In the startup world, the mantra is often “move fast and break things.” But when you are trying to close an enterprise deal or get your ISO 27001 certification, the new mantra has to be “move fast and secure things.” This is where ISO 27001 Annex A 5.4 Management Responsibilities comes into play.
For a tech startup, this control can feel like a culture clash. It requires management to ensure that everyone applies security policies. It sounds like corporate bureaucracy, but if implemented correctly, it’s actually the secret sauce that lets you scale without crashing. Here is how to nail Annex A 5.4 without slowing down your sprint velocity.
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What Annex A 5.4 Means for a Startup
The standard says management must require all personnel to apply information security in accordance with policies. In a corporate giant, this means posters in the hallway and annual seminars. In a tech startup, it means something very different.
It means ensuring your developers aren’t pushing secrets to public repositories. It means ensuring your sales team isn’t putting customer data into unapproved AI tools. It means that the Founders and the CTO are actively driving a culture where security is part of the product, not an afterthought.
The “Founder Mode” Problem
The biggest hurdle for startups with Annex A 5.4 is usually the founders themselves. You are used to having “God Mode” access to everything—production databases, AWS root accounts, the company bank account.
To comply with this control, management must lead by example. If the CTO disables MFA because it’s “annoying,” you have failed Annex A 5.4. The auditor will look specifically for this. They want to see that the rules apply to everyone, especially those at the top. You have to walk the talk.
Step 1: Bake Security into Your Tools (Jira, Slack, GitHub)
Don’t rely on a dusty employee handbook that nobody reads. To ensure policies are “applied” (as the standard requires), bake them into the tools your team uses every day.
- Onboarding: Use your HR or IT automation tool to ensure every new hire signs the Information Security Policy before they get their laptop.
- Code Reviews: Enforce branch protection rules in GitHub or GitLab. Make “Security Review” a mandatory step in your pull request process. Management’s responsibility is to ensure these checks are never bypassed.
- Communication: Use a dedicated #security-announcements channel in Slack or Teams. Post updates there and track emojis or replies as evidence of acknowledgement.
Step 2: Define Roles Without the Bloat
In a startup of 15 people, you don’t have a dedicated Compliance Officer. That’s fine. Annex A 5.4 doesn’t require new hires; it requires defined responsibilities.
Assign security ownership to existing roles:
- The CTO is responsible for secure coding standards and cloud infrastructure.
- The COO (or Founder) is responsible for physical security and HR checks.
- The Lead Dev is responsible for peer reviews and dependency scanning.
If you are struggling to map these out or need a template that makes sense for a lean team, Hightable.io offers toolkits specifically designed to help you define these roles quickly, satisfying the auditor without creating a heavy org chart.
Step 3: Training that Doesn’t Suck
Management must ensure personnel are competent. For a tech startup, generic security training is a waste of time. Your engineers know what a strong password is.
Fulfill your management responsibility by providing role-specific training. strict guidelines on using production data in staging environments, or how to handle API keys securely. Document that this training happened—even if it was just a 30-minute Zoom call recorded for the knowledge base.
Step 4: The Whistleblowing Channel
Startups often feel like families, which makes reporting security issues awkward. “I don’t want to rat out Dave for turning off the firewall.”
Management must provide a clear, safe way to report incidents or weaknesses. This could be a simple Typeform or a dedicated email alias. The key is that leadership must encourage reporting. When someone reports a bug or a vulnerability, celebrate it. That is positive evidence of management responsibility.
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How to Prove It to the Auditor
When the audit comes, you need artifacts. Since you likely don’t have a massive compliance department, use your native tools:
- Screenshots of PRs: Show that code was blocked because it failed a security check.
- Calendar Invites: Show that “Security Strategy” is a standing item in your quarterly leadership meeting.
- Offboarding Tickets: Show that when a contractor left, their access was revoked in under 24 hours (and that management oversaw this process).
Conclusion
ISO 27001 Annex A 5.4 isn’t about slowing you down. It’s about ensuring that as you scale, your security culture scales with you. It prevents the dangerous “technical debt” of security shortcuts that can kill a startup later on.
By integrating these responsibilities into your existing dev and ops processes, you can satisfy the requirement painlessly. And if you need a head start on the documentation or policy templates, checking out Hightable.io can save you weeks of drafting time, letting you get back to building your product.
About the author
Stuart Barker is a veteran practitioner with over 30 years of experience in systems security and risk management.
Holding an MSc in Software and Systems Security, Stuart combines academic rigor with extensive operational experience. His background includes over a decade leading Data Governance for General Electric (GE) across Europe, as well as founding and exiting a successful cyber security consultancy.
As a qualified ISO 27001 Lead Auditor and Lead Implementer, Stuart possesses distinct insight into the specific evidence standards required by certification bodies. He has successfully guided hundreds of organizations – from high-growth technology startups to enterprise financial institutions – through the audit lifecycle.
His toolkits represents the distillation of that field experience into a standardised framework. They move beyond theoretical compliance, providing a pragmatic, auditor-verified methodology designed to satisfy ISO/IEC 27001:2022 while minimising operational friction.
