Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
Yes - if your startup handles client data, uses cloud tools, or wants to sell to larger customers, you should have an information security policy. It gives your team clear rules for protecting data and gives customers confidence that you take security seriously.
The nuance is that a policy isn't just a document you keep in a folder. Enterprise customers, insurers, investors and procurement teams may ask to see it during supplier onboarding, especially if you're a SaaS business or you process personal data for clients.
A simple template can help you move quickly, but it needs to match how your business actually works. A policy that says you encrypt everything, review access monthly and test backups weekly won't help if that isn't true.
Do You Need An Information Security Policy For Your Startup?
Yes, you probably need one if your startup stores, sends, receives or otherwise handles business data or personal data. That includes customer lists, employee records, payment data, health information, login credentials, confidential documents and product usage data.
You may not have a legal rule that says, word for word, you must have an information security policy. But under the UK GDPR and the Data Protection Act 2018, you do need appropriate technical and organisational measures to protect personal data. A written policy is one practical way to show what those measures are and how your team follows them.
You may also need a policy because someone else asks for it. This often happens when you:
- sell software to enterprise customers
- act as a processor for a client's personal data
- complete a supplier onboarding questionnaire
- apply for cyber insurance
- prepare for due diligence before investment or sale
- work in a regulated or security-conscious industry
For a small team, your policy doesn't need to read like a bank's security manual. It should be clear, practical and proportionate to your risks. If you have five people and use Google Workspace, AWS and a CRM, your policy should explain how those systems are secured, who has access and what your personnel security process covers when someone leaves.
What Should An Information Security Policy Template Include?
An information security policy template should cover the rules your team follows to keep systems, data and devices secure. It should also explain who is responsible for each area, because vague promises are hard to apply when something goes wrong.
Here is a practical outline you can use as a starting point. This isn't a finished legal document, and it's worth having a lawyer tailor it before you rely on it with customers or staff.
- Purpose And Scope: Explain why the policy exists and which people, systems, data and locations it covers.
- Roles And Responsibilities: Name who owns security decisions, who manages access and what staff must do day to day.
- Data Classification: Set out how you label and handle public, internal, confidential and highly sensitive information.
- Access Control: Explain how accounts are created, approved, reviewed and removed, including admin access.
- Password And MFA Rules: State your password manager, multi-factor authentication and credential sharing rules.
- Device And Remote Working Security: Cover laptops, mobiles, acceptable use rules, updates, screen locks, home networks and lost devices.
- Cloud And Supplier Security: List how you choose and manage key suppliers that store or access your data.
- Backups And Business Continuity: Explain what is backed up, how often backups are checked and who restores data.
- Incident Response: Set out what your team must do if there's a suspected breach or security issue.
- Training And Awareness: Explain onboarding training, refresher training and phishing awareness expectations.
- Monitoring And Review: Say how often the policy is reviewed and what triggers an earlier update.
Try to use everyday language. Your team is more likely to follow a policy that says use the company password manager and never share logins in Slack than one full of technical wording no one reads.
How Do You Write An Information Security Policy That Customers Will Accept?
You write a customer-ready policy by matching it to your real controls, your customer commitments and the risks in your product. Customers don't expect every startup to have enterprise-level systems from day one, but they do expect honest, organised answers.
Start with the systems that matter most. For a SaaS startup, that usually means:
- your production environment and hosting provider
- source code repositories
- customer support tools
- CRM and billing systems
- analytics and product monitoring tools
- staff laptops and identity management systems
Then connect your policy to the questions customers are likely to ask. For example, if your enterprise customer asks whether you remove access when a staff member leaves, your policy should say who removes it, when they remove it and how you record it.
A Simple Writing Process
- Map Your Data: Write down what client data you collect, where it lives and who can access it.
- List Your Current Controls: Include MFA, password managers, access approvals, encryption, backups and logging.
- Close Obvious Gaps: If you don't have offboarding steps or access reviews, create them before promising them.
- Write Clear Rules: Make each rule practical enough for a new starter to follow.
- Align Your Contracts: Check that your policy matches your SaaS terms, data processing agreement and support processes.
Templates often miss the commercial side. If your policy says you'll notify customers of every incident within 24 hours, but your customer contract says something different, you'll have confusion at the exact moment you need clarity.
How Does Your Policy Support UK GDPR Compliance?
Your information security policy supports UK GDPR compliance by showing the practical steps you take to protect personal data. It won't make you compliant on its own, but it can be a key part of your evidence if a customer, auditor or the Information Commissioner's Office asks what you do.
Under the UK GDPR, you need security measures that are appropriate to the risk. That means a startup handling low-risk contact details won't need the same controls as a healthtech platform handling special category data. Your policy should reflect that difference.
There are a few areas where your policy should connect clearly with your privacy documents:
- Security Of Processing: Explain how you protect personal data through access controls, encryption, backups and staff rules.
- Personal Data Breaches: Include an escalation process so you can assess whether you need to notify the ICO within 72 hours of becoming aware of a reportable breach.
- Data Subject Requests: Make sure access controls and data locations help you respond to requests within the usual one month timeframe.
- Processors And Sub-Processors: Explain how you check suppliers that process personal data for you.
- Retention And Deletion: Connect your data retention rules with how long you keep data and how you delete it safely.
Your policy should sit alongside your privacy policy or notice, data processing agreement, records of processing activities, staff confidentiality terms and supplier contracts. If those documents all say different things, your risk goes up.
What Happens During Supplier Onboarding Or A SaaS Security Review?
During supplier onboarding, your customer will usually check whether your security controls are strong enough for the data and access they'll give you. This can be a simple questionnaire or a detailed review involving legal, procurement, security and privacy teams.
Common questions include:
- Do you have a written information security policy?
- Do you require MFA for staff accounts?
- How do you manage joiners, movers and leavers?
- Where is customer data hosted?
- Do you use sub-processors?
- Do you encrypt data in transit and at rest?
- How quickly do you notify customers of a security incident?
- Do you carry out staff security training?
Worked Example: A SaaS Startup Selling To A Larger Customer
Priya runs a 12-person SaaS startup that helps retailers manage stock. A national retailer wants to sign a 2-year contract worth 60,000 pounds a year, but procurement sends a 90-question security questionnaire.
Priya already uses MFA, AWS hosting, a password manager and weekly automated backups. But she doesn't have a written access review process, and staff offboarding is handled informally.
Before responding, Priya updates her information security policy to include:
- a same-day access removal checklist for departing staff
- a quarterly access review for production systems and customer support tools
- a breach escalation process that flags the UK GDPR 72-hour ICO assessment window
- a named security owner and deputy
- a supplier review process for tools that handle customer data
That doesn't mean every answer becomes yes. But it lets Priya respond consistently, show a sensible plan and avoid making promises her team can't keep.
Common Mistakes To Avoid
The biggest mistake is using an infosec policy template without checking whether it matches your business. A polished document can create risk if it promises controls you don't actually have.
Watch out for these common issues:
- Copying Enterprise Language: If you're not ISO certified, don't write the policy as though you are. Say what you actually do.
- Forgetting Remote Work: If your team works from home, your policy should cover Wi-Fi, screen locks, device storage and personal device rules.
- No Owner: Someone needs to be responsible for access approvals, supplier checks and incident decisions.
- No Staff Process: Security policies only work if your team knows about them and agrees to follow them.
- Inconsistent Contracts: Your policy, SaaS agreement, data processing agreement and customer order form should work together.
- Over-Promising On Incident Notices: Fast notice can be useful, but make sure you build in time to assess what happened and whether personal data is involved.
Another easy mistake is treating the policy as a one-off task. If you add a new CRM, move hosting providers, start using AI tools without clear AI governance rules or hire your first overseas contractor, your security position may change.
A good review cycle is at least once a year, plus whenever there's a major change to your product, team, suppliers or customer commitments. Keep a record of each version so you can show customers when the policy was last approved.
Key Takeaways
- An information security policy helps your startup protect data, answer customer questionnaires and support UK GDPR compliance.
- Your policy should match your real systems, suppliers and ways of working, not an ideal version of the business.
- For SaaS sales, the policy should connect with your customer contracts, data processing agreement and incident response process.
- UK GDPR risk matters because a personal data breach may need ICO assessment and possible notification within 72 hours.
- A template can be a useful starting point, but it's safest when tailored to your product, team and customer promises.
If you'd like help with your information security policy, SaaS customer terms, data processing agreement or supplier onboarding documents, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.
Drafted by Taylor, Sprintlaw's AI, and overseen by Alex Solo. How we write
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