For small businesses and startups, outsourcing software development is often a necessity. Whether you are hiring a freelancer on Upwork or a dedicated agency, it is cost-effective and scalable. However, handing over your code and data to a third party introduces significant security risks.
ISO 27001 Annex A 8.30 (Outsourced Development) is the control that ensures you do not lose control of your security just because the code is being written outside your office walls.
What is ISO 27001 Annex A 8.30?
Annex A 8.30 requires an organisation to supervise and monitor the development of software outsourced to third parties. In simple terms, you are responsible for ensuring that the external developers follow the same security rules as your internal staff.
The standard makes it clear: You cannot outsource responsibility. If your agency builds a vulnerability into your app and you get hacked, the liability sits with you.
The “Blind Trust” Trap
Small businesses often fall into the trap of assuming the agency “knows what they are doing.” You might assume that because you paid for professional development, the code is secure. This is rarely the case unless security was explicitly specified in the contract.
Without Annex A 8.30, you risk:
- Backdoors: Developers leaving debug access open.
- Data Theft: Freelancers downloading your live database to their insecure personal laptops.
- Spaghetti Code: Poorly documented code that makes future security updates impossible.
- Supply Chain Attacks: Compromised libraries being used in your software.
How to Comply: 3 Critical Steps for SMEs
To satisfy this control without hiring a full-time security manager, focus on these three areas: Contracts, Monitoring, and Testing.
1. The Contract (The Foundation)
You must establish security requirements before work begins. Your contract or Statement of Work (SoW) should explicitly state:
- Secure Coding Standards: The developer must follow standards like OWASP Top 10.
- Data Handling: Real customer data must not be used for testing (see Annex A 8.33).
- Right to Audit: You reserve the right to scan or review their code for security flaws.
- Intellectual Property: Clarify that you own the code and the security configurations.
2. Monitoring and Supervision
Do not wait until the end of the project to check the quality. Regular checkpoints are essential.
- Code Reviews: Even if you are non-technical, ask for automated code scan reports (e.g., from tools like SonarQube or Snyk).
- Supply Chain Security: Ask for a Software Bill of Materials (SBOM) to know exactly what open-source libraries they are using.
3. Acceptance Testing
Never accept software blindly. Before the final payment is released and the code goes live, you must perform Acceptance Testing. Verify that the security requirements in the contract were actually met. If they built a login page, does it lock out after 5 failed attempts? If not, send it back.
What the Auditor Will Ask
When auditing a small business using external agencies, the ISO 27001 auditor will want to see proof of governance. Be ready for these questions:
- “Show me the contract with your development agency. Where are the security clauses?”
- “How do you ensure they are not using your live customer data on their local machines?”
- “Did you scan the code for vulnerabilities before you launched it? Show me the report.”
Summary Checklist for SMEs
- Define security requirements in the initial contract.
- Prohibit the use of live production data in the agency’s test environment.
- Require regular reports on code quality and security scans.
- Test the software for security flaws before final acceptance.
- Retain the right to audit the agency’s security practices.
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.

