Compliance as a Service (CaaS)

If your ISO 27001 certificate covers all of your health and care data processing, the NHS Data Security and Protection Toolkit does two useful things with it. It marks the applicable evidence items as complete on its own, and it shrinks the scope of any independent audit to whatever your certification doesn’t already cover. A certified vendor who does the mapping properly walks into a DSPT submission with most of the technical and organizational evidence already written, already audited, and already versioned. What ISO 27001 won’t do is get you out of the DSPT. It says nothing about the NHS-specific information governance items, clinical safety, the national data opt-out, or Caldicott principles. Vendors who assume “certified means done” usually discover this in the last two weeks of June. This piece is for the founder, CTO, or ops lead at a UK health-tech company who owns compliance without being a compliance person. It covers what each framework asks for, which Annex A controls line up with which DSPT requirements, which evidence you can reuse as-is, which needs reframing around patient data, and a five-step workflow for turning an existing ISMS into a DSPT submission. One more thing on timing: NHS England published DSPT version 9 for the 2026/27 cycle on 4 September 2026, and the submission deadline is 30 June 2027. So this exercise belongs in your calendar now, not next spring. Understanding the Two Frameworks at a Glance​ What ISO 27001:2022 Covers ISO/IEC 27001:2022 is the international standard for an Information Security Management System (ISMS). It comes in two halves. Clauses 4 to 10 define the management system itself: context, leadership, risk assessment and treatment, resourcing, operation, performance evaluation, and continual improvement. Annex A lists 93 reference controls across four themes (organizational, people, physical, technological). Your Statement of Applicability (SoA) records which of those controls you apply, which you exclude, and why. An accredited certification body issues the certificate after a two-stage audit, then you keep it through annual surveillance audits and a three-year recertification cycle. The certificate covers a defined scope, and that scope statement is the first thing a DSPT assessor reads. What the NHS DSPT Requires in 2026/27 The Data Security and Protection Toolkit (DSPT) is NHS England’s annual online self-assessment for every organization that touches NHS patient data or systems. It’s a contractual requirement under the NHS Standard Contract. Your published status (“Standards Met”, “Standards Exceeded”, “Approaching Standards”, “Standards Not Met”) is publicly searchable, so procurement teams and prospective NHS customers do look it up. The Toolkit isn’t one assessment. NHS England tailors it by organization category, and your category decides which assertions you answer and whether you need an independent audit. Version 9 came out on 4 September 2026. The Category 1 view is aligned to CAF version 4.0, and the whole thing closes on 30 June 2027. Insider Note: Most health-tech SaaS vendors are Category 3, not Category 2. To be an IT Supplier you need all three things at once: digital goods or services to the NHS, 50 or more staff, and £10 million or more in turnover. Picking “IT Supplier” because you sell NHS-facing software, without hitting the size thresholds, lands you in a heavier evidence set and a mandatory audit you may not need. Check the category before you check anything else. Key Structural Differences Between ISO 27001 and DSPT Four differences matter when you’re trying to reuse evidence. What they’re about. ISO 27001 is an information security standard. The DSPT is an information governance standard that includes security. A good chunk of it deals with lawful basis, transparency, data subject rights, records management, and the SIRO and Caldicott Guardian roles. None of that is in Annex A. How you’re assured. ISO 27001 gets certified once and surveilled once a year by an accredited body. The DSPT starts from a blank submission every year, and Category 1 and 2 organizations get independently assessed every year too. How granular they are. Annex A controls read as objectives (“access rights shall be provisioned, reviewed, modified and removed”). DSPT evidence items read as things to upload (“a list of all systems that hold personal data, with the date of last review”). So the mapping runs many-to-one in both directions. Where they’re heading. Since 2024/25 NHS England has been moving the Toolkit onto the NCSC Cyber Assessment Framework (CAF). CAF is outcome-based: assessors score you Achieved, Partially Achieved, or Not Achieved against an NHS England profile, rather than accepting a policy upload as proof. Category 1 organizations are already there. Category 2 and 3 are still on assertions and evidence, but NHS England has said CAF alignment will reach more organization types over time. The Business Case for Reusing ISO 27001 Evidence in DSPT How Much of DSPT Can Realistically Be Satisfied by ISO 27001 Controls For a Category 2 or 3 vendor with a full-scope ISO 27001 certificate, expect 60 to 75 percent of the mandatory evidence items to come from ISMS artifacts, either automatically (where the Toolkit auto-completes them) or with some light reframing. The rest is NHS-specific governance and information governance content that ISO 27001 doesn’t touch. The NHS’s own guidance treats reuse as a scope question. The DSPT help pages say an ISO 27001 certification must cover all health and care data processing to receive the full exemption, and that a certificate scoped only to an IT department is good evidence for many of the IT questions but not all of them. If your certificate says “the SaaS platform hosted in AWS eu-west-2” and NHS data also passes through your support desk tooling, your analytics sandbox, and a contractor’s laptop, the auto-completion won’t apply. Your assessor will want to know how those flows are controlled. Time and Cost Savings for Health-Tech Vendors There’s no fee to submit the DSPT. The cost is internal time, plus, if you’re Category 2, the independent audit and the annual penetration test the mandatory assertions expect. Building a first DSPT submission from nothing usually takes

ISO/IEC 27001 certificates nearly doubled in a single year, from 48,671 in 2023 to 96,709 in 2024, according to ISO’s own certification survey. A big share of that jump comes from startups, not enterprises. The reason is simple: buyers stopped taking “we take security seriously” at face value, and a certificate is the fastest way to prove it.  This guide covers when a startup should pursue ISO 27001, what it costs, how long it takes, and how a small team gets certified without a dedicated security department. What Is ISO 27001 and Why It Matters for Startups ISO/IEC 27001 is the international standard for information security management. It doesn’t hand you a checklist of firewalls to buy. Instead, it asks you to build and run an Information Security Management System (ISMS): a documented, repeatable way of finding your security risks and doing something about them. Certification means an accredited third party checked that your ISMS works and matches the standard. For a startup, that distinction matters. You’re not being graded on whether you own expensive tools. You’re being graded on whether you can show a system, which is exactly what an enterprise buyer’s procurement team wants to see before they sign. The Core Principles: Confidentiality, Integrity, and Availability Everything in ISO 27001 traces back to the CIA triad: confidentiality, integrity, and availability. Confidentiality means only the right people see the data. Integrity means the data is accurate and hasn’t been tampered with. Availability means the data is there when someone needs it. Every control you put in place, and every risk you assess, ties back to protecting one of those three properties. ISO puts it plainly: an ISMS that meets the standard preserves the confidentiality, integrity, and availability of information by running a risk management process. Keep the triad in mind, and the rest of the framework stops feeling abstract. How ISO 27001 Differs from Other Security Frameworks for Early-Stage Companies SOC 2 is the framework startups usually bump into first, especially when selling into the US. It results in an attestation report from a CPA firm, scoped to specific systems. ISO 27001 is a certification, recognized in over 150 countries, and it covers your whole organization through a formal ISMS with management reviews and company-wide risk assessment. The two overlap heavily. Roughly 70 to 80 percent of the controls line up, so if you do one, the second gets much cheaper. The real difference is structure. SOC 2 checks whether specific controls work. ISO 27001 checks whether you’ve built a management system that keeps those controls working over time. It also aligns closely with GDPR, which is why it travels well in Europe. Insider Note: Auditors can usually tell within an hour whether your ISMS is real or was assembled the week before the audit. A management review meeting with actual notes, decisions, and follow-ups from three months ago is worth more than a perfect-looking policy binder with no evidence anyone ever used it. When Should a Startup Pursue ISO 27001 Certification? The honest answer: when a deal, a market, or an investor is asking for it, or is about to. Certifying purely because it feels responsible is a good way to burn cash and calendar time you don’t have yet. Early-Stage vs. Growth-Stage: Timing the Certification At pre-seed and seed, ISO 27001 is usually early unless you’re selling into regulated industries or the EU from day one. Your product and processes are still shifting, and certifying a moving target means re-documenting everything a quarter later. At Series A and beyond, the math changes. Deals get bigger, buyers get more careful, and investor due diligence starts probing your security posture. Certifying while you’re 15 to 40 people is often the sweet spot: mature enough to have stable processes, small enough that scoping the ISMS is still manageable. When ISO 27001 Might Be Overkill for Your Startup If your customers are US SMBs who only ever ask for SOC 2, leading with ISO 27001 may be solving a problem you don’t have. If you’re pre-revenue and still hunting for product-market fit, your time is better spent shipping. And if no one in your sales pipeline has ever mentioned a certificate, that silence is data. Pro Tip: Pull your Last 20 Security Questionnaires Before you commit, pull your last 20 security questionnaires or RFPs and count how many explicitly asked for ISO 27001 versus SOC 2 versus nothing. That single tally answers the “which framework, and when” question faster than any consultant’s discovery call. Key Benefits of ISO 27001 for Startups Unlocking Enterprise Sales and Bigger Deals The clearest return is revenue you couldn’t touch before. Large buyers often won’t even start a security review without a recognized certificate on file. ISO 27001 gets you past the first gate of enterprise sales, and it shortens the review itself because a big chunk of the questionnaire is already answered by your certification. Building Investor and Board Confidence Certification signals operational maturity. When an investor sees a functioning ISMS, they see a founder who can build systems, not only ship features. That plays well in investor due diligence, where a security gap can stall a term sheet, and it gives your board something concrete to point to on risk. Establishing Customer Trust from Day One A certificate is third-party proof, and third-party proof beats self-assurance every time. For a young company with no brand equity yet, it’s a shortcut to being taken seriously by customers who’ve never heard of you. Creating a Scalable Security Foundation Because ISO 27001 makes you build a system rather than a one-off fix, it scales as you grow. New hires, new products, and new data types slot into an ISMS you already run. You’re not rebuilding security from scratch at every stage. Reducing Long-Term Compliance Costs Adding SOC 2, HIPAA, or ISO 42001 later is far cheaper once an ISMS exists, thanks to that 70 to 80 percent control overlap. The first framework is the expensive one.

Two controls decide whether your ISO 27001 business continuity plan survives an audit: Annex A 5.29 and Annex A 5.30. One keeps your security controls working while everything else is failing. The other gets your systems back online before the damage becomes permanent. Plenty of teams write a continuity policy that satisfies neither in the way a certification auditor expects, and they discover the gap during the Stage 2 audit, when it is expensive to fix. This article covers what ISO 27001:2022 actually requires for business continuity, the components an auditor will ask to see, the step-by-step build, and the mistakes that turn a continuity plan into a non-conformity. What Is an ISO 27001 Business Continuity Plan? An ISO 27001 business continuity plan is the documented set of procedures that keeps information security effective and critical ICT services available during a disruption. It is not a generic “keep the lights on” binder. Under ISO 27001, the plan protects the confidentiality, integrity, and availability of information when normal operations break down: a ransomware event, a cloud outage, a data center failure, or a supplier collapse. The plan lives inside your Information Security Management System (ISMS). It draws on your risk assessment, your asset register, and your Business Impact Analysis (BIA), and it feeds your disaster recovery procedures. Scope is the part people get wrong. ISO 27001 cares about the information security aspects of continuity, not every operational hiccup a full business continuity program might cover.   Why You Need a Business Continuity Plan for ISO 27001 Compliance Downtime is expensive, and the bill arrives fast. For most organizations, the question is not whether a disruption will happen, but how quickly they recover when it does. There is also a hard compliance reason. You cannot certify to ISO 27001 while ignoring continuity. The standard requires you to maintain information security during disruption and to keep ICT able to support recovery, and an auditor will ask for the evidence. A continuity plan is where availability stops being a promise and becomes a tested capability. Let Axipro help you build a business continuity plan that’s practical, compliant, and audit-ready. Strengthen Your Business Continuity Strategy Schedule A Consultation ISO 27001 Requirements Related to Business Continuity Planning ISO/IEC 27001:2022 carries 93 Annex A controls across four categories: organizational, people, physical, and technological. Continuity sits in the organizational set, and two controls do the heavy lifting, supported by two more on the technical side. Annex A 5.29 – Information Security During Disruption A.5.29 requires you to maintain information security at an appropriate level when a disruption hits. The point is that security controls have a habit of degrading under pressure. People disable multi-factor authentication to “speed things up,” logging stops on a failover system, or access controls loosen while everyone scrambles. A.5.29 says the confidentiality and integrity of your information must be maintained even while availability is under threat. It is classed as both a preventive and a corrective control, meaning it should reduce the chance of an incident and also help resolve one already underway. Annex A 5.30 – ICT Readiness for Business Continuity A.5.30 is the technical engine. It requires that your ICT readiness is planned, implemented, maintained, and tested against business continuity objectives and ICT continuity requirements. In plain terms, your servers, networks, applications, and cloud services need a defined recovery path, each with a Recovery Time Objective (RTO) and Recovery Point Objective (RPO), and you need to prove the path works. This control is entirely new in the 2022 revision. It has no precedent in ISO 27001:2013, which is exactly why teams migrating from the older version so often have a gap here. Important: A.5.30 did not exist in ISO 27001:2013. If your continuity documentation was written against the old Annex A 17 cluster and never updated, you are missing a control the auditor will specifically test. Treat ICT readiness as a fresh requirement, not a relabel. Two technological controls back these up. Annex A 8.13 (Information Backup) requires backups to be taken and tested in line with an agreed policy, and Annex A 8.14 (Redundancy of Information Processing Facilities) covers the failover and redundancy that let critical systems keep running when a component dies. Relationship Between ISO 27001 and ISO 22301 This is where confusion is common. ISO 27001 requires the information security aspects of continuity. ISO 22301 is the dedicated standard for a full Business Continuity Management System (BCMS), covering people, facilities, supply chain, and operations far beyond information security. An ISO 27001 certificate does not certify your wider continuity program. The good news: both standards share the Annex SL high-level structure, so risk assessment, internal audit, management review, and document control carry across. Teams that already run ISO 27001 can layer ISO 22301 on top with far less effort than starting from scratch. Key Components of an ISO 27001 Business Continuity Plan Business Impact Analysis (BIA) The BIA is the foundation. It identifies your critical business processes, the ICT systems they depend on, and the cost of losing each one over time. It is where your recovery objectives come from, not from a vendor datasheet. A BIA also sets the Maximum Tolerable Period of Disruption (MTPD): the point beyond which an activity’s failure causes unacceptable damage. Risk and Disruption Scenario Assessment Your risk assessment identifies what could cause a disruption and how likely it is, feeding the Risk Treatment Plan and the Statement of Applicability (SoA) that records which controls apply. Continuity planning then runs concrete scenarios: ransomware, a regional outage, a key supplier failure, the loss of a data center. Response and Recovery Strategies For each critical system, you define how you will respond and recover: failover to a secondary site, restore from backup, or switch to a manual workaround. This links incident response to crisis management, the executive-level decision-making that kicks in when an incident escalates beyond a routine fix. Roles and Responsibilities Name real people, not departments. “IT will handle it” is the single most common