Statement of Applicability - botBrains Docs

botBrains is not yet ISO 27001 certified. We are preparing our ISMS and writing these policies as part of pursuing certification, and we fully intend to get our controls attested.

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The Statement of Applicability (SoA) records how botBrains applies each of the 93 ISO/IEC 27001:2022 Annex A controls: whether the control is in scope, which policy governs it, and its implementation status. It’s the index that ties the policies to the controls they satisfy.

How to read this

Applicable. Whether the control is in scope. The only exclusion is outsourced development, which botBrains doesn’t do.
Implemented. Yes (operating), Inherited (operated by a certified provider), Partial; … (in place, with the action that finishes it), or No; … (applicable, with the action that starts it).
Policy. The governing policy, with the specifics that add detail.

A.5 Organizational controls

Annex A	Control	Applicable	Implemented	Policy
5.1	Policies for information security	Yes	Yes	Information Security
5.2	Information security roles and responsibilities	Yes	Yes	Roles & Responsibilities (CISO named; co-founder alternate)
5.3	Segregation of duties	Yes	No	Roles & Responsibilities (documented compensating controls, accepted risk)
5.4	Management responsibilities	Yes	Yes	Information Security; Code of Conduct
5.5	Contact with authorities	Yes	Yes	Incident Management (see internal communication plan)
5.6	Contact with special interest groups	Yes	Yes	BITS via Slack, SIEM reads NVD, GitHub advisories
5.7	Threat intelligence	Yes	Yes	Vulnerability Management; Responsible Disclosure (Dependabot advisories, disclosure inputs, SIEM)
5.8	Information security in project management	Yes	Yes	Secure Development See design stage
5.9	Inventory of information and associated assets	Yes	Yes	Asset Management
5.10	Acceptable use of information and assets	Yes	Yes	Acceptable Use
5.11	Return of assets	Yes	Yes	Asset Management; HR Security (leaver process, laptop return)
5.12	Classification of information	Yes	Yes	Data Classification (four-level scheme)
5.13	Labelling of information	Yes	Yes	Data Classification (context-based labelling)
5.14	Information transfer	Yes	Yes	Data Classification; Cryptography (transfer rules by level; TLS 1.3, min 1.2)
5.15	Access control	Yes	Yes	Access Control (least privilege, RBAC)
5.16	Identity management	Yes	Yes	Access Control (unique named accounts)
5.17	Authentication information	Yes	Yes	Access Control (MFA, password manager, Clerk)
5.18	Access rights	Yes	Yes	Access Control (joiner-mover-leaver, access reviews)
5.19	Information security in supplier relationships	Yes	Yes	Supplier Management (supplier due diligence)
5.20	Addressing security within supplier agreements	Yes	Yes	Supplier Management (Art. 28 DPAs on file)
5.21	Managing security in the ICT supply chain	Yes	Yes	Supplier Management (model-subprocessor rules)
5.22	Monitoring, review and change of supplier services	Yes	Yes	Supplier Management (annual supplier review defined)
5.23	Information security for use of cloud services	Yes	Yes	Supplier Management (EU cloud, DPAs, residency rules)
5.24	Incident management planning and preparation	Yes	Yes	Incident Management (incident lifecycle defined)
5.25	Assessment and decision on security events	Yes	Yes	Incident Management (triage and severity)
5.26	Response to information security incidents	Yes	Yes	Incident Management; Breach Notification
5.27	Learning from information security incidents	Yes	Yes	Incident Management (root-cause analysis)
5.28	Collection of evidence	Yes	Yes	Incident Management (evidence preservation)
5.29	Information security during disruption	Yes	Yes	Business Continuity & DR
5.30	ICT readiness for business continuity	Yes	Yes	Business Continuity & DR; Backup (RTO/RPO, backups, failover)
5.31	Legal, statutory, regulatory and contractual requirements	Yes	Yes	Data Protection (GDPR met; Article 30 Record of Processing Activities)
5.32	Intellectual property rights	Yes	Yes	Code of Conduct; Acceptable Use
5.33	Protection of records	Yes	Yes	Data Retention (retention and protection of records)
5.34	Privacy and protection of PII	Yes	Yes	Data Protection (GDPR processor controls; Article 30 Record of Processing Activities)
5.35	Independent review of information security	Yes	Yes	Internal Audit Programme (employees only)
5.36	Compliance with policies, rules and standards	Yes	Yes	Information Security (enforcement clauses)
5.37	Documented operating procedures	Yes	Yes	Operations Security

A.6 People controls

Annex A	Control	Applicable	Implemented	Policy
6.1	Screening	Yes	Yes	HR Security (proportional checks defined)
6.2	Terms and conditions of employment	Yes	Yes	HR Security (contracts with confidentiality terms)
6.3	Information security awareness, education and training	Yes	Partial	HR Security
6.4	Disciplinary process	Yes	Yes	HR Security
6.5	Responsibilities after termination or change	Yes	Yes	HR Security (offboarding, continuing confidentiality)
6.6	Confidentiality or non-disclosure agreements	Yes	Yes	HR Security (required before access)
6.7	Remote working	Yes	Yes	Acceptable Use; Physical Security (fully remote; home-office controls)
6.8	Information security event reporting	Yes	Yes	Incident Management; Responsible Disclosure

A.7 Physical controls

Annex A	Control	Applicable	Implemented	Policy
7.1	Physical security perimeters	Yes	Inherited	Physical Security (certified data centers)
7.2	Physical entry	Yes	Inherited	Physical Security (provider access control)
7.3	Securing offices, rooms and facilities	Yes	Inherited	Physical Security (no own offices; home-office)
7.4	Physical security monitoring	Yes	Inherited	Physical Security (provider surveillance)
7.5	Protecting against physical and environmental threats	Yes	Inherited	Physical Security (provider fire, power, and climate controls)
7.6	Working in secure areas	Yes	Inherited	Physical Security (data center secure areas)
7.7	Clear desk and clear screen	Yes	Yes	Physical Security; Acceptable Use (idle lock, clean-screen practice)
7.8	Equipment siting and protection	Yes	Yes	Physical Security (devices in trusted locations; servers inherited)
7.9	Security of assets off-premises	Yes	Yes	Physical Security; Asset Management (full-disk-encrypted laptops, device care)
7.10	Storage media	Yes	Yes	Asset Management; Data Classification (no removable media for production data)
7.11	Supporting utilities	Yes	Inherited	Physical Security (data center power and cooling)
7.12	Cabling security	Yes	Inherited	Physical Security (data center cabling)
7.13	Equipment maintenance	Yes	Inherited	Physical Security (cloud provider maintenance)
7.14	Secure disposal or re-use of equipment	Yes	Yes	Asset Management (laptop wipe with full-disk encryption; providers destroy server media)

A.8 Technological controls

Annex A	Control	Applicable	Implemented	Policy
8.1	User endpoint devices	Yes	Yes, no MDM	Acceptable Use (full-disk encryption, MFA, updates)
8.2	Privileged access rights	Yes	Yes	Access Control (minimal admin access with MFA)
8.3	Information access restriction	Yes	Yes	Access Control (multi-tenant logical isolation)
8.4	Access to source code	Yes	Yes	Secure Development (private GitHub, role-based, MFA)
8.5	Secure authentication	Yes	Yes	Access Control (MFA everywhere; Clerk for the product)
8.6	Capacity management	Yes	Yes	Operations Security (CloudWatch and Better Stack monitoring)
8.7	Protection against malware	Yes	Yes	Operations Security (ClamAV on uploads, hardened servers)
8.8	Management of technical vulnerabilities	Yes	Yes	Vulnerability Management (Dependabot, Wazuh)
8.9	Configuration management	Yes	Yes	Operations Security; Network Security (hardened, version-controlled infrastructure as code)
8.10	Information deletion	Yes	Yes	Data Retention (retention and secure deletion)
8.11	Data masking	Yes	Yes	Data Classification; Data Protection (tenant isolation, pseudonymization)
8.12	Data leakage prevention	Yes	Yes	Data Classification; Acceptable Use (access controls and acceptable use), external sharing warnings in Gmail/Calendar/Meets, Secure Communication Guidelines, DNS Malware filtering via 1.1.1.2, no network level warnings
8.13	Information backup	Yes	Yes	Backup (Point-in-Time Recovery with Write-Ahead Log, tested restore)
8.14	Redundancy of information processing facilities	Yes	Yes	Business Continuity & DR (hot standby, reproducible-from-code recovery, multi-provider model inference)
8.15	Logging	Yes	Yes	Logging & Monitoring (centralized logs, Wazuh, Better Stack)
8.16	Monitoring activities	Yes	Yes	Logging & Monitoring (Wazuh SIEM, Sentry alerting)
8.17	Clock synchronization	Yes	Yes	Logging & Monitoring; Operations Security (synchronized to network time)
8.18	Use of privileged utility programs	Yes	Yes	Access Control; Operations Security (restricted admin tooling)
8.19	Installation of software on operational systems	Yes	Yes	Operations Security (change management, hardened images)
8.20	Networks security	Yes	Yes	Network Security (provider security groups, MFA, company VPN for production server access)
8.21	Security of network services	Yes	Yes	Network Security (private-network isolation or TLS 1.3 for service-to-service)
8.22	Segregation of networks	Yes	Yes	Network Security (environment and tenant segmentation)
8.23	Web filtering	Yes	No	Network Security (spam and virus filtering)
8.24	Use of cryptography	Yes	Yes	Cryptography (AES-256, TLS 1.3 min 1.2, provider-managed keys)
8.25	Secure development life cycle	Yes	Yes	Secure Development
8.26	Application security requirements	Yes	Yes	Secure Development (security requirements per change)
8.27	Secure system architecture and engineering principles	Yes	Yes	Secure Development (least privilege, defence in depth)
8.28	Secure coding	Yes	Yes	Secure Development; Employees Only: Secure Coding Standards (OWASP-aligned coding rules, automated checks, review gates)
8.29	Security testing in development and acceptance	Yes	Yes	Secure Development (CI tests, dependency scanning)
8.30	Outsourced development	No	N/A	No outsourced development; all code written in-house
8.31	Separation of development, test and production environments	Yes	Yes	Operations Security; Secure Development (separate local, staging, production)
8.32	Change management	Yes	Yes	Operations Security; Secure Development (CI/CD, staging)
8.33	Test information	Yes	Yes	Secure Development; Data Classification (no production data in non-production; synthetic or anonymized)
8.34	Protection of information systems during audit testing	Yes	Yes	Read only auditer access, no customer data access, NDA for confidential data

ISO 27001

How the ISMS fits together, with the full policy list.