Seed-stage B2B SaaS startup
Sample for a fictional organisation · 4,463 words[Company] Statement of Applicability
- Version: 1.0
- Owner: CTO
- Approved by: CEO
- Effective date: [Effective date]
- Next review date: [Review date]
1. Purpose and Scope
This statement lists the 93 information security controls in Annex A of ISO/IEC 27001:2022 and records, for each one, whether [Company] applies it, the justification for that decision and, for each control that applies, whether it is implemented. It follows what clause 6.1.3 d) of that standard asks a statement of applicability to contain: the controls [Company] needs, the justification for including them, whether they are implemented, and the justification for excluding any control in Annex A.
This statement applies to the scope of [Company]'s information security management system. [Company] has no offices or other premises: its staff work remotely and its systems run in the cloud. Controls that a supplier operates for [Company], such as the physical security of the data centers its cloud services run in, are covered through the supplier controls 5.19 to 5.23.
This statement was prepared from a profile of [Company]'s size, sector, systems, data and obligations, not from [Company]'s risk assessment or an audit of its controls. Each decision to apply or exclude a control, each justification and each status is a starting point. Before this statement is approved or shared outside [Company], the CTO checks it against the scope of the information security management system, and each control owner confirms or corrects the rows they own against the risk assessment and the risk treatment plan and changes any status that does not match what is in place. The CTO then raises the version number and updates the dates in the document control list.
4. Summary of Decisions
The table below counts the decisions in sections 5 to 8 by theme.
| Theme | Controls | Applicable | Excluded |
|---|---|---|---|
| Organizational | 37 | 37 | 0 |
| People | 8 | 8 | 0 |
| Physical | 14 | 6 | 8 |
| Technological | 34 | 33 | 1 |
| Total | 93 | 84 | 9 |
The table below counts the same 93 controls by the value in their Status column.
| Status | Controls |
|---|---|
| Partly implemented | 54 |
| Planned | 30 |
| Excluded | 9 |
| Total | 93 |
The excluded controls are 7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 7.11, 7.12 and 8.30. Sections 7 and 8 give the justification for each.
7. Physical Controls
Section 7 lists the 14 physical controls of Annex A. The CTO owns each control in this section.
| Control | Title | Applicable | Justification | Status |
|---|---|---|---|---|
| 7.1 | Physical security perimeters | No | [Company] has no offices or other premises, so there is no building perimeter, boundary or fence to secure. | Excluded |
| 7.2 | Physical entry | No | [Company] has no offices or other premises, so there are no entrances, visitors or access badges to manage. | Excluded |
| 7.3 | Securing offices, rooms and facilities | No | [Company] has no offices or other premises, so there are no rooms, floors or facilities to lock and protect. | Excluded |
| 7.4 | Physical security monitoring | No | [Company] has no offices or other premises, so there are no buildings or sites for cameras or alarms to watch. | Excluded |
| 7.5 | Protecting against physical and environmental threats | No | [Company] has no offices or other premises, so there is no site exposed to fire, flood or other environmental damage. | Excluded |
| 7.6 | Working in secure areas | No | [Company] has no offices or other premises, so there are no secure areas where staff work with restricted equipment or information. | Excluded |
| 7.7 | Clear desk and clear screen | Yes | Staff work at home and while traveling, where laptop screens and papers can be seen by family, visitors or strangers. | Partly implemented |
| 7.8 | Equipment siting and protection | Yes | Staff laptops and phones sit on home desks and shared spaces, where spills, damage and theft are real risks to customer data. | Partly implemented |
| 7.9 | Security of assets off-premises | Yes | Laptops and phones travel with staff outside their homes, and a lost or stolen device could expose customer data. | Partly implemented |
| 7.10 | Storage media | Yes | Staff may copy files to USB drives or external disks at home, which could carry customer PII out of cloud systems. | Partly implemented |
| 7.11 | Supporting utilities | No | [Company] has no offices or other premises, so there are no building utilities such as power, water or telecoms to keep running. | Excluded |
| 7.12 | Cabling security | No | [Company] has no offices or other premises, so there is no building cabling for power or data to protect. | Excluded |
| 7.13 | Equipment maintenance | Yes | Staff laptops and phones need repair and servicing from outside providers who could otherwise see the customer data on them. | Planned |
| 7.14 | Secure disposal or re-use of equipment | Yes | Old laptops and phones used by staff at home still hold customer data and credentials when they are sold, recycled or discarded. | Partly implemented |
Read the full example
[Company] Statement of Applicability
- Version: 1.0
- Owner: CTO
- Approved by: CEO
- Effective date: [Effective date]
- Next review date: [Review date]
1. Purpose and Scope
This statement lists the 93 information security controls in Annex A of ISO/IEC 27001:2022 and records, for each one, whether [Company] applies it, the justification for that decision and, for each control that applies, whether it is implemented. It follows what clause 6.1.3 d) of that standard asks a statement of applicability to contain: the controls [Company] needs, the justification for including them, whether they are implemented, and the justification for excluding any control in Annex A.
This statement applies to the scope of [Company]'s information security management system. [Company] has no offices or other premises: its staff work remotely and its systems run in the cloud. Controls that a supplier operates for [Company], such as the physical security of the data centers its cloud services run in, are covered through the supplier controls 5.19 to 5.23.
This statement was prepared from a profile of [Company]'s size, sector, systems, data and obligations, not from [Company]'s risk assessment or an audit of its controls. Each decision to apply or exclude a control, each justification and each status is a starting point. Before this statement is approved or shared outside [Company], the CTO checks it against the scope of the information security management system, and each control owner confirms or corrects the rows they own against the risk assessment and the risk treatment plan and changes any status that does not match what is in place. The CTO then raises the version number and updates the dates in the document control list.
2. Roles
- CTO: keeps this statement, compares the controls [Company] needs with Annex A at each review, and raises the version number when a row changes. The CTO is also accountable for the organizational controls in section 5, the physical controls in section 7 and the technological controls in section 8, and confirms the justification and status of each of those controls at each review.
- CEO: approves this statement and each exclusion in it. The CEO is also accountable for the people controls in section 6 and confirms the justification and status of each of those controls at each review.
- All staff: follow the policies and procedures that put the applicable controls into practice, and tell the CTO when a control is not working.
3. How to Read This Statement
Sections 5 to 8 carry the numbers of the four themes of Annex A, so control 6.3 is in section 6.
- Control and Title: the number and title of the control in Annex A of ISO/IEC 27001:2022. The text of each control is in the standard and is not reproduced in this statement.
- Applicable: "Yes" means [Company] has decided that it needs the control. "No" means [Company] has excluded it.
- Justification: for a control that applies, what [Company] has or does that makes the control necessary; for an excluded control, why [Company] does not need it.
- Status: whether a control that applies is in place. "Partly implemented" means part of the control is in place, and the rest must be recorded as an open action in the risk treatment plan before this statement is approved. "Planned" means the control is not yet in place, and putting it in place must be recorded as an open action in the risk treatment plan before this statement is approved. "Excluded" in the Status column marks a control that does not apply.
- Excluding a control: A control is excluded only where [Company] does not have what the control protects or does not do the activity it governs, never because of its cost or the effort it needs. A control that [Company] needs and does not yet have stays applicable, and its status shows that it is not yet in place.
- Open actions: Each open action in the risk treatment plan must have an owner and a target date.
- Choosing controls: The CTO decides which controls [Company] needs from its risk assessment, the laws and contracts it must meet and the way it works, and compares them with Annex A so that no necessary control is left out.
4. Summary of Decisions
The table below counts the decisions in sections 5 to 8 by theme.
| Theme | Controls | Applicable | Excluded |
|---|---|---|---|
| Organizational | 37 | 37 | 0 |
| People | 8 | 8 | 0 |
| Physical | 14 | 6 | 8 |
| Technological | 34 | 33 | 1 |
| Total | 93 | 84 | 9 |
The table below counts the same 93 controls by the value in their Status column.
| Status | Controls |
|---|---|
| Partly implemented | 54 |
| Planned | 30 |
| Excluded | 9 |
| Total | 93 |
The excluded controls are 7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 7.11, 7.12 and 8.30. Sections 7 and 8 give the justification for each.
5. Organizational Controls
Section 5 lists the 37 organizational controls of Annex A. The CTO owns each control in this section.
| Control | Title | Applicable | Justification | Status |
|---|---|---|---|---|
| 5.1 | Policies for information security | Yes | [Company] needs written rules that tell staff how to handle customer data and use the cloud tools the business runs on. | Partly implemented |
| 5.2 | Information security roles and responsibilities | Yes | [Company] must give every security duty for customer PII, AWS and GitHub a clear role, so no task goes unowned. | Partly implemented |
| 5.3 | Segregation of duties | Yes | Staff who can both change code in GitHub and deploy to AWS could make a harmful change with nobody else involved. | Partly implemented |
| 5.4 | Management responsibilities | Yes | Leadership at [Company] must set the example for staff in handling customer PII and using AI tools. | Partly implemented |
| 5.5 | Contact with authorities | Yes | [Company] handles PII for United States customers and must know which public authorities to contact after a serious incident. | Partly implemented |
| 5.6 | Contact with special interest groups | Yes | [Company] builds software on AWS and GitHub and gains from security communities that share news of threats. | Planned |
| 5.7 | Threat intelligence | Yes | Customer PII held in the cloud attracts attackers, so [Company] needs timely information about threats aimed at software businesses like it. | Planned |
| 5.8 | Information security in project management | Yes | New product features and projects at [Company] can change how customer PII is collected, stored or shared. | Planned |
| 5.9 | Inventory of information and other associated assets | Yes | [Company] relies on laptops, phones, AWS resources, Google Workspace data and GitHub repositories that it must be able to list and protect. | Partly implemented |
| 5.10 | Acceptable use of information and other associated assets | Yes | Staff use laptops, phones, Google Workspace and AI tools for their work and need clear limits on what they may do with them. | Partly implemented |
| 5.11 | Return of assets | Yes | Staff work remotely with laptops and phones that [Company] must be able to recover when someone leaves or changes role. | Partly implemented |
| 5.12 | Classification of information | Yes | Customer PII, source code and internal business data carry different levels of risk and need different handling. | Partly implemented |
| 5.13 | Labelling of information | Yes | Staff sharing files in Google Workspace need a clear way to tell customer PII from other business information. | Planned |
| 5.14 | Information transfer | Yes | Customer data, code and messages move between staff, customers and suppliers over the internet and through Google Workspace and GitHub. | Partly implemented |
| 5.15 | Access control | Yes | Customer PII, source code and AWS resources should be reachable only by staff whose work requires them. | Partly implemented |
| 5.16 | Identity management | Yes | Every person and service account that reaches Google Workspace, AWS or GitHub needs its own identity so actions can be traced. | Partly implemented |
| 5.17 | Authentication information | Yes | Passwords, access keys and tokens for AWS, GitHub and Google Workspace would give attackers direct access to customer PII if exposed. | Partly implemented |
| 5.18 | Access rights | Yes | Staff change tasks over time, so their rights in AWS, GitHub and Google Workspace must match what their current work needs. | Partly implemented |
| 5.19 | Information security in supplier relationships | Yes | [Company] depends on AWS, Google Workspace and GitHub, and a weakness at any of them could expose customer data. | Partly implemented |
| 5.20 | Addressing information security within supplier agreements | Yes | Supplier contracts must state what each provider may do with the customer PII it handles for [Company]. | Partly implemented |
| 5.21 | Managing information security in the ICT supply chain | Yes | The third-party packages and cloud services that [Company]'s software depends on can carry weaknesses into it. | Planned |
| 5.22 | Monitoring, review and change management of supplier services | Yes | AWS, Google Workspace and GitHub change their services over time, and those changes can affect how customer data is protected. | Planned |
| 5.23 | Information security for use of cloud services | Yes | Customer PII is held on AWS, so [Company] needs clear lines between what AWS secures and what it must secure itself. | Partly implemented |
| 5.24 | Information security incident management planning and preparation | Yes | Customer PII held in AWS could be exposed in a breach, so [Company] needs a prepared response with clear roles and contacts. | Partly implemented |
| 5.25 | Assessment and decision on information security events | Yes | Alerts from AWS and GitHub and reports from staff must be judged quickly as real incidents or harmless events. | Partly implemented |
| 5.26 | Response to information security incidents | Yes | Small and mid-sized business customers rely on [Company] to contain and fix any incident involving their PII quickly. | Partly implemented |
| 5.27 | Learning from information security incidents | Yes | Each incident or near miss at [Company] shows weaknesses in its cloud tools or habits that need correcting so they do not recur. | Planned |
| 5.28 | Collection of evidence | Yes | A dispute or breach involving customer PII could require trustworthy records from AWS, GitHub and staff devices as evidence. | Planned |
| 5.29 | Information security during disruption | Yes | Customers rely on [Company]'s software, so customer data must stay protected even while AWS or Google Workspace is disrupted. | Planned |
| 5.30 | ICT readiness for business continuity | Yes | [Company]'s product depends on AWS services that must be ready to recover quickly after a failure. | Planned |
| 5.31 | Legal, statutory, regulatory and contractual requirements | Yes | [Company] serves United States business customers and handles PII, so it faces privacy duties and customer contract terms it must identify. | Partly implemented |
| 5.32 | Intellectual property rights | Yes | [Company] writes its own software and uses third-party code, tools and AI services whose licenses and ownership rules it must respect. | Partly implemented |
| 5.33 | Protection of records | Yes | Business records, customer contracts and source code history in Google Workspace and GitHub must not be lost, altered or exposed. | Planned |
| 5.34 | Privacy and protection of PII | Yes | [Company] handles personally identifiable information for small and mid-sized business customers and must protect it from misuse or exposure. | Partly implemented |
| 5.35 | Independent review of information security | Yes | Business customers want confidence in [Company]'s security from someone other than the people who run it. | Planned |
| 5.36 | Compliance with policies, rules and standards for information security | Yes | Staff handling customer PII and cloud systems must follow [Company]'s rules, and leaders need a way to see whether they do. | Planned |
| 5.37 | Documented operating procedures | Yes | Routine tasks such as deploying code to AWS and managing accounts in Google Workspace need written steps that every staff member can follow. | Planned |
6. People Controls
Section 6 lists the 8 people controls of Annex A. The CEO owns each control in this section.
| Control | Title | Applicable | Justification | Status |
|---|---|---|---|---|
| 6.1 | Screening | Yes | Staff gain access to customer PII, source code and AWS, so [Company] needs confidence in the people it hires. | Partly implemented |
| 6.2 | Terms and conditions of employment | Yes | Each new hire gets access to customer PII and source code, so security duties must be part of their employment terms. | Partly implemented |
| 6.3 | Information security awareness, education and training | Yes | Staff use AI tools, email and cloud systems where mistakes can expose customer PII, so they need security awareness and training. | Partly implemented |
| 6.4 | Disciplinary process | Yes | [Company] needs a fair and known way to respond when an employee deliberately or carelessly puts customer PII at risk. | Planned |
| 6.5 | Responsibilities after termination or change of employment | Yes | Departing employees hold accounts in Google Workspace, AWS and GitHub and laptops with customer data that must be withdrawn. | Partly implemented |
| 6.6 | Confidentiality or non-disclosure agreements | Yes | Staff and suppliers see confidential customer information and source code that [Company] must keep from being passed on. | Partly implemented |
| 6.7 | Remote working | Yes | Staff work remotely from home and while traveling on home networks and public Wi-Fi that [Company] does not control. | Partly implemented |
| 6.8 | Information security event reporting | Yes | Staff are the first to notice phishing, lost devices or odd behavior in cloud tools, so they need an easy way to report it. | Partly implemented |
7. Physical Controls
Section 7 lists the 14 physical controls of Annex A. The CTO owns each control in this section.
| Control | Title | Applicable | Justification | Status |
|---|---|---|---|---|
| 7.1 | Physical security perimeters | No | [Company] has no offices or other premises, so there is no building perimeter, boundary or fence to secure. | Excluded |
| 7.2 | Physical entry | No | [Company] has no offices or other premises, so there are no entrances, visitors or access badges to manage. | Excluded |
| 7.3 | Securing offices, rooms and facilities | No | [Company] has no offices or other premises, so there are no rooms, floors or facilities to lock and protect. | Excluded |
| 7.4 | Physical security monitoring | No | [Company] has no offices or other premises, so there are no buildings or sites for cameras or alarms to watch. | Excluded |
| 7.5 | Protecting against physical and environmental threats | No | [Company] has no offices or other premises, so there is no site exposed to fire, flood or other environmental damage. | Excluded |
| 7.6 | Working in secure areas | No | [Company] has no offices or other premises, so there are no secure areas where staff work with restricted equipment or information. | Excluded |
| 7.7 | Clear desk and clear screen | Yes | Staff work at home and while traveling, where laptop screens and papers can be seen by family, visitors or strangers. | Partly implemented |
| 7.8 | Equipment siting and protection | Yes | Staff laptops and phones sit on home desks and shared spaces, where spills, damage and theft are real risks to customer data. | Partly implemented |
| 7.9 | Security of assets off-premises | Yes | Laptops and phones travel with staff outside their homes, and a lost or stolen device could expose customer data. | Partly implemented |
| 7.10 | Storage media | Yes | Staff may copy files to USB drives or external disks at home, which could carry customer PII out of cloud systems. | Partly implemented |
| 7.11 | Supporting utilities | No | [Company] has no offices or other premises, so there are no building utilities such as power, water or telecoms to keep running. | Excluded |
| 7.12 | Cabling security | No | [Company] has no offices or other premises, so there is no building cabling for power or data to protect. | Excluded |
| 7.13 | Equipment maintenance | Yes | Staff laptops and phones need repair and servicing from outside providers who could otherwise see the customer data on them. | Planned |
| 7.14 | Secure disposal or re-use of equipment | Yes | Old laptops and phones used by staff at home still hold customer data and credentials when they are sold, recycled or discarded. | Partly implemented |
8. Technological Controls
Section 8 lists the 34 technological controls of Annex A. The CTO owns each control in this section.
| Control | Title | Applicable | Justification | Status |
|---|---|---|---|---|
| 8.1 | User endpoint devices | Yes | Every laptop and phone that reaches Google Workspace, AWS or GitHub is a doorway to customer PII if lost or compromised. | Partly implemented |
| 8.2 | Privileged access rights | Yes | Administrator rights in AWS, GitHub and Google Workspace can change or delete everything, so they need tighter control than ordinary accounts. | Partly implemented |
| 8.3 | Information access restriction | Yes | Customer PII, internal files and repositories each hold information that only certain staff should be able to open or change. | Partly implemented |
| 8.4 | Access to source code | Yes | [Company]'s source code in GitHub is its main product asset, and unauthorized changes or copying would harm customers and the business. | Partly implemented |
| 8.5 | Secure authentication | Yes | Staff sign in to Google Workspace, AWS and GitHub from remote locations, so passwords alone would leave customer PII exposed to stolen credentials. | Partly implemented |
| 8.6 | Capacity management | Yes | Customers depend on [Company]'s cloud-hosted product, which needs enough AWS computing and storage capacity to keep working as usage grows. | Planned |
| 8.7 | Protection against malware | Yes | Laptops, phones and files shared through Google Workspace can be infected by malware that steals credentials or customer PII. | Partly implemented |
| 8.8 | Management of technical vulnerabilities | Yes | [Company]'s software, its dependencies and its AWS resources can contain flaws that attackers exploit to reach customer PII. | Partly implemented |
| 8.9 | Configuration management | Yes | AWS accounts, GitHub organizations and staff devices have many settings, and a wrong setting can silently expose customer data. | Planned |
| 8.10 | Information deletion | Yes | Customer PII in AWS and Google Workspace must be removed completely when it is no longer needed or a customer asks. | Planned |
| 8.11 | Data masking | Yes | Engineers working with customer data and AI tools do not need to see real PII, only disguised values. | Planned |
| 8.12 | Data leakage prevention | Yes | Customer PII could leak through email, shared Google Workspace files, GitHub repositories or prompts entered into AI tools. | Planned |
| 8.13 | Information backup | Yes | Customer data in AWS and business files in Google Workspace would be lost for good after a failure, deletion or attack without copies. | Partly implemented |
| 8.14 | Redundancy of information processing facilities | Yes | [Company]'s customers need its cloud-hosted product to stay available when a single AWS component or zone fails. | Planned |
| 8.15 | Logging | Yes | Records of who accessed or changed AWS, GitHub and Google Workspace are needed to investigate incidents and prove what happened. | Partly implemented |
| 8.16 | Monitoring activities | Yes | Unusual activity in AWS, GitHub and Google Workspace can go unnoticed, harming customers, unless someone is watching for it. | Planned |
| 8.17 | Clock synchronization | Yes | Accurate timestamps across laptops, AWS and GitHub are needed so that records of an incident can be put in the right order. | Partly implemented |
| 8.18 | Use of privileged utility programs | Yes | Powerful administration tools and scripts used with AWS can bypass normal safeguards and reach customer PII directly. | Planned |
| 8.19 | Installation of software on operational systems | Yes | Unvetted software on AWS workloads or staff laptops could bring malware or weaknesses into systems that handle customer PII. | Partly implemented |
| 8.20 | Networks security | Yes | Staff connect from home networks and public Wi-Fi to cloud systems, so traffic carrying customer PII needs protection on the way. | Partly implemented |
| 8.21 | Security of network services | Yes | [Company] depends on internet providers and AWS networking services whose weaknesses or outages could affect its product and its customers. | Partly implemented |
| 8.22 | Segregation of networks | Yes | [Company]'s AWS environment holds production customer data that should be kept apart from development and staff-facing networks. | Planned |
| 8.23 | Web filtering | Yes | Staff browse the web and use AI tools from remote laptops, where malicious or unsafe sites could reach customer PII. | Planned |
| 8.24 | Use of cryptography | Yes | Customer PII stored in AWS and sent between staff, customers and suppliers needs cryptographic protection against exposure or tampering. | Partly implemented |
| 8.25 | Secure development life cycle | Yes | [Company]'s own staff write the software its business customers use, so security must be built in at every stage of development. | Partly implemented |
| 8.26 | Application security requirements | Yes | Customer-facing features that process PII for small and mid-sized businesses need clear security requirements before engineers start building them. | Partly implemented |
| 8.27 | Secure system architecture and engineering principles | Yes | A cloud-hosted product on AWS holding customer PII needs sound design principles so that one flaw does not expose everything. | Planned |
| 8.28 | Secure coding | Yes | Staff write all of [Company]'s code, and common coding mistakes could create flaws that expose customer PII. | Partly implemented |
| 8.29 | Security testing in development and acceptance | Yes | Code changes headed for release to customers need security testing and acceptance checks so flaws are found before they reach customer PII. | Planned |
| 8.30 | Outsourced development | No | [Company]'s own staff write all of its software, so there is no outsourced development. | Excluded |
| 8.31 | Separation of development, test and production environments | Yes | Engineers building features in GitHub must not work directly in the AWS production environment holding live customer data. | Partly implemented |
| 8.32 | Change management | Yes | Changes to code in GitHub and to AWS resources can break the product or open security gaps for customers if made carelessly. | Partly implemented |
| 8.33 | Test information | Yes | Engineers need realistic data for development and testing, and copying real customer PII into those environments would put it at risk. | Planned |
| 8.34 | Protection of information systems during audit testing | Yes | Checks of [Company]'s AWS and Google Workspace systems by customers or outside parties could disrupt operations or expose customer PII if not controlled. | Planned |
9. Controls from Other Sources
Annex A is not a complete list of controls, and ISO/IEC 27001:2022 allows controls from any source. Where [Company]'s risk treatment needs a control that Annex A does not contain, the CTO adds it to this section with a justification and a status, in the same way as an Annex A control. This version of the statement records no such control.
10. Review and Maintenance
- The CTO reviews every row with the control owners at least once every 12 months, and the CEO approves the statement after each review.
- Each review checks that every decision still matches the risk assessment and the risk treatment plan, that every exclusion still holds, and that every status matches what is in place.
- The statement is reviewed sooner when the risk assessment changes, when the scope of the information security management system changes, when [Company] adopts a new system or supplier that changes how a control is met, when it opens or closes premises or starts or stops developing software, when a new law or contract adds a requirement, or when an incident or an audit shows that a control is missing or not working.
- A control that the risk treatment plan relies on must be applicable in this statement, and the two documents must agree.
- Every change to a row raises the version number and the date. Earlier versions are kept, so that the version an auditor or a customer was given can be produced.
- A copy is shared outside [Company] only with the approval of the CTO, and every copy carries its version number and date.
Disclaimer
This document is provided for informational purposes only and does not constitute legal advice. It is provided "as is", without warranty of any kind, express or implied, and no liability is accepted for any loss or damage arising from its use. It is used at your own discretion. Review it with a qualified adviser before adopting it.