For SMEs and startups, ISO 27001 can seem complex. A hybrid approach – handling core tasks internally while engaging external support for specialised activities – may help lean teams structure their ISMS, retain oversight while considering certification-related activities if applicable.
In a hybrid ISO 27001 model, the organisation retains ultimate accountability for its ISMS under the Standard, regardless of whether specific tasks are performed by external providers. Outsourcing a task does not transfer overall responsibility. In practice, this often means keeping risk decisions, policies, and evidence in-house, while outsourcing activities such as penetration testing, certification audits, or legal reviews.
Why a DIY vs Outsource Strategy Matters
ISO 27001 emphasises structured processes, documented evidence, and operational ownership. For small teams, attempting to handle everything internally may lead to burnout, while outsourcing all tasks can reduce internal knowledge retention and influence and control over the ISMS. A hybrid approach, combining internal ownership with targeted external support, may help teams prioritise effort while retaining accountability – particularly where no dedicated compliance function exists.
Benefits of a Hybrid Approach:
- Supports internal ownership of sensitive processes
- Can reduce costs by leveraging specialised services selectively when needed
- Helps retain oversight of your ISMS
- May help clarify documentation and responsibility for internal reference
The In-House List: Core ISO 27001 Tasks to Manage Internally
1. Risk Management
The Standard generally expects organisations to demonstrate ownership of their risk decisions. This may help the team identify operational vulnerabilities and consider possible responses.
- Identifying risks relevant to the specific business context such as data breaches, cloud failures, or human error
- Mapping Annex A controls to risks in your Statement of Applicability (SoA)
- Reviewing risk treatment decisions to ensure they align with the organisation's risk appetite.
Practical Tip: A SaaS startup might log all cloud incidents monthly to directly connect them to risk treatment actions. Keeping this in-house may help maintain clearer internal records for reference or observation.
2. Policy Ownership
Policies reflect what your team actually does, so internal authorship is generally recommended. This may help ensure policies are more relevant to team practices and easier for responsible staff to understand.
The ISO 27001 standard requires certain documented policies. Common examples that organisations often develop include, but not limited to:
- Information Security Policy
- Access Control Policy
- Asset Management and Operations Security Policies
Practical tip: Keeping monthly access review logs in-house may help maintain clearer records. SMEs can adapt policies to reflect actual team size and operations.
3. Evidence Collection
Documentation and records provide the backbone of your ISMS. Maintaining core evidence internally may help your team maintain and reference operational records.
Common evidence types:
- System logs (access, incident, backups)
- Training records and attendance
- Supplier risk assessments
- Internal audit checklists
Practical note:
- Internal auditors are intended to remain impartial (ISO/IEC 27001:2022 Clause 9.2). To meet the impartiality requirements of Clause 9.2, organisations may choose to engage an independent third party or a qualified staff member who is not involved in the area being audited.
- Teams may consider simple formats such as spreadsheets or centralised software to organise records.
4. Control Implementation Within Expertise
Internal implementation of technical controls is common in startups, as it allows team members with direct knowledge of the infrastructure to maintain context. Handling these internally may help maintain context and keep records aligned with the team’s understanding.
Example: Implementing multi-factor authentication or role-based access internally may sometimes be easier to manage internally than outsourcing, because your team understands the environment and dependencies.
Tip: For very complex setups, partial external guidance may complement internal expertise, but ownership and understanding remain internal.
5. Role-Based Mapping for SMEs
Defining who is responsible for which ISMS tasks helps small teams distribute effort without losing oversight.
Suggested roles:
- CEO / Founder: In many SMEs, the CEO or Founder typically assumes responsibility for risk ownership and management reviews (Clause 9.3). Chairs periodic reviews and sets risk appetite.
- CTO / Lead Developer: Technical controls and evidence collection, ensuring operational accuracy.
- Operations / HR: Policy awareness and training records, monitoring compliance among team members.
Practical note: In very small teams, roles may overlap. Clearly documenting who is responsible for each task helps prevent confusion and supports continuity.
Outsourcing for ISO 27001: When External Support May Help
For small teams, some ISO 27001 tasks can be complex, specialist, or time-consuming. Engaging external support strategically may be used alongside internal activities to manage workload and maintain oversight.
1. Specialist Assessments
Certain technical tasks often require skills that small teams may not have in-house:
- Penetration testing or vulnerability assessments – simulate attacks to find weaknesses.
- Cryptography reviews – validate encryption practices for data in transit and at rest.
- Business continuity simulations – test disaster recovery and operational resilience.
Tip: Even if a consultant performs the assessment, your internal team may review key findings to better understand identified risks and potential mitigation options.
2. External Audits and Certification
Some activities, such as certification audits, generally require accredited external auditors:
- Accredited external audits are generally used to assess whether an ISMS aligns with the Standard's requirements.
- Gap identification may provide insights for internal consideration.
Note: To support independence and impartiality, organisations often use different firms for ISO 27001 consultancy and certification audit.
Tip: Internal team members may attend or observe audit processes to become familiar with typical evidence and reporting formats.
3. Optional Documentation Support
Templates or consultant guidance can accelerate drafting policies and procedures:
- Policy templates for areas like access control, asset management, or incident response.
- Guidance for complex clauses or regulatory requirements.
Tip: Using templates does not replace internal understanding – teams may choose to tailor content to align actual practices.
4. Legal and Regulatory Reviews
Certain areas such as data protection or specific contractual obligations frequently involve legal considerations that are outside the scope of information security management. Organisations may consider consulting qualified legal counsel regarding specific statutory obligations.
Tip: While legal advisors can provide interpretations, internal staff may choose to track changes, approvals, and implementation of relevant recommendations.
5. Compliance Automation Platforms
Modern compliance software can serve as a middle ground between DIY and full outsourcing:
- Automate evidence collection for logs, training records, and audit trails.
- Track ISO 27001 activities with less manual effort.
- Conduct internal review of outputs may help confirm they accurately reflect the organisation’s processes.
Tip: Consider automation as a “middle ground” that may reduce routine workload while supporting internal oversight.
Maintenance vs Implementation
DIY efforts are often more manageable during initial implementation. Over time, teams may choose to use automation tools or virtual CISO (vCISO) services to support the ISMS maintenance phase. Ongoing maintenance typically involves evidence collection, internal reviews, supplier monitoring, and periodic updates to risks and controls as the organisation or threat landscape evolves.
Complexity vs Ownership Matrix
The matrix below illustrates how common ISO 27001 activities may vary in complexity and ownership for small and medium-sized organisations.
|
Task |
Complexity |
Ownership |
Notes |
|
Risk Assessment |
Medium |
Internal |
Templates may be used for efficiency |
|
Core Policies |
Low |
Internal |
Typically concise and practical |
|
Evidence Collection |
Medium |
Internal |
Logs, training records, audit evidence |
|
Internal Audit |
Medium |
Internal / External |
Use of an impartial auditor is commonly advised |
|
Technical Controls |
High |
Internal |
Typically managed by cloud or IT teams |
|
Specialist Testing |
High |
Outsourced |
Penetration testing, BCP simulations |
|
Certification Audit |
High |
Outsourced |
Conducted by an accredited certification body when certification is pursued |
|
Legal / Regulatory Review |
Medium |
Outsourced |
Data protection and contractual considerations |
Cost-Benefit Context
While a DIY approach can potentially reduce external consultancy fees, organisations should factor in the internal resource costs and the potential for longer implementation timelines. Selective outsourcing may allow small teams to focus internal effort on decision-making and oversight, while specialist activities – such as testing, certification, or legal review – may optionally be handled with additional external support. Teams may find that splitting tasks this way can help manage resources and maintain clarity on responsibilities.
Summary: Common Task Allocation in a Hybrid ISO 27001 Model
This article guides small teams on how to divide ISO 27001 tasks between internal management and external support to maintain effective ISMS oversight.
Typically Kept Internal (ISO 27001):
- Risk management and SoA mapping
- Core policies
- Evidence collection
- Controls within internal expertise
- Role-based responsibilities
Commonly Outsourced:
- Specialist assessments
- External audits and certification
- Legal and regulatory reviews
- Optional documentation support
For many SMEs and startups, a hybrid ISO 27001 approach may help balance internal control, resource considerations, and optional external assurance.
Next Step: Explore our ISO 27001 templates to support organisation of key policies, risk registers, and essential records in a practical, manageable way for your lean team.
Next Article: In ISO 27001 Incident Management Workflow: A Practical Template for SMEs, a step-by-step guide for SMEs on how to structure, document, and respond to information security incidents while maintaining oversight and traceability.
Related Guides
Explore these ISO 27001 resources to help your SME build a practical, lean ISMS:
Start Here: Complete Guide
-
ISO 27001 for SMEs and Startups: The Chill Implementation Guide (2026 Edition) – Full roadmap covering all clauses and Annex A controls, with practical steps, examples, and guidance.
Practical Checklists and Essential Documents – Detailed Guides by Topic
- ISO 27001 Without a Dedicated Compliance Team: What Small Teams Can Do – A pragmatic look at how startups can distribute security "hats" among existing staff and use templates to manage an ISMS without a full-time compliance hire.
- ISO 27001 Incident Management Workflow: A Practical Template for SMEs – Step-by-step guidance for small teams to handle security events, preserve records, and maintain a structured approach.
- Exploring Evidence Collection: A Perspective on ISO 27001 Annex A.5 for SMEs – Practical guidance for SMEs to capture digital, traceable evidence linking policies, roles, and operations for ISMS oversight.
-
Common ISO 27001 Audit Artefacts: Observations on SME Preparations – Practical guidance for SMEs to organise ISO 27001 audit artefacts and support traceable ISMS evidence.
Please Note: This article provides general information only and does not constitute legal, regulatory, or compliance advice. Using our products or following this guidance cannot guarantee certification, improved business outcomes, or regulatory compliance. Organisations remain responsible for ensuring all actions meet certification and compliance requirements.