ISO 27001:2022 Annex A 5.11 Return of assets for AI Companies AI Companies

ISO 27001 Annex A 5.11 Return of Assets is a security control that mandates employees and contractors to return all of the organization’s assets in their possession upon termination or change of employment. This critical process enables AI companies to revoke access credentials and protect high-value intellectual property like model weights and training data from unauthorized retention.

When a trusted employee or contractor leaves, it raises a security question that keeps many CSOs and CEOs awake at night. If you run an Artificial Intelligence company, the stakes are even higher. The real danger isn’t just about turning off their email access. It is about the high-value intellectual property that might walk out the door with them.

Think about the source code for your new algorithm, the training data on a USB drive, or a laptop holding a uniquely trained model. These aren’t just files; they are the core of your business. If you fail to get them back, it is not just a mistake. It is a threat to your company’s survival. For more insights on managing these risks, you can check out resources at hightable.io.

This is exactly what ISO 27001 Annex A 5.11 Return of Assets is designed to handle. It is a structured defence to stop your critical data from leaking. This guide will help you set this up effectively. It will help you pass your audit, but more importantly, it will help you protect the assets that give you a competitive edge.

The “No-BS” Translation: Decoding the Requirement

Let’s strip away the consultant-speak. Annex A 5.11 isn’t just about getting a key card back. It is about ensuring your former Lead Engineer can’t delete your production database from their sofa.

The Auditor’s View (ISO 27001)	The AI Company View (Reality)
“All personnel and other interested parties as appropriate shall return all of the organisation’s assets in their possession upon change or termination of their employment.”	The Hardware: Get the MacBook Pro (M3 Max) back immediately so you can wipe it. The Cloud: Revoke the AWS IAM User, kill the GitHub Personal Access Token (PAT), and boot them from the Slack workspace before their exit interview ends.

The Business Case: Why This Actually Matters for AI Companies

Why should a founder care about “Asset Return”? Because in the AI world, your valuation is tied to assets that are incredibly easy to steal.

The Sales Angle

Enterprise clients are terrified of IP theft. In security questionnaires, they will ask: “How do you ensure terminated employees cannot access our data?” If you cannot prove a strict offboarding process that includes asset reclamation (both physical and digital), you look like a leaky bucket. No bank will put their data in your model if your ex-employees still have the keys.

The Risk Angle

The “Departing Founder” Scenario: We often see this in startups. A co-founder leaves on bad terms. If you don’t have a formal “Return of Assets” process, they might argue that the local copy of the model weights on their personal drive belongs to them. Annex A 5.11, backed by a signed employment contract, is your legal hammer to get that IP back.

DORA, NIS2 and AI Regulation: The Exit Strategy

Regulators treat offboarding as a critical control point. If you fail here, you aren’t just losing a laptop; you are breaching the law.

• DORA (Article 9): Mandates that financial entities and their providers (you) strictly manage access rights. Failing to revoke access (return the digital asset) upon termination is a direct violation of ICT security requirements.
• NIS2 Directive: Focuses on supply chain security. If a contractor leaves your company but keeps their access to your code repository, you have introduced a supply chain vulnerability.
• EU AI Act: Implies strict governance over high-risk AI systems. If unauthorized personnel (including ex-employees) retain access to model training parameters, you cannot guarantee the system’s integrity or safety.

ISO 27001 Toolkit vs SaaS Platforms: The Asset Trap

SaaS platforms love to integrate with your MDM (Mobile Device Management) and call it a day. But asset return is a physical and legal process, not just an API call. Here is why the ISO 27001 Toolkit is the superior choice.

Feature	ISO 27001 Toolkit (Hightable.io)	Online SaaS Platform
Flexibility	Handles Physical & Digital. A spreadsheet can track a MacBook, a physical YubiKey, and a “Hugging Face Token” equally well.	rigid Integrations. They track what they can scan (laptops). They often fail to track physical keys, access cards, or hard-copy notebooks containing IP.
Cost	One-off fee. Pay once. Manage your assets forever.	Per-Asset Pricing. Some platforms charge you based on the number of assets or users. As you scale, you get punished.
Ownership	Your Data. Your Asset Register is an Excel file on your secure drive. It belongs to you.	Vendor Lock-in. If you cancel the subscription, you lose your history of who returned what. Good luck with the legal dispute.
Simplicity	Zero Training. Everyone knows how to update a list.	Complex Workflows. Training HR to use a complex GRC tool just to mark a laptop as “returned” is a waste of time.

What is Annex A 5.11 and Why Does It Matter?

Before you start building processes, you need to understand what this control really means. For an AI company, this is not just an HR form to file away. It is a key part of protecting your intellectual property.

Defining the Control

The ISO 27001 standard is very direct. It states that all employees and other interested parties must return all organisational assets when their employment or contract ends or changes. Note the word “changes.” If an employee moves from a finance role to a marketing role, they probably don’t need that high-security laptop anymore. You must collect it to ensure their assets match their current job.

The ‘So What?’ for Your Company

For you, this control is more than a checklist. Its goal is to stop the theft of IP and data. If you lose control of these assets, you face legal and commercial risks.

• Protecting IP and Trade Secrets: Your assets are containers for value. A single USB drive could hold the proprietary code or algorithms that run your business.
• Data Protection Compliance: If you don’t retrieve a device with personal data, you could be breaking laws like the GDPR. This leads to fines and bad press.
• The Security Triad: An unreturned asset hurts your security posture. It risks confidentiality (competitors seeing your models), integrity (someone altering your training data), and availability (losing the only copy of a dataset).

Identifying Your Assets: What Do You Need to Reclaim?

You cannot ask for things back if you don’t know they are missing. For AI companies, this goes way beyond just laptops and phones. You need a full inventory to make your offboarding work.

Physical Hardware

These are the things you can touch. Don’t forget the small stuff:

• Endpoint devices: Laptops (MacBooks), desktops, phones, and tablets.
• Storage: USB drives, external hard drives, YubiKeys (MFA tokens).
• Special gear: Development kits, VR headsets, or local GPU clusters.

Information and Data (The AI Risk)

This is where AI companies differ from a bakery. The asset isn’t just the machine; it’s what is on the machine:

• Local Weights: Copies of model weights (.pt, .safetensors) stored on local drives.
• Training Data: CSVs or JSON files of cleaned customer data.
• Notebooks: Jupyter notebooks with experimental code and API keys hardcoded (we know you do it).

Access Credentials

You must also take back the digital keys:

• Cloud Access: AWS/GCP/Azure root or IAM user access.
• SaaS Seats: GitHub, Linear, Slack, Notion, OpenAI API keys.
• VPN/SSH Keys: Certificates used to access production servers.

Building Your Asset Return System

You can’t comply with Annex A 5.11 using just a sticky note. An ISO auditor will expect to see a real system in place. You need these six pillars to make it work.

1. Asset Management Policy: This is your high-level rulebook. It tells your team how assets are valued and tracked from day one.
2. Asset Management Process: This is the “how-to” guide. It details the steps for handing out and taking back equipment.
3. An Asset Register: This is vital. It is your single source of truth. If your register is wrong, you cannot secure your gear.
4. Acceptable Use Rules: This document sets the boundaries. It tells staff what they can and cannot do with company tech.
5. Legal Contracts: Your employment contracts must say that staff have to return assets when they leave. Without this, your policy has no teeth.
6. The HR Process: When HR flags a leaver, it must trigger your security checklist immediately.

The Offboarding Playbook

Once your system is built, you need to execute it when someone leaves. Here is how to handle the physical return.

• Secure Return and Transport: If your team is remote, don’t just ask them to mail it. Use a trackable courier service. You need to know where that asset is at all times.
• Secure Remote Wipe: This is a best practice. If you can, wipe the device remotely (using MDM like Kandji or Jamf) before it gets shipped. If the package gets lost in the mail, you only lose a piece of metal, not your company secrets.
• Secure Storage: When the device arrives, lock it up. Do not leave it on a desk. Put it in a secure cabinet until it can be wiped and re-imaged for the next person.

Tackling Tricky Scenarios

A mature company knows how to handle the hard stuff. For AI firms, this usually means personal devices and the notice period.

BYOD (Bring Your Own Device)

You cannot take an employee’s personal phone, but you are responsible for the company data on it. You have two options:

• Technical Control: Use Mobile Device Management (MDM) software. This creates a “corporate container” on the phone. When they leave, you wipe just that container.
• Procedural Control: Have them sign a document confirming they have deleted all company data. For high-risk roles, this might not be enough.

The High-Risk Notice Period

The time between an employee quitting and their last day is risky. They still have access, but they are leaving. You should review their access rights immediately. Monitor their downloads. For sensitive roles like ML engineers, consider taking their main device early and giving them a “clean” loaner laptop for their final tasks.

The Evidence Locker: What the Auditor Needs to See

When the audit comes, I don’t want to hear about your process; I want to see the paper trail. Prepare these artifacts:

• Offboarding Checklist (Ticket Export): A Jira/Linear ticket for a recent leaver showing the “Return Assets” box was ticked by IT.
• Courier Receipts (PDF): Proof that you paid for the secure shipping of the laptop.
• Asset Register (Excel): Updated to show the asset is now “In Stock” or “Reassigned,” not still assigned to the person who left 3 months ago.
• Wipe Logs (Screenshots): A screenshot from your MDM showing the device was wiped on [Date].

Common Pitfalls & Auditor Traps

Here are the top 3 ways AI companies fail this control:

• The “Ghost” User: You collected the laptop, but you forgot to disable their Google Workspace account. They can still access Google Drive from their personal phone. Major non-conformity.
• The “Shadow” Code: The developer pushed code to their personal GitHub account “for safekeeping.” You didn’t check, and you didn’t ask them to delete it.
• The “Friendly” Exit: A co-founder leaves, and you let them keep their laptop “as a gift.” Did you wipe it first? Did you remove the company data? If not, you just gifted them your IP.

Handling Exceptions: The “Break Glass” Protocol

Sometimes, an employee disappears (ghosts you) or refuses to return the equipment. What do you do?

The Hostile Exit Workflow:

• Trigger: Employee is unresponsive for 5 days after termination.
• Technical Action: Initiate “Remote Lock” and “Remote Wipe” immediately via MDM.
• Legal Action: Send a formal legal letter demanding return of property (Consult Legal Counsel).
• Audit Log: Document these steps in an incident ticket. Even if you never get the laptop back, the evidence that you tried protects you during the audit.

The Process Layer: “The Standard Operating Procedure (SOP)”

How to operationalise A 5.11 using your existing stack (Linear, Google Workspace).

• Step 1: The Trigger (Manual). HR or Founder marks user as “Terminated” in the HR system (or sends a Slack DM to Ops).
• Step 2: The Ticket (Automated/Manual). Create a “Leaver” ticket in Linear. It must have a sub-task: “Collect Asset [Tag #123].”
• Step 3: The Logistics (Manual). Ops team sends a prepaid shipping box to the employee’s home address.
• Step 4: The Revocation (Automated). IT runs a script (or clicks a button) to suspend Google Workspace, Slack, and AWS access at the exact termination time.
• Step 5: The Verification (Manual). When the box arrives, Ops opens it, verifies the serial number against the Asset Register (Excel), and marks it “Returned.”

For an AI company, Annex A 5.11 is not just a compliance task. It is a strategic move. It is the system you use to protect your innovations and your value. The true test is not just how you handle a standard exit, but how you manage the risks when a key player walks out the door. Do it right, and your value stays with you.

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