ISO 27001 controls

Your suppliers carry part of your risk. Annex A asks you to manage that share on purpose.

Four controls in the organizational theme deal with the companies you buy from. Together they ask for a supplier policy, security terms in contracts, attention to the technology supply chain, and ongoing monitoring once the contract is signed. This page turns them into a working process: tiers, questions, clauses and the records an auditor will ask to see.

Back to ISO 27001 services

01 · The four controls

Four controls, one supplier lifecycle

Policy before purchase, terms at signature, watching after.

  1. 5.19
    Information security in supplier relationshipsDecide how you choose and manage suppliers so their access to your information does not become your weakest point.
  2. 5.20
    Addressing information security within supplier agreementsAgree the security duties of each supplier in writing, sized to what the supplier can reach.
  3. 5.21
    Managing information security in the ICT supply chainLook past the supplier to the software, hardware and sub-suppliers that sit behind it.
  4. 5.22
    Monitoring, review and change management of supplier servicesCheck over time that suppliers still meet what they agreed, and handle changes to their service.

Read together, the controls describe a lifecycle rather than a checklist. A supplier policy sets the rules. Due diligence applies them before purchase. The contract fixes them. Monitoring proves they still hold. An auditor follows one supplier through all four stages and expects each stage to leave a record.

The full list of organizational controls and how they group is on the Annex A organizational controls page. Here we stay with these four.

02 · Supplier tiers

Tier suppliers by what they can reach

Effort follows access, not contract value.

Treating every vendor the same wastes effort on the office coffee contract and starves the review of the provider that hosts customer data. A tier set by what a supplier can touch keeps the work proportionate, and it is the first thing an auditor uses to judge whether your process is sensible.

TierWhat the supplier can reachIllustrative exampleBefore signingAfter signing
CriticalHolds or processes customer or regulated data, or runs a service your product cannot work withoutCloud hosting, payment processor, managed security providerFull questionnaire, independent assurance report or certificate, contract security scheduleFormal review at a set interval, incident notice terms tested, exit plan kept current
HighHas standing access to internal systems or sensitive internal dataPayroll platform, outsourced developers, support desk toolShorter questionnaire, assurance report if one exists, security clausesReview at renewal and on any change in service
ModerateLimited data, no standing access to systemsSurvey tool with staff emails, design agencyBasic checks and standard termsConfirm at renewal that nothing has changed
LowNo access to information or systemsStationery, cateringNone beyond procurementNone

Write the tier rules into the supplier policy so the decision is repeatable. A supplier can move up a tier when you start sending it more data. That move should trigger the checks of the new tier.

03 · Due diligence

Questions worth asking before you sign

Fewer, sharper questions beat a long form nobody reads.

The questions below are a starting set for critical and high-tier suppliers. Each one is meant to produce an answer you can check, not a yes you have to take on trust.

  1. Which of our data will you store or see, in which countries, and on whose infrastructure?
  2. What independent assurance can you share, and does its scope cover the service we are buying?
  3. Which of your own suppliers will touch our data, and how will you tell us when that list changes?
  4. How do your staff get access to customer environments, and how is that access approved and removed?
  5. How soon will you tell us about an incident that affects our data, and through which contact?
  6. How do you back up the service, and when did you last test a restore?
  7. How will we get our data back, in what format, and how will you delete it when we leave?
  8. Who on your side owns security, and how do we reach them outside a sales conversation?

Reading an assurance report

A SOC 2 report or an ISO 27001 certificate from the supplier saves questions, but only if you read the scope. A certificate that covers a different product or site tells you little. Note what you checked and what you accepted.

04 · Contract terms

Security terms that belong in the agreement

Each clause should be testable later.

  • Scope of information. Which information the supplier may handle, and what it may and may not do with it.
  • Minimum safeguards. The baseline controls you expect, or a reference to a standard or report the supplier will keep current.
  • Incident notice. A duty to tell you about incidents affecting your information within an agreed window, through named contacts.
  • Sub-suppliers. Your right to know about, and object to or approve, sub-suppliers who will touch your information, with the same duties passed down.
  • Right to assurance. Your right to receive assurance reports, or to audit or assess, in proportion to the tier.
  • Change notice. Advance notice of changes to the service, its location or its security that could affect you.
  • Return and deletion. How data comes back at the end, and written confirmation that copies are deleted.
  • Confidentiality and staff. Confidentiality duties that bind the supplier's people, and screening where the role warrants it.

Large suppliers often refuse to change their paper. That is acceptable. Record what their standard terms already cover, note the gaps, and decide whether to accept the residual risk. The risk decision is the evidence, not a negotiated clause.

05 · Small vs large

Proportionate at either size

Same controls, different weight.

Small company

A list, a form and a calendar

  • One supplier register in a spreadsheet with tier, owner and data handled
  • Due diligence only for critical and high tiers, using a short question set
  • Accept large providers' standard terms with a written note of the gaps
  • A review of critical suppliers at a set interval, done by the security lead

Large company

A procurement workflow

  • Supplier risk built into procurement, so no purchase order issues without a tier
  • Questionnaires and evidence held in a third-party risk tool
  • Standard security schedule attached to every high and critical contract
  • Business owners attest to each supplier's use at review time; changes routed through change management

An auditor does not grade the tool. They test whether each stage happened for the suppliers they sample.

06 · Evidence

What an auditor samples, and where teams slip

One supplier, traced from register to review.

  • The supplier policy and the tier rules it sets
  • The supplier register, complete enough that the auditor's own list of paid vendors finds no surprise
  • For a sampled critical supplier: the due-diligence answers, the assurance report you reviewed and your notes on it
  • The signed agreement, with the security terms or the recorded risk decision where terms were missing
  • Records of the last review, including any changes the supplier announced and what you did about them
  • Register built from memory. The auditor compares it with accounts payable. Missing vendors suggest the process does not run.
  • Report filed, never read. A supplier's SOC 2 sitting in a folder, with no note of scope or exceptions, shows collection rather than review.
  • No exit thought. Critical suppliers with no plan for getting data back leave 5.20 half done.
  • Monitoring only at onboarding. 5.22 is about the life of the contract. A single check at the start does not meet it.
  • Ignoring the fourth party. The supplier's own hosting or subprocessors sit inside 5.21 and need at least a recorded look.

Sources: ISO/IEC 27001:2022 Annex A control names 5.19 to 5.22; ISO/IEC 27002:2022 as background on control purpose (not quoted); the ISO/IEC 27036 series on information security for supplier relationships, including its part on ICT supply chain security. Tiers, questions and clauses are our own illustration.

Supplier security questions

Do all suppliers need a security questionnaire?

No. Only the tiers your policy says.

The standard expects a risk-based approach. Most companies send questionnaires only to critical and high-tier suppliers and rely on procurement checks for the rest. What matters is that the rule is written down and followed.

Is a supplier's ISO 27001 certificate enough on its own?

Only if its scope covers the service you use.

A certificate is strong evidence when its scope includes the product, sites and teams that handle your data. Check the scope statement and the certificate's validity, and record that you did. Where the scope falls short, ask further questions.

What if a big cloud provider will not sign our clauses?

Record what their terms cover and accept the gap knowingly.

Map their standard agreement and published assurance against the terms you would want. Note the gaps, decide whether they matter, and record the risk acceptance with an owner. Auditors accept a reasoned decision far more readily than silence.

How does 5.21 differ from 5.19?

5.21 looks further down the chain.

5.19 is about your direct suppliers. 5.21 asks you to consider the technology supply chain behind them: the components, software and sub-suppliers that make up the service. In practice that means asking about subprocessors and the provenance of critical components.

Who should own supplier security?

A business owner per supplier, with security setting the rules.

Security usually writes the policy and runs reviews for high tiers. Each supplier still needs a business owner who knows what it is used for and can say when that use changes.

Know which suppliers carry your risk before an auditor asks.

An ISO 27001 gap analysis reviews your supplier register, contracts and monitoring against 5.19 to 5.22 and shows what is missing.