the R work, never hold the A in their own name.
RS-nn, CL-nnThe activities of this matrix, and the rules of the Information Classification & Handling Policy they serve.
(calc)A cell or column the workbook calculates. Do not type or paste over it.
EXAMPLEA worked example: a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders, as at 2026-09-30. Replace the holders and delete the EXAMPLE rows before approval.

Framework References

Framework references

These references indicate relevance only and do not reproduce the text of any standard.

FrameworkReferenceSupported by
ISO/IEC 27001:2022Annex A 5.9 — Inventory of information and other associated assetsAsset owners: an owner for every information asset in the inventory
NIST CSF 2.0GV.RR-02 — “Roles, responsibilities, and authorities related to cybersecurity risk management are established, communicated, understood, and enforced”Responsibilities and Role holders: roles, responsibilities and authorities for information established, communicated and checked
NIS2 — Directive (EU) 2022/2555Article 21(2)(i) — “human resources security, access control policies and asset management”The whole matrix: who manages information assets and their handling
DORA — Regulation (EU) 2022/2554Article 8(1) — identify, classify and document ICT-supported business functions, information assets and ICT assets, reviewed at least yearlyResponsibilities and Asset owners: roles and responsibilities for information assets identified and documented
GDPR — Regulation (EU) 2016/679Article 32(4) — “The controller and processor shall take steps to ensure that any natural person acting under the authority of the controller or the processor who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.”Responsibilities, RS-05, RS-07 and RS-13: people with access to personal data act on instructions and are briefed
ISO/IEC 27001:2022Annex A 5.2 — Information security roles and responsibilitiesResponsibilities and Role holders: information security roles and responsibilities defined and allocated

Editions referenced: ISO/IEC 27001:2022 incl. Amd 1:2024; NIST CSF 2.0; Directive (EU) 2022/2555 (NIS2) and Implementing Regulation (EU) 2024/2690; Regulation (EU) 2016/679 (GDPR); Regulation (EU) 2022/2554 (DORA) and Delegated Regulation (EU) 2024/1774

ISO/IEC 27001 references name the clause or control this document relates to. They do not say that meeting it meets any other framework's requirement.

Prepared by Zero One Cybersecurity · Published by CISO Times

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