If you walk into a tech startup today, you won’t see rows of filing cabinets or server racks. You will see people on laptops, wearing noise-canceling headphones, pushing code to the cloud. In this environment, the traditional idea of an “Asset Inventory” feels outdated. You don’t have many physical things to count.
However, your assets are there, they are just invisible. They are S3 buckets full of customer logs, repositories of proprietary algorithms on GitHub, and API keys connecting your Stripe account to your backend.
ISO 27001 Annex A 5.9: Inventory of Information and Other Associated Assets is the control that forces you to visualize this invisible infrastructure. For a tech startup, this isn’t about counting monitors; it is about mapping your survival.
Here is how to implement Annex A 5.9 in a high-growth tech environment where the “assets” change every time a developer spins up a new container.
Table of contents
What is Annex A 5.9 Asking For?
The standard requires you to identify information and associated assets, document them in an inventory, and assign ownership.
The 2022 update is particularly important for tech companies because it explicitly distinguishes between:
- Information: The value (e.g., Customer PII, Source Code, Financial Projections).
- Associated Assets: The container (e.g., The Production Database, The Laptop, The SaaS Tool).
You need to know what valuable data you have and where it lives.
The “Startup” Asset List: What actually counts?
Don’t waste time inventorying the office coffee machine. Focus on the assets that, if lost or compromised, would kill your company. For a tech startup, your inventory should be dominated by:
1. Code and Intellectual Property
Your source code is likely your most valuable asset.
Asset: “Monolith Repository (GitHub).”
Owner: CTO.
2. Cloud Infrastructure
You don’t own servers, but you own configurations.
Asset: “AWS Production Environment (us-east-1).”
Asset: “GCP Kubernetes Cluster.”
3. SaaS Sprawl
Startups run on SaaS. Every tool that holds data is an asset.
Asset: “Slack Workspace” (Internal Comms).
Asset: “HubSpot” (Customer Data).
Asset: “Linear/Jira” (Product Roadmap).
4. Secrets and Keys
Often overlooked, but critical.
Asset: “Master Encryption Keys” or “Stripe Production API Keys.”
Step 1: The Great “Shadow IT” Hunt
In a startup, developers love trying new tools. “I just spun up a Vercel instance to test this feature” is a common phrase. That Vercel instance is now an asset.
To implement Annex A 5.9, start with a discovery phase. Don’t just ask IT. Ask the team leads:
- Marketing: “Where are we storing the email list?” (Mailchimp? Notion?)
- Engineering: “Do we have any test databases running on personal accounts?”
- HR: “Where are the employee contracts?” (Google Drive? DocuSign?)
You will likely find 20% more assets than you thought you had. This discovery process is often the most valuable part of the entire ISO 27001 journey.
Step 2: Assigning Ownership (The “Bus Factor”)
Every asset needs an owner. In a flat startup structure, this is tricky. You don’t want to assign everything to the Founder.
The Rule of Thumb: The owner is the person who has the authority to delete it or grant access to it.
- Production DB: Owned by the VP of Engineering.
- Sales CRM: Owned by the Head of Sales.
- Company Laptop: Owned by the Employee using it (they are responsible for its physical security).
Step 3: Building the Inventory (Keep it Agile)
You do not need enterprise asset management software that costs $10k a year. A well-structured spreadsheet or a dedicated page in your Notion workspace is compliant, provided it is maintained.
Your register needs to track:
- Asset Name: (e.g., AWS S3 – Customer Docs)
- Type: (Cloud Storage)
- Owner: (DevOps Lead)
- Classification: (Confidential)
- Location: (Cloud – EU Region)
If you want to ensure your spreadsheet covers the “Associated Assets” nuance correctly without over-engineering it, Hightable.io provides specific ISO 27001 toolkits for tech startups. Their Asset Inventory templates are designed to handle intangible assets like code and cloud containers natively.
Step 4: Handling “Ephemeral” Assets
A common question from startups: “We spin up dynamic EC2 instances that live for 4 hours. Do I need to log every single one?”
The Answer: No. That would be madness.
You inventory the Service or the Group. You list “Auto-Scaling Group: Web Servers” as the asset. The individual instances are just temporary manifestations of that asset.
DO IT YOURSELF
STOP SPANKING £10,000s on CONSULTANTS and ISMS ONLINE PLATFORMS
Common Pitfalls for Tech Startups
Inventorying “The Internet”:
Don’t list “GitHub” as the asset. List “Our Repositories hosted on GitHub.” You don’t own GitHub; you own your data inside it.
Ignoring Personal Devices (BYOD):
If your developers use their personal MacBooks to access the production database, those MacBooks are now “Associated Assets” and need to be tracked (and secured).
Conclusion
ISO 27001 Annex A 5.9 isn’t meant to slow you down. It is meant to give you visibility. You can’t secure your startup if you don’t know where your data is. By mapping your SaaS tools, cloud infrastructure, and code repositories, you build a map of your digital territory.
Start by hunting down your Shadow IT, group your cloud assets logically, and use the templates at Hightable.io to get your documentation audit-ready fast, so you can get back to shipping features.
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.
