How to Implement ISO 27001 Annex A 8.30 Outsourced Development
Welcome to this guide on ISO 27001 Annex A 8.30. If you are reading this, you are likely looking at your Statement of Applicability and wondering how to handle software development that you do not do in house. As a certification body, we see many companies struggle here. You might think that because you hired a professional agency, the security risk is their problem. This is a common mistake.
We want to help you understand exactly what this control requires. At ISO27001.com, we believe that compliance should be practical rather than just a box ticking exercise. This control focuses on outsourced development. It ensures that any software or code created by a third party is just as secure as if you wrote it yourself. You remain responsible for the risk, so you must supervise the process.
Table of contents
Understanding the Core Requirement
Annex A 8.30 deals with the risks associated with external software development. When you hire a contractor or a development house, you are opening a door to your data. The goal is to ensure that information security is part of the software development lifecycle from the very start.
You need to direct, monitor, and review the work of the outsourcer. You cannot simply sign a contract and wait for the finished product. An auditor will look for evidence that you defined security requirements before a single line of code was written. We expect to see that you maintained control throughout the project.
Define Your Security Requirements First
The first step is often the most important. You must tell your developer what you expect regarding security. Do not assume they know your internal standards. You should create a document that outlines specific security needs for the project. This might include rules on data encryption, user authentication, or how logs are handled.
If you have a Secure Development Policy, as suggested in other parts of the standard, you should share relevant parts with the vendor. If you do not tell them that you need two factor authentication, they might not build it. When we audit you, we will ask to see the requirements document you sent to the developer.
Secure the Agreement
Once you know what you want, you need to put it in writing. The legal contract is your best tool for enforcement. You should include specific clauses that mandate secure coding practices. This is where you protect your organization legally and technically.
Your agreement should cover several key areas. You need to define who owns the code and who is responsible if a vulnerability is found later. You should also require the vendor to scan for bugs or security flaws before they deliver the work. At ISO27001.com, we recommend looking for clauses that allow you to audit their work or require them to provide evidence of their own testing.
Supervise the Development Process
Implementing Annex A 8.30 means staying involved. You should not be a passive observer. Depending on the size of the project, you might need regular check ins to discuss security. If the vendor plans to use open source libraries, you should know about it. You need to ensure they are not introducing known vulnerabilities into your environment.
You should also monitor their testing environment. They should not use your live production data for testing unless it has been sanitized or masked. We often find non conformance here. If an auditor sees real customer data in a test environment hosted by a third party, it will likely be a major issue.
The Acceptance Phase
Before you accept the final code, you must verify it. This is your quality gate. You need to perform acceptance testing that specifically looks at security. This could involve running your own vulnerability scans or doing a manual code review. If you do not have the skills in house to check the code, you might need to hire a specialist to do a penetration test.
You should only approve the work once you are satisfied that your requirements have been met. If you find issues, the vendor must fix them before the project is signed off. Keep records of these tests. They are the best evidence you can show an auditor to prove you followed the process.
What the Auditor Wants to See
When we arrive for your certification audit, we look for a paper trail. We want to see the story of your outsourced project. You should be able to show us the initial email or document where you listed security requirements. We will ask to see the contract with the security clauses highlighted.
We will also look for evidence of your supervision. This could be minutes from project meetings where security was discussed. Finally, we need to see the results of your acceptance testing. If you can show us that you found a security bug and the vendor fixed it before launch, that is excellent evidence of an effective process.
Implementing ISO 27001 Annex A 8.30 does not have to be painful. It is about applying the same level of care to external vendors that you apply to your own team. If you follow these steps, you will protect your data and you will be ready for your audit.
