policy SME

Outsourced Development Policy - SME

Ensure secure and compliant outsourced software development for SMEs with robust controls, clear ownership, and vendor oversight. ISO 27001:2022 aligned.

Overview

This SME-focused Outsourced Development Policy sets clear requirements for secure, contract-controlled software development by third parties. It covers contract obligations, secure coding, asset ownership, and post-project offboarding, ensuring regulatory compliance and risk mitigation even in organizations without dedicated IT or security teams.

SME-Focused Security

Tailored for SMEs without dedicated IT teams, ensuring robust controls and compliance in outsourced development.

Clear Ownership

Mandates contractual clarity on asset ownership and full rights over deliverables and documentation.

Compliant & Auditable

Supports ISO 27001:2022 certification and maintains records for audits, legal, and regulatory needs.

Enforced Secure Practices

Requires secure coding, proper vetting of third-party components, and post-delivery testing.

Read Full Overview
This Outsourced Development Policy (document number P28S) is specifically designed for small and medium-sized enterprises (SMEs), providing a pragmatic framework for secure, compliant, and well-managed outsourced software development. It is fully aligned with ISO/IEC 27001:2022, ensuring that even organizations lacking dedicated IT or security teams can adhere to international best practices and legal obligations when engaging external developers, freelancers, or third-party agencies. The policy establishes clear roles and responsibilities for the General Manager (GM), who serves as the principal authority for vendor approval, contractual oversight, and remediation actions, and the Project Owner, who is tasked with day-to-day coordination, functional validation, and secure handover. By emphasizing the need for enforceable contracts, confidentiality agreements, and documented agreements on asset ownership and rights transfer, the policy protects organizations from risks such as insecure code, improper reuse of proprietary assets, data exposure, supplier lock-in, and non-compliance with regulations (including GDPR, NIS2, and DORA). Mandatory governance controls are set forth, requiring contracts to specify secure development obligations, regular risk assessments by the GM, and proper management of all system credentials and access. Security expectations cover developer obligations to use secure coding techniques (referencing standards like OWASP Top 10), thorough documentation, careful library selection, and a strict prohibition on retaining access or corporate data after project closure. Comprehensive procedures ensure that every outsourced project is preceded by due-diligence screening, validated through functional and security testing (preferably by someone other than the developer), and concluded only after complete delivery of source code, build instructions, and transfer of all credentials. The policy is SME-specific, using simplified roles such as General Manager and Project Owner in place of traditional CISO or SOC positions. This means it provides step-by-step instructions executable by business or operations managers, and includes risk assessment procedures, exception tracking, and incident response guidance tuned for organizations lacking extensive technical resources. Every engagement must be backed by documented agreements, and auditable trails are mandatory, supporting regulatory reporting and internal reviews. Annual and interim policy reviews must be conducted by the GM, ensuring the controls remain current with SME-facing risks and evolving compliance standards. The Outsourced Development Policy is part of a suite of SME-oriented controls, intended to be implemented in conjunction with related policies, such as governance roles, access control, security awareness, data protection, secure development, and incident response, to manage outsourced development risks holistically, complying with standards like ISO/IEC 27001:2022, ISO 27002:2022, GDPR, and more.

Policy Diagram

Diagram illustrating the SME outsourced development workflow—from contract and access approval, secure coding and delivery, to mandated handover, offboarding, and audit records.

Click diagram to view full size

What's Inside

Scope and Rules for External Development

Mandatory Contracts and NDA Clauses

Secure Coding and Testing Requirements

Access and Credential Management

Ownership, Handover, and Offboarding

Exception and Incident Response Processes

Framework Compliance

🛡️ Supported Standards & Frameworks

This product is aligned with the following compliance frameworks, with detailed clause and control mappings.

Framework Covered Clauses / Controls
ISO/IEC 27001:2022
ISO/IEC 27002:2022
NIST SP 800-53 Rev.5
EU GDPR
Article 28
EU NIS2
EU DORA
COBIT 2019

Related Policies

Governance Roles And Responsibilities Policy-SME

Clarifies who is responsible for vendor approval, access control, and risk acceptance when using outsourced developers.

Access Control Policy SME

Defines the proper creation, restriction, and termination of user accounts and admin access used during outsourced development.

Information Security Awareness And Training Policy SME

Ensures internal staff understand how to coordinate securely with external developers, including handling credentials and project files.

Data Protection And Privacy Policy SME

Establishes security and legal requirements for handling personal data that may be processed by outsourced developers under GDPR.

Secure Development Policy SME

Specifies how internal and external development must follow secure coding practices and vetting of libraries and frameworks.

Incident Response Policy SME

Required when outsourced development leads to security incidents or vulnerabilities, guiding coordinated investigation and remediation.

About Clarysec Policies - Outsourced Development Policy - SME

Generic security policies are often built for large corporations, leaving small businesses struggling to apply complex rules and undefined roles. This policy is different. Our SME policies are designed from the ground up for practical implementation in organizations without dedicated security teams. We assign responsibilities to the roles you actually have, like the General Manager and your IT Provider, not an army of specialists you don't. Every requirement is broken down into a uniquely numbered clause (e.g., 5.2.1, 5.2.2). This turns the policy into a clear, step-by-step checklist, making it easy to implement, audit, and customize without rewriting entire sections.

Simple, Role-Based Oversight

Assigns oversight and approval to actual SME roles, like GM and IT Provider, for practical day-to-day control and accountability.

Handover & Offboarding Checklist

Requires signed delivery checklists, code transfer, and proof of data deletion for secure project closure and minimal residual risk.

Frequently Asked Questions

Built for Leaders, By Leaders

This policy was authored by a security leader with 25+ years of experience deploying and auditing ISMS frameworks for global enterprises. It's designed not just to be a document, but a defensible framework that stands up to auditor scrutiny.

Authored by an expert holding:

MSc Cyber Security, Royal Holloway UoL CISM CISA ISO 27001:2022 Lead Auditor & Implementer CEH

Coverage & Topics

🏢 Target Departments

IT Security Compliance Legal Procurement

🏷️ Topic Coverage

Outsourced Development Secure Development Lifecycle Security Testing Compliance Management Supplier Management
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Outsourced Development Policy - SME

Product Details

Type: policy
Category: SME
Standards: 7