ISO 27001:2022 Annex A 8.30 Outsourced Development for SMEs

In this guide, I will show you exactly how small businesses and SMEs can implement ISO 27001:2022 Annex A 8.30 Outsourced development without the enterprise-level complexity. You will get a complete walkthrough of the control tailored for organizations with limited resources, along with practical examples and access to ISO 27001 templates that make compliance easy.

I am Stuart Barker, an ISO 27001 Lead Auditor with over 30 years of experience auditing businesses of all sizes. I will cut through the jargon to show you exactly what changed in the 2022 update and provide the plain-English advice you need to get your small business certified.

Key Takeaways: ISO 27001 Annex A 8.30 Outsourced Development (SME Edition)

For Small and Medium-sized Enterprises (SMEs), ISO 27001 Annex A 8.30 addresses the “Blind Trust” trap. When you hire a freelancer or dev agency to build your app or website, you cannot outsource the risk. If they leave a backdoor open or use vulnerable code, you are liable for the data breach. This control ensures that you maintain supervision and security standards over code written outside your office walls.

Core requirements for compliance include:

• The Contract is King: You must define security requirements before work begins. Your Statement of Work (SoW) must explicitly mention secure coding standards (like OWASP Top 10) and prohibit the use of live customer data for testing.
• Right to Audit: You must legally reserve the right to review their code or run security scans against it. If they refuse to let you check their work, that is a major red flag.
• Supply Chain Transparency: You need to know what ingredients are in your software. Ask for a Software Bill of Materials (SBOM) to track open-source libraries that might have hidden vulnerabilities.
• No “Blind Acceptance”: Do not pay the final invoice until the code has passed a security check. Verify that requirements (e.g. “Account locks after 5 failed attempts”) actually work.
• Intellectual Property: Clarify ownership. You must own not just the finished product, but the security configurations and documentation to ensure future maintenance is possible.

Audit Focus: Auditors will look for “The Governance Trail”:

1. The Contract: “Show me the agreement with your dev agency. Where does it say they must code securely?”
2. The Check: “You received the code last month. Show me the scan report or manual review you did before launching it.”
3. Data Handling: “How do you ensure the freelancer isn’t using your real customer database on their personal laptop?” (Evidence of test data creation).

SME Outsourcing Checklist (Audit Prep):

Checkpoint	Action Required	Evidence Artifact
Pre-Contract	Define “Secure Coding” in the agreement.	Signed SoW with security clauses.
Development	Monitor code quality.	Automated scan report (e.g. SonarQube).
Testing	Verify security features work.	Acceptance Test Log (UAT).
Handover	Ensure ownership of code/docs.	Repository Transfer Log.

What is ISO 27001 Annex A 8.30 for SMEs?

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.

Fast Track ISO 27001 Annex A 8.30 Compliance for SMEs with the ISO 27001 Toolkit

For Small Businesses and SMEs, 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. Whether you are hiring a freelancer or a dedicated agency, handing over code and data introduces significant risks like backdoors or data theft. You cannot outsource responsibility; if your agency builds a vulnerability, the liability sits with you.

While SaaS compliance platforms often try to sell you “automated vendor tracking” or complex “third-party risk modules”, they cannot actually write the security clauses for your specific contracts or ensure your agency is not using live customer data for testing. Those are human governance and legal tasks. The High Table ISO 27001 Toolkit is the logical choice for SMEs because it provides the outsourcing framework you need without a recurring subscription fee.

1. Ownership: You Own Your Outsourcing Governance Forever

SaaS platforms act as a middleman for your compliance evidence. If you define your outsourced development rules and store your agency contracts inside their proprietary system, you are essentially renting your own supply chain security.

• The Toolkit Advantage: You receive the Secure Coding Standards and Supplier Security Clauses in fully editable Word formats. These files are yours forever. You maintain permanent ownership of your records, such as your specific history of code review sign-offs, ensuring you are always ready for an audit without an ongoing “rental” fee.

2. Simplicity: Governance to Avoid the “Blind Trust” Trap

Annex A 8.30 is about supervision and monitoring. You do not need a complex new software interface to manage what a well-structured Statement of Work (SoW) and a formal acceptance testing process already do perfectly.

• The Toolkit Advantage: SMEs need to avoid assuming the agency “knows what they are doing”. What they need is the governance layer to prove to an auditor that security requirements were established before work began. The Toolkit provides pre-written “Acceptance Testing Checklists” and “Contract Clauses” that formalise your existing agency relationships into an auditor-ready framework, without forcing your team to learn a new software platform just to log a code scan.

3. Cost: A One-Off Fee vs. The “Agency” Tax

Many compliance SaaS platforms charge more based on the number of “vendors”, “outsourced projects”, or “active contracts” you track. For an SME, these monthly costs can scale aggressively for very little added value.

• The Toolkit Advantage: You pay a single, one-off fee for the entire toolkit. Whether you work with 1 freelancer or 10 agencies, the cost of your Outsourced Development Documentation remains the same. You save your budget for actual software development rather than an expensive compliance dashboard.

4. Freedom: No Vendor Lock-In for Your Supply Chain Strategy

SaaS tools often mandate specific ways to report on and monitor “outsourced development”. If their system does not match your unique business model or specialised industry requirements, such as a specific “Right to Audit” clause, the tool becomes a bottleneck to efficiency.

• The Toolkit Advantage: The High Table Toolkit is 100% technology-agnostic. You can tailor the Outsourcing Procedures to match exactly how you operate, whether you use formal agency audits or simple, risk-managed automated code scans. You maintain total freedom to evolve your supply chain strategy without being constrained by the technical limitations of a rented SaaS platform.

Summary: For SMEs, the auditor wants to see proof of governance, such as contracts with explicit security clauses and evidence of acceptance testing before launch. The High Table ISO 27001 Toolkit provides the governance framework to satisfy this requirement immediately. It is the most direct, cost-effective way to achieve compliance using permanent documentation that you own and control.