Auditing ISO 27001 Annex A 8.30 Outsourced Development is the technical verification of security integrity within third-party engineering workflows. The Primary Implementation Requirement is the enforcement of contractual security mandates and automated code scanning, providing the Business Benefit of protecting intellectual property while ensuring external deliverables meet internal security standards.
ISO 27001 Annex A 8.30 Outsourced Development Audit Checklist
This technical verification tool is designed for lead auditors to establish the security integrity of software developed by third-party providers. Use this checklist to validate compliance with ISO 27001 Annex A 8.30.
1. Outsourced Development Security Policy Formalisation Verified
Verification Criteria: A formalised policy exists defining the mandatory security requirements, coding standards, and testing protocols for all outsourced development projects.
Required Evidence: Approved “Third-Party Development Policy” or “Outsourced Coding Standard” with explicit version control.
Pass/Fail Test: If the organisation cannot produce a formalised document specifying the security mandates for external developers, mark as Non-Compliant.
2. Contractual Security Obligations and Right-to-Audit Confirmed
Verification Criteria: Technical and organisational security requirements, including vulnerability remediation SLAs and the right to perform independent audits, are embedded in the developer’s contract.
Required Evidence: Signed Master Service Agreement (MSA) or Statement of Work (SOW) with highlighted security clauses and audit rights.
Pass/Fail Test: If a third-party developer has access to the codebase without a contractually binding security schedule, mark as Non-Compliant.
3. Intellectual Property and Source Code Ownership Validated
Verification Criteria: Legal and technical provisions ensure the organisation retains ownership and control over the source code, preventing unauthorised reuse or retention by the provider.
Required Evidence: Contractual “Ownership of Work Product” clauses and access logs from the organisation-owned version control system (VCS).
Pass/Fail Test: If the outsourced developer hosts the organisation’s production source code on an unmanaged, private repository without administrative oversight, mark as Non-Compliant.
4. Secure External Access to Development Environments Verified
Verification Criteria: Access granted to external developers is restricted via Multi-Factor Authentication (MFA) and limited to the specific environments required for the project (Least Privilege).
Required Evidence: Identity and Access Management (IAM) logs showing MFA-protected logins and restricted VPN/Bastion host access for third-party IDs.
Pass/Fail Test: If an external developer can access the development network using single-factor authentication or has access to internal production servers, mark as Non-Compliant.
5. Automated Security Scanning of Outsourced Code Confirmed
Verification Criteria: All code delivered by the third party is subjected to automated Static Application Security Testing (SAST) and Software Composition Analysis (SCA) prior to acceptance.
Required Evidence: SAST/SCA scan reports (e.g., Snyk, SonarQube) specifically for the modules delivered by the external provider.
Pass/Fail Test: If outsourced code is integrated into the main branch without a documented vulnerability scan, mark as Non-Compliant.
6. Independent Vulnerability Assessment and Pentesting Validated
Verification Criteria: Major deliverables from the outsourced provider undergo an independent penetration test to verify the efficacy of the implemented security controls.
Required Evidence: Signed Penetration Test report dated within the project completion window and a corresponding Remediation Tracker.
Pass/Fail Test: If a third-party application is promoted to production without a verified independent security assessment, mark as Non-Compliant.
7. Secure Handling of Sensitive Data by Providers Verified
Verification Criteria: Technical mechanisms prevent the use of live production data by outsourced developers, enforcing the use of masked or synthetic data in external environments.
Required Evidence: Data Masking logs or UAT environment snapshots demonstrating the absence of legitimate PII/financial records.
Pass/Fail Test: If unmasked production PII is found residing in a third-party developer’s environment or a shared staging area, mark as Non-Compliant.
8. Supply Chain Dependency Vetting Recorded
Verification Criteria: The organisation verifies that the outsourced provider has a process to vet and monitor the security of fourth-party libraries and open-source components used in the build.
Required Evidence: Software Bill of Materials (SBOM) provided by the developer and the organisation’s internal verification logs.
Pass/Fail Test: If the outsourced developer cannot provide a list of third-party libraries used in the deliverable or their associated licenses, mark as Non-Compliant.
9. Developer Background and Personnel Security Confirmed
Verification Criteria: The outsourced provider confirms that all personnel assigned to the project have undergone appropriate background screening and have signed non-disclosure agreements (NDAs).
Required Evidence: Attestation of Background Checks from the provider or signed NDAs for each named developer on the project.
Pass/Fail Test: If the provider cannot demonstrate that background screening has been conducted for developers with access to sensitive source code, mark as Non-Compliant.
10. Formal Acceptance and Security Sign-off Verified
Verification Criteria: A formalised acceptance process exists where the organisation’s security lead signs off on the third-party deliverable based on the successful results of all security tests.
Required Evidence: Final Project Acceptance Document or “Go/No-Go” meeting minutes with a specific “Security Approval” field.
Pass/Fail Test: If the outsourced code is deployed to production without a formal record of internal security acceptance, mark as Non-Compliant.
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Contractual Mandates | Tool records “SOW Uploaded” as compliance. | Verify the Annex. Does the SOW actually define CVE remediation timelines (e.g., 48 hours for Critical)? If not, the ‘Contract’ is a failure. |
| Access Control | GRC dashboard identifies that “Partner Access is Managed.” | Test the Perimeter. Can the third-party developer jump from the Dev VPC to the Prod VPC? GRC tools don’t check for lateral movement. |
| Ownership Proof | Platform assumes code is owned because it’s paid for. | Check the Git Config. Who owns the private repo where the dev works? If it’s the dev’s personal account, the organization has lost control. |
| Testing Efficacy | Tool checks for a “Pentest Report” upload. | Verify Independence. Did the outsourced provider mark their own homework, or did an independent third party perform the test? |
| Data Sanitisation | SaaS tool accepts an answer of “No Production Data Used.” | Audit the VCS History. Scan the commit history for hardcoded secrets or PII accidentally pushed by external contractors. |
| Supply Chain | Tool identifies that an “SBOM was requested.” | Check for Action. Did the organization actually scan the SBOM for vulnerabilities, or just file it away? |
| Sign-off Integrity | Platform identifies the “Project Manager” as the approver. | Verify Technical Authority. A Project Manager is not a security expert. The ‘Pass’ must be signed by the CISO or Lead Security Engineer. |
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