Information Security


Information security within the company:

When an external ISO is the right choice

Luca Roth · Updated on: 03.07.2025
Bild eines externen informationssicherheitsbeauftragten

Who is responsible for information security in a company?

Who actually cares whether your company will still be cyber-resilient tomorrow - and meet the increasing demands of customers, insurers or authorities?

In many small and medium-sized enterprises (SMEs), the answer is: no one - or someone who simply doesn't have the time or the expertise.

This is exactly where the information security officer (ISO) comes into play.

Is an ISO required by law?

In principle, there is no general legal obligation to appoint an ISO. However, there are numerous legal, contractual and regulatory requirements that make the role indirectly or directly necessary.

Here are a few examples:

Standard / Law                                           Relevance for ISO obligation    
ISO 27001 

No explicit obligation, but section 5.3 requires a person responsible for the ISMS. Annex A.5.2

requires separation of functions - usually only realizable via an ISO role.

TISAX / VDA ISA  Not an explicit obligation, but requires defined and assigned responsibilities as well as the separation of functions in the case of high protection requirements (Control 1.2.2), which can usually only be fulfilled by an ISO.
NIS-2Does not name the ISO directly, but it is often necessary for the implementation and monitoring of the required risk management measures.
BSI law (Kritische Infrastrukturen (KRITIS) sind Organisationen und Einrichtungen mit wichtiger Bedeutung für das staatliche Gemeinwesen, bei deren Ausfall oder Beeinträchtigung nachhaltig wirkende Versorgungsengpässe, erhebliche Störungen der öffentlichen Sicherheit oder andere dramatische Folgen eintreten würden.KRITIS) Explicit ISO allocation for operators of critical infrastructures.
EASA Part-IS Explicit requirement for a role to ensure ISMS compliance - analogous to an ISO

 

In short: In many industries and constellations, an ISO is de facto necessary. But even for companies without a legal, contractual or regulatory obligation, in our experience it is essential to clearly assign responsibility for information security in order to ensure smooth business operations. So why not appoint an ISO right away?

Tasks of an information security officer (ISO)

An ISO implements the information security strategy in operations, based on the objectives of the management. However, overall responsibility always remains with the company management.

Typical tasks of an ISO:

  • Development and maintenance of the information security management system (ISMS)
  • Identification and assessment of risks and vulnerabilities
  • Creation and maintenance of guidelines and processes
  • Contact person for management and employees
  • Organization and support of audits
  • Regular reporting to the company management

These tasks are key to ensuring compliance, cyber resilience and trust towards customers and partners.

Different rolse – same responsibility?

Terms such as ISO, CISO or IT security officer are often used synonymously - but should be differentiated:

RoleDescription
Information Security OfficerISOResponsible for operational implementation of the information security strategy
Chief Information Security OfficerCISOStrategically responsible manager at C-level
IT security officerIT security officerFocuses on IT-related security measures - i.e. a subset of information security


The choice of role usually depends on the size of the company. In SMEs, an ISO (internal or external) usually takes on all tasks, while larger companies rely on entire teams led by a CISO.

What skills does an ISO need?

In addition to comprehensive specialist knowledge, the ISO should have methodological competence and communication skills. It is particularly important to:

  • show a confident handling of common standards, norms and laws (ISO 27001, NIS-2, GDPR, ...)
  • have basic IT expertise (network technology, software development, ...)
  • have experience in project management
  • be able to communicate clearly and comprehensibly at eye level with both individual departments and management
  • be assertive

Ideally, the ISO also has a good knowledge of the whole company and its processes and also has basic technical knowledge to better classify and handle information security risks.

Internal or external? When an external ISO is the right choice

In our experience, it generally makes sense to fill the ISO job internally if employees with the required skills and the necessary budget are available.

However, many SMEs try to cover the tasks of an ISO with IT managers or other specialists on the side. This often leads to conflicts of interest (e.g. checking their own processes) or a lack of independence or resource bottlenecks (time, personnel, prioritization, specialist knowledge).

An external information security officer offers an effective alternative here. 

Benefits of an external ISO

  • Instant availability without lengthy recruiting
  • Objectivity and neutral view from the outside
  • High level of professional qualification and experience
  • Predictable, scalable cost structure
  • Clear methodical approach
  • Smooth cooperation with internal IT and management

How does collaboration with an external ISO work?

  • Fixed contact person
  • Regular coordination - on-site or remote
  • Transparent reports, adapted to maturity level and industry
  • Focus on effective implementation, not formalism
  • An external ISO is not a substitute for internal responsibility - but a professional reinforcement that relieves and secures companies in a targeted manner.

The most important facts

Is an ISO mandatory?
Not across the board - but in many cases de facto necessary due to regulations.

Can the IT manager also be an ISO?
Not recommended. There is a risk of conflicts of interest.

Does the ISO have to work full-time?
Not necessarily. Part-time solutions or external support often make sense.

What does an external ISO cost?
This depends on the size of the company, the degree of maturity and the scope of services - contact us and we will prepare a suitable offer.

Why should you appoint an external ISO from HvS-Consulting?  

Because information security is our trade.
Our consultants have many years of experience in the areas of information security and cyber security - from practice, for practice. We know what is important when information security in a company is not just to be documented, but to be practiced.

We know the height of the bar.
Our consultants are certified lead auditors for ISO 27001, TISAX and other standards. This means that we don't just think in terms of requirements - we also know how auditors audit and what really gets you ahead. Compliance that works.

Fast access to specialized know-how.
As part of HvS-Consulting, our ISOs have agile and uncomplicated access to a broad network of experts when required - from specialists in OT security to lawyers in information security law. Without detours, without external escalation.

The result:

An external ISO that not only knows processes - but also makes them work. Tried and tested, efficient and compatible with your corporate culture.

Conclusion

Information security is no longer a side issue - not even for SMEs.

Whether it's internal or external: The role of the ISO is crucial for compliance, resilience and trust. And it should be clearly defined, professionally staffed and effectively implemented.

 

Want to know what an external ISO for your company could look like? 


Find out now

About the author

Luca Roth

Information Security Consultant

He supports companies in setting up and further developing ISMS - in a practical, rule-compliant and risk-based manner.

His main focus: Security processes, guidelines, risk management, ISMS audits, gap analyses and vulnerability management.

With over two years of experience in information and IT security, he ensures clear structures and sustainable security levels.

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Luca Roth Cyber Security Consultant HvS Consulting GmbH