Illustrative Guide to Common ISO 27001 Risks for SMEs

Minimalist illustration of SMEs and startups managing ISO 27001 risks with a risk register, likelihood-impact scoring, and cloud-based data flows.

Why SMEs Benefit from Tracking Common Risks

ISO 27001 risk management may assist SMEs and startups in considering potential risks in a structured way. Smaller teams often operate with limited IT resources, lean infrastructure, and reliance on cloud or third-party services, which may increase exposure to operational and cyber risks.

Awareness of commonly observed ISO 27001 risks may provide guidance for teams considering likelihood, impact, and structured risk recordkeeping. This article presents illustrative examples intended to inform practical risk scoring and structured risk management approaches aligned with ISO 27001 principles.

ISO 27001 Risk Scoring for SMEs: Likelihood and Impact Explained

A minimalist vector illustration of a 3x3 risk matrix (Low, Medium, High) where a small team is placing a 'Risk' marker, illustrating how likelihood and impact combine to determine a risk level.

SMEs and startups often use simple, repeatable scoring approaches to compare risks consistently across different systems, processes, and suppliers. Considering both likelihood and impact may assist organisations in prioritising risk treatment activities, allocating resources pragmatically, and maintaining structured ISO 27001 risk records.

Likelihood

Illustrative Example:

Likelihood

Description

Low

Rare occurrence; minimal operational impact anticipated

Medium

Possible occurrence; may result in moderate operational or financial impact

High

Likely occurrence; could lead to significant operational, reputational, contractual, or financial impact

Impact

Illustrative Example:

Impact

Description

Low

Minor disruption; typically manageable

Medium

Noticeable disruption; potential data loss or downtime

High

Severe disruption; may in some circumstances contribute to regulatory, contractual, or financial consequences

Risk Level Example:

Risk Level = Likelihood × Impact

  • Medium Likelihood × High Impact = Medium-High Risk
  • High Likelihood × High Impact = Critical Risk

Tip: These scores are commonly applied consistently across systems, processes, and suppliers to support relative risk prioritisation and maintain well-documented risk records.

Exploring Common SME Risks and Illustrative Examples

Below are seven frequently observed ISO 27001 risks for small and medium-sized organisations. Each includes an illustrative example, indicative likelihood and impact levels, and practical mitigation considerations with aligned Annex A control references.

1. Data Breaches and Unauthorised Data Access

Data breaches and unauthorised access are commonly observed ISO 27001 risks for SMEs, particularly where teams operate with limited security resources or distributed working arrangements.

Example Scenario: Unauthorised access to customer or employee information could occur due to phishing attempts, weak authentication practices, or misconfigured cloud storage repositories.

Likelihood: Medium

Impact: High

Mitigation Considerations:

Organisations may consider approaches such as:

  • Consider implementing multi-factor authentication
  • Conduct periodic access reviews
  • Provide staff information security awareness training
  • Apply cloud service governance and configuration management practices

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.8.5 – Secure authentication

Risk reduction support: May reduce risks associated with weak authentication when multi-factor authentication is applied.

A.8.3 – Information access restriction

Supports access control mechanisms by limiting data access to authorised users.

A.5.23 – Information security for use of cloud services

Risk reduction support: Supports structured management of cloud services, reducing exposure from misconfigured storage.

A.5.18 – Access rights

Risk reduction support: Supports access reviews and management of access rights in line with defined access principles.

A.6.3 – Information security awareness, education and training

Risk reduction support: Supports staff awareness and training to reduce phishing-related and human-error risks.

A.8.9 – Configuration management

Supporting mitigation: Supports the application of secure configuration practices for systems and services.

2. Human Error and Process Gaps

A vector illustration showing a remote worker making a data handling error, such as incorrect file sharing, highlighting the ISO 27001 risk of human error in distributed SME teams.

Routine mistakes in data handling are commonly observed risks for SMEs, particularly where workflows rely on manual steps, small teams, or informal processes.

Example Scenario: Accidental deletion of client information, mislabelled documents, incorrect file sharing, or incomplete backup routines.

Likelihood: High

Impact: Medium-High (Regulatory obligations may increase the potential impact where personal data is involved)

Mitigation Considerations:

Organisations may consider approaches such as:

  • Consider documenting operating procedures
  • Maintain consistent version control practices
  • Provide staff information security awareness training
  • Use automated or scheduled backup processes
  • Apply structured asset and information management practices

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.5.10 – Acceptable use of information and other associated assets

Scope of control: Supports defining acceptable use expectations for information and associated assets.

A.5.37 – Documented operating procedures

Supports risk management by providing a documented reference for routine activities and processes.

A.6.3 – Information security awareness, education and training

Risk reduction support: May assist in reducing the likelihood of human error through ongoing awareness and training.

A.8.13 – Information backup

Supports risk management by providing recovery options following accidental deletion or data loss.

A.5.12 – Classification of information

Supporting control: Supports consistent handling of information based on sensitivity and classification.

A.5.36 – Compliance with policies, rules and standards for information security

Process support: Supports monitoring alignment with documented policies and procedures.

3. Device Loss or Theft

A minimalist illustration of a stylised laptop left on a coffee shop table with a question mark above it, representing the common ISO 27001 risk of device loss or theft for mobile SME workforces.

Device loss or theft may pose risks for SMEs, particularly where personnel use laptops, mobile phones, or tablets outside a secure office environment. Devices that are lost or stolen may expose sensitive or business-critical information if protective measures are limited.

Example Scenario: A company laptop or mobile device containing confidential client or employee information is misplaced or stolen while used off-premises.

Likelihood: Medium

Impact: Medium-High

Mitigation Considerations:

Organisations may consider approaches such as:

  • Consider applying encryption to devices that store sensitive information
  • Use authentication mechanisms such as passwords or multi-factor authentication
  • Define and communicate Bring Your Own Device (BYOD) security expectations
  • Use mobile device management (MDM) solutions where appropriate
  • Maintain regular information backup processes
  • Record and review device access and usage logs

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.7.9 – Security of assets off-premises

Scope of control: Supports consideration of security measures for devices used outside organisational premises.

A.8.1 – User end point devices

Supports risk management by covering technical measures such as device security configuration and malware protection.

A.6.7 – Remote working

Supporting control: Provides guidance for managing information security risks associated with remote device use.

A.8.24 – Use of cryptography

Risk reduction support: Supports the use of encryption to limit data exposure following device loss or theft.

A.8.13 – Information backup

Supports data recovery options where information stored on lost or stolen devices cannot be accessed.

A.8.15 – Logging

Detection support: Supports recording and review of activity related to device usage.

A.5.17 – Authentication information

Supporting control: Supports management of authentication information for accessing devices and systems.

4. Supplier or Cloud Service Failure

Supplier and cloud service dependencies may introduce information security and operational risks for SMEs, particularly where business processes, data storage, or customer-facing services rely on external providers. Service disruptions or security weaknesses at the supplier level could affect data availability, confidentiality, or business continuity.

Example Scenario: A cloud-based SaaS platform experiences an outage that limits access to operational data, or a third-party service provider handles confidential client information in a way that increases exposure risk.

Likelihood: Medium

Impact: Medium-High

Mitigation Considerations:

Organisations may consider a combination of governance, contractual, and operational measures, such as:

  • Performing periodic supplier and cloud service risk assessments
  • Defining information security expectations within supplier agreements
  • Establishing contingency or business continuity arrangements for critical services
  • Reviewing supplier performance, service changes, and security posture over time

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.5.19 – Information security in supplier relationships

Provides a foundation for identifying and managing information security risks associated with third-party suppliers.

A.5.20 – Addressing information security within supplier agreements

May support the inclusion of information security considerations within contractual arrangements.

A.5.22 – Monitoring, review and change management of supplier services

Supports ongoing oversight of supplier services and changes that could affect security or availability.

A.5.23 – Information security for use of cloud services

Can assist with managing risks related to cloud service adoption and operation.

A.5.29 – Information security during disruption

Supports planning and response activities during service interruptions or supplier-related incidents.

A.5.31 – Legal, statutory, regulatory and contractual requirements

Helps align supplier arrangements with applicable legal and contractual obligations.

5. System Downtime and Technical Failures

System downtime and technical failures may pose operational and information security risks for SMEs, particularly where digital services, internal systems, or customer-facing platforms are critical to daily operations. Software defects, infrastructure issues, or unaddressed technical vulnerabilities may affect service availability, data protection, and organisational resilience.

Example Scenario: A website or cloud service becomes unavailable due to a server failure, software error, or delayed security patch, may in some circumstances contribute to service disruption or data exposure risks.

Likelihood: Medium

Impact: High

Mitigation Considerations: 

Organisations may consider a combination of preventive and response-focused measures, such as:

  • Applying system updates and security patches on a planned and prioritised basis
  • Using monitoring and alerting mechanisms to identify outages or abnormal behaviour
  • Establishing incident response processes for handling technical failures
  • Aligning business continuity and disaster recovery arrangements with system dependencies

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.8.14 – Redundancy of information processing facilities

May support the use of failover or redundancy measures to reduce the impact of system unavailability.

A.8.13 – Information backup

Can assist with restoring data and systems following technical failure or system crashes.

A.8.16 – Monitoring activities

Supports early detection of outages, anomalies, or technical issues through monitoring and alerting.

A.8.8 – Management of technical vulnerabilities

Helps organisations identify and address known vulnerabilities that could contribute to system failures.

A.8.32 – Change management

Supports structured planning and testing of system changes or patches to reduce unintended disruptions.

A.5.29 – Information security during disruption

Provides guidance for maintaining security controls and operations during periods of system downtime.

A.5.31 – Legal, statutory, regulatory and contractual requirements

May assist organisations in considering availability and resilience obligations arising from legal or contractual requirements. 

6. Regulatory and Legal Noncompliance

SMEs may underestimate information security risks associated with privacy, data protection, or contractual obligations. Noncompliance may result in financial penalties, reputational impact, or disruptions to business operations.

Example Scenario: Accidental mishandling of personal data, failure to meet local privacy requirements, or overlooking regulatory reporting obligations could increase organisational exposure.

Likelihood: Medium-Low

Impact: High

Mitigation Considerations:

Organisations may consider approaches such as:

  • Tracking applicable compliance obligations over time
  • Developing policies that align with relevant laws and regulations
  • Conducting periodic legal and internal reviews of practices and processes
  • Maintaining records of compliance activities within the ISMS and Statement of Applicability

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.5.31 – Legal, statutory, regulatory and contractual requirements

May support documentation and ongoing monitoring of applicable legal and contractual obligations.

A.5.34 – Privacy and protection of personal identifiable information (PII)

Can assist in addressing risks related to personal data handling and privacy compliance.

A.5.36 – Compliance with policies, rules and standards for information security

May help organisations monitor and verify that procedures meet legal and contractual expectations.

A.5.35 – Independent review of information security

Supports periodic reviews of internal controls and legal compliance practices.

7. Insider Threats and Privilege Misuse

Negligent or unauthorised insider actions may present risks to SMEs, often arising from accidental misuse or mismanagement of access rights. Such actions can potentially affect data confidentiality, operational integrity, and organisational reputation.

Example Scenario: Employees store company files on personal devices, misconfigure access permissions, or inadvertently share sensitive information.

Likelihood: Medium

Impact: High

Mitigation Considerations: 

Organisations may consider approaches such as:

  • Implementing or reviewing role-based access control policies
  • Conducting periodic access audits and monitoring user activity
  • Applying segregation of duties for critical systems
  • Providing staff awareness and training on privileged access management

Suggested Relevant Annex A Controls (ISO/IEC 27001:2022):

Reference Control

Illustrative Contribution for Consideration

A.5.18 – Access rights

May support the management of access rights, including provisioning, reviewing, and removing privileges according to least privilege principles.

A.8.2 – Privileged access rights

Can assist with managing privileged access rights to reduce potential misuse.

A.8.3 – Information access restriction

Supports limiting access to information and assets, reinforcing role-based control.

A.8.16 – Monitoring activities

May help detect abnormal or suspicious actions (e.g. bulk file downloads) for early awareness.

A.5.3 – Segregation of duties

Can assist in preventing control conflicts and mitigating deliberate misuse or fraud risks.

A.6.3 – Information security awareness, education and training

May reduce accidental insider errors through awareness and training initiatives.

A.6.7 – Remote working

Supports secure handling of company files off-premises and can reduce device-related misuse risks.

The Final Step: Risk Treatment Options

After assessing risks, SMEs may consider how to treat them, weighing factors such as cost, practicality, and residual risk. Selecting a treatment approach is one way organisations may consider addressing potential impacts and maintain structured risk documentation.

A flow diagram illustration of an SME team facing a risk and choosing between four pathways: Mitigate, Accept, Transfer, or Avoid, representing the ISO 27001 risk treatment process.

Illustrative Treatment Options:

  1. Mitigate: May reduce the likelihood or impact of a risk by applying controls. Common for higher-impact risks. Examples include multi-factor authentication, staff security awareness training, or automated backups.
  2. Accept: May document a decision to tolerate the risk when it is low or when mitigation costs may outweigh potential losses; may involve management review.
  3. Transfer: May shift the risk to a third party, for example through insurance policies or contractual arrangements with cloud providers that follow high-security practices.
  4. Avoid: May refrain from activities that generate the risk, such as not handling sensitive data from certain jurisdictions.

Practical Tip: Organisations may record each treatment decision in their Risk Register. The selected controls may also be referenced in the Statement of Applicability (SoA) to support structured risk management and traceability.

Key Takeaways for SMEs

  • Organisations may consider approaches to managing ISO 27001 risks in an SME environment using structured methods.
  • Likelihood × impact scoring may be applied consistently to help prioritise risks.
  • Focus may be placed on frequently observed SME risks, such as human error, device loss, or supplier failures.
  • Organisations may consider linking each risk to relevant Annex A:2022 controls and assigning clear owners.
  • When selecting a risk treatment approach – treat, accept, transfer, or avoid – organisations may record each decision in their Risk Register.
  • Documented controls may be referenced in the Statement of Applicability (SoA) to support structured traceability and ongoing review.

Next Steps: Explore ready-to-use ISO 27001 templates designed to support consideration of an ISMS framework, depending on organisational context.

Next Article: In How to Implement ISO 27001 With a Small Team: Guide for SMEs and Startups, we break down practical steps for SMEs to build an effective ISMS, manage key risks, and link controls to Annex A:2022 requirements.

Related Guides

Explore these ISO 27001 resources to help your SME build a practical, lean ISMS:

Start Here: Complete Guide

C. Risk, Statement of Applicability, and Annex A Controls – Detailed Guides by Topic

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.