ISO 27001:2022 Annex A 5.29 Information security during disruption for AI Companies

ISO 27001 Annex A 5.29 is a security control that ensures organizations maintain information security continuity during disruptive events. The primary implementation requirement involves integrating security into business continuity plans, providing the business benefit of protecting critical AI datasets and models when operational stability is most vulnerable.

Every business faces the risk of disruption, but for a company driven by artificial intelligence, the stakes are uniquely high. A crisis won’t wait for you to get ready. Your core assets are not just servers and software; they are vast datasets, complex models, and intricate algorithmic processes. These assets are both incredibly valuable and acutely vulnerable. When things go wrong, you need a plan that understands this unique landscape. This is where ISO 27001 Annex A 5.29 Information security during disruption provides a critical framework, guiding you to protect your most important assets when you are at your most vulnerable.

ISO 27001 Annex A 5.29 is a control designed to ensure you have a clear and effective plan to maintain information security at an appropriate level during a disruptive event. Its core purpose is to integrate information security directly into your broader business continuity and disaster recovery planning, ensuring that security is a fundamental component of your response, not an afterthought.

The “No-BS” Translation: Decoding the Requirement

Let’s strip away the consultant-speak. Annex A 5.29 is about not dropping the ball when the building is on fire. It asks: “When you switch to backup systems, are they as secure as the primary ones?”

The Auditor’s View (ISO 27001)	The AI Company View (Reality)
“The organisation shall define, document, implement and maintain requirements for information security during disruption.”	Don’t let the BCP kill security. If your primary data centre goes down and you failover to a “cold site,” does that cold site have the same firewall rules? Or is it wide open to the internet? If you restore from backup, is the backup encrypted?
“Controls shall be established to maintain information security at the required level during disruption.”	No shortcuts in a crisis. Just because you are under DDoS attack doesn’t mean you can turn off MFA “to help people log in faster.” Security must persist.

The Business Case: Why This Actually Matters for AI Companies

Why should a founder care about “Security during Disruption”? Because attackers love chaos. They launch a DDoS attack to distract you while they exfiltrate your database.

The Sales Angle

Enterprise clients will ask: “Does your Disaster Recovery (DR) plan include security validation?” If your answer is “We just restore the backup,” that’s insufficient. If your answer is “We verify the integrity of the restored data and re-apply all access controls before bringing the system online,” you win. A 5.29 proves you don’t panic.

The Risk Angle

The “Insecure Restore” Breach: You get ransomware. You restore from a backup. But the backup contained the same vulnerability (e.g., unpatched Log4j) that let them in. You get hacked again immediately. A 5.29 forces you to secure the recovery environment before you open the doors.

DORA, NIS2 and AI Regulation: Resilience is Law

Regulators are focused on “Operational Resilience.”

• DORA (Article 11): Financial entities must have “backup policies and recovery procedures.” You must test that your backup systems are secure and physically separated from primary systems (immutable backups).
• NIS2 Directive: Mandates “business continuity and crisis management.” You must ensure security during a crisis. If you lower your shields to stay online, you are non-compliant.
• EU AI Act: High-risk systems must have “robustness.” This means the system must withstand errors or inconsistencies. If a disruption causes your AI to output harmful data, you must have a plan to contain it.

ISO 27001 Toolkit vs SaaS Platforms: The Continuity Trap

SaaS platforms help you write a BCP, but they don’t help you secure it. Here is why the ISO 27001 Toolkit is superior.

Feature	ISO 27001 Toolkit (Hightable.io)	Online SaaS Platform
The Plan	Offline Access. A Word/PDF BCP that you can print. If your SaaS tool is down, you still have the plan.	Cloud-Dependent. If AWS goes down and your BCP is hosted on an AWS-based SaaS, you can’t access your recovery steps. Critical failure.
Ownership	Your Strategy. You define the RTO (Recovery Time Objective) and RPO (Recovery Point Objective).	Generic Templates. Platforms offer generic “office fire” plans that don’t cover AI specific risks like Model Drift or Inference API outages.
Simplicity	Checklists. Simple lists: “1. Secure Backup. 2. Scan for Malware. 3. Restore.”	Complex Modules. BCP modules in GRC tools are often over-engineered and confusing during a real crisis.
Cost	One-off fee. Pay once. Be resilient forever.	Subscription. You pay monthly for a BCP tool you hopefully never use.

The Unique Risks AI Companies Face with Disruption

Understanding your specific risk profile is the first step toward effective compliance. A generic business continuity plan is not enough when your operations are far from generic.

Exposure of Sensitive Training Datasets

During a crisis, you may switch to backup systems. This creates a significant risk that your proprietary training data could be exposed. Is your “cold storage” encrypted with the same keys as your production bucket? If not, a failover exposes your IP.

Disruption of Algorithmic Processes

When you activate fallback systems, they may not have the same processing capabilities as your primary environment. This creates a risk that your model outputs could be altered or degraded. Customers relying on your API for real-time decisions (e.g., fraud detection) will receive failures.

Vulnerabilities in the AI Supply Chain

A disruption at one of your key suppliers (e.g., OpenAI API goes down) impacts you. Your continuity plan must account for maintaining security when a critical external dependency fails. Do you have a secure fallback to a local model (e.g., Llama) or a different provider?

Your Blueprint for Compliance: Actionable Steps for AI Businesses

Resilience isn’t defined by how you operate in the quiet; it’s proven when you must stand up secure as everything changes.

Develop AI-Centric Continuity Plans

Update your Business Continuity Plan (BCP) to specifically address AI risks. Document procedures for securing training data during a failover and validating algorithmic integrity on backup systems.

Define and Document Your Fallback Controls

When a primary control fails, you need a secure, pre-planned alternative.

Scenario	Primary Control	Secure Fallback Control
Access to Critical Systems	SSO with MFA	Break-Glass Accounts (stored in physical safe)
Remote Developer Access	Corporate VPN	Restricted IP Whitelisting on Cloud Provider
Data Processing	Automated Pipeline	Manual processing on air-gapped laptop (secure)

The Evidence Locker: What the Auditor Needs to See

When the audit comes, prepare these artifacts:

• BCP Test Report (PDF): “On [Date], we simulated an AWS region failure. We verified that the backup region had encryption enabled.”
• Backup Config (Screenshot): Evidence that backups are encrypted (e.g., AWS Backup settings).
• Alternative Site Review: Evidence that you checked the security of your “Work From Home” policy if the office is unavailable.

Common Pitfalls & Auditor Traps

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

• The “Open Backup” Error: Your production DB is secure, but your backup snapshots are in a public S3 bucket for “easy access” during recovery. Instant fail.
• The “Untested” Plan: You have a BCP document, but nobody has ever tried to restore the database from it. When asked, the engineer admits: “I don’t know if the decryption key works.”
• The “Hero” Dependency: Your recovery plan relies on one specific engineer knowing the command line arguments. If they are sick, you can’t recover securely.

Handling Exceptions: The “Break Glass” Protocol

Sometimes you need to bypass security to restore operations (e.g., disable WAF to debug).

The Emergency Bypass Workflow:

• Trigger: Security control prevents recovery (e.g., IP whitelist blocks backup restoration).
• Authority: CISO approval required to disable control.
• Mitigation: Implement alternative monitoring (e.g., watch logs in real-time) while control is down.
• Restoration: Re-enable control immediately after recovery.

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

How to operationalise A 5.29 using your existing stack (AWS, Linear).

• Step 1: Planning (Manual). Create the BCP using the High Table Toolkit. Define “Security during Disruption.”
• Step 2: Configuration (Automated). Use Infrastructure as Code (Terraform) to ensure your DR environment has the exact same security groups as Production.
• Step 3: Testing (Manual). Conduct a quarterly “Game Day.” Failover the database. Verify encryption.
• Step 4: Reporting (Manual). Log the test results in Linear: “Passed – Recovery Secure.”

For an AI company, complying with ISO 27001 Annex A 5.29 is a strategic necessity. The High Table ISO 27001 Toolkit provides the clear and efficient path to achieving this, ensuring your resilience plan is not just a document, but a capability.

ISO 27001 Annex A 5.29 for AI Companies FAQ

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