1. Purpose
The SaaS Application Register is used to identify, document, assess, and manage third-party Software-as-a-Service (SaaS) applications used by the organization.
SaaS applications may process sensitive business information, customer information, employee information, credentials, source code, financial information, or security data. The organization therefore needs visibility into:
- Which SaaS applications are being used.
- Why each application is used.
- Who owns the application.
- What information it processes.
- Where the information is stored or processed.
- Who can access it.
- Whether the application is business-critical.
- What security and privacy requirements apply.
- Which supplier provides the service.
- What contractual protections exist.
- How the application is monitored and reviewed.
- When the application should be retired.
The register supports the organization’s ISMS, supplier security management, risk assessment, access control, information classification, privacy management, and business continuity activities.
2. Scope
The register should cover SaaS applications that are:
- Officially procured by the organization.
- Approved for business use.
- Used to process organizational information.
- Used to process customer information.
- Used by employees or contractors for business activities.
- Integrated with corporate systems.
- Connected to organizational identity providers.
- Used to support critical business processes.
Examples include:
- Microsoft 365 / Google Workspace
- Slack / Microsoft Teams
- GitHub / GitLab
- Jira / ServiceNow
- Salesforce / HubSpot
- HR and payroll platforms
- Accounting platforms
- Customer support platforms
- Cloud security platforms
- Project management platforms
- Marketing platforms
- CRM systems
- File-sharing platforms
- E-signature platforms
- AI-based SaaS applications
- Security and compliance platforms
Personal consumer applications that are not approved for business use should generally be managed through the organization’s acceptable-use or shadow-IT process rather than simply being added as approved SaaS applications.
3. SaaS Application Management Principles
3.1 Know What Is Being Used
The organization should maintain visibility over important SaaS applications.
3.2 Assign an Internal Owner
Every important SaaS application should have an accountable internal owner.
3.3 Understand the Data
Before using a SaaS application, determine what organizational or customer information will be processed.
3.4 Assess Supplier Risk
Security, privacy, contractual, availability, and business risks should be considered based on the nature and criticality of the service.
3.5 Control Access
Access should be based on business need and appropriate authorization.
3.6 Review Periodically
Applications, users, permissions, supplier security, and business requirements should be reviewed periodically.
3.7 Manage the Full Lifecycle
SaaS applications should follow:
Request → Assess → Approve → Configure → Use → Review → Renew → Retire
4. SaaS Application Register — Main Template
| Field | Description |
|---|---|
| SaaS ID | Unique application identifier |
| Application Name | Name of SaaS application |
| Provider / Supplier | SaaS provider |
| Application URL | Official application URL |
| Business Purpose | Why the organization uses it |
| Business Process | Process supported |
| Application Owner | Internal accountable owner |
| Technical Owner | IT/security/technical custodian |
| Department | Primary business department |
| User Population | Employees, contractors, customers, etc. |
| Number of Users | Approximate active users |
| Information Processed | Type of information handled |
| Information Classification | Public, Internal, Confidential, Restricted |
| Personal Data | Whether personal data is processed |
| Customer Data | Whether customer information is processed |
| Criticality | Critical, High, Medium, Low |
| Integration | SSO, API, SCIM, other integrations |
| Authentication | SSO/MFA/password/etc. |
| Privileged Access | Administrative access details |
| Supplier Risk | Low, Medium, High, Critical |
| Security Assessment | Status and date |
| Privacy Assessment | Status and date |
| Contract | Contract status |
| DPA | Data Processing Agreement status where applicable |
| Security Agreement | Security requirements / contractual terms |
| Data Location | Hosting or processing location where known |
| Retention | Data retention requirements |
| Backup / Recovery | Business continuity considerations |
| Incident Notification | Supplier notification requirement |
| Exit / Deletion | Data return/deletion arrangements |
| Renewal Date | Contract/subscription renewal |
| Last Review | Last application review |
| Next Review | Next planned review |
| Status | Approved, Conditional, Under Review, Retired |
| Related Risk ID | Relevant risk reference |
| Evidence | Supporting documentation |
5. Sample SaaS Application Register
The following is an illustrative example for a technology/SaaS startup.
| ID | SaaS Application | Purpose | Owner | Data | Classification | Criticality | Status |
|---|---|---|---|---|---|---|---|
| SaaS-001 | Microsoft 365 | Email & collaboration | IT Manager | Business/Employee | Confidential | Critical | Approved |
| SaaS-002 | GitHub Enterprise | Source code | CTO | Source Code | Confidential | Critical | Approved |
| SaaS-003 | Jira | Project management | Engineering Lead | Project Data | Internal | High | Approved |
| SaaS-004 | Salesforce | CRM | Sales Head | Customer Data | Confidential | High | Approved |
| SaaS-005 | HR Platform | HR management | HR Manager | Employee Data | Restricted | High | Approved |
| SaaS-006 | Zendesk | Customer support | Support Lead | Customer Data | Confidential | High | Approved |
| SaaS-007 | DocuSign | Electronic signatures | Legal/Operations | Contracts | Confidential | High | Approved |
| SaaS-008 | Slack | Communication | IT Manager | Business Information | Internal/Confidential | High | Approved |
| SaaS-009 | Security Platform | Security monitoring | Security Lead | Security Data | Confidential | High | Approved |
| SaaS-010 | AI Productivity Tool | Business productivity | Business Owner | Business Information | Risk-based | Medium | Conditional |
Actual applications, providers, data types, and classifications should be determined from the organization’s environment.
6. SaaS Application Ownership
Each important SaaS application should have an internal owner.
The owner is accountable for:
- Business justification.
- Application approval.
- Data classification.
- User access requirements.
- Supplier assessment.
- Security requirements.
- Contractual requirements.
- Periodic review.
- Renewal or termination.
- Data retention and deletion.
- Business continuity considerations.
The SaaS provider operates the service, but the organization retains responsibility for deciding whether the application is appropriate for its business use.
7. SaaS Technical Custodian
The technical custodian supports the operational and security configuration of the application.
Responsibilities may include:
- SSO configuration.
- MFA configuration.
- User provisioning.
- SCIM configuration.
- Administrative roles.
- API integrations.
- Security settings.
- Logging.
- Monitoring.
- Backup/export configuration.
- Integration management.
- Offboarding.
Example:
Application: GitHub Enterprise
Application Owner: CTO
Technical Custodian: DevOps Lead
Business Users: Engineering
The CTO remains accountable for the application, while DevOps manages the technical configuration.
8. SaaS Business Criticality
The organization should determine how important each SaaS application is to business operations.
| Criticality | Example |
|---|---|
| Critical | Loss could significantly interrupt core business or customer services |
| High | Loss could materially affect important business operations |
| Medium | Loss would cause manageable disruption |
| Low | Loss has limited operational impact |
Criticality should consider:
- Business dependency.
- Number of users.
- Customer impact.
- Data sensitivity.
- Revenue dependency.
- Operational dependency.
- Availability requirements.
- Recovery alternatives.
9. Information Processed by SaaS Applications
Before approving a SaaS application, identify the information it will process.
Examples:
| SaaS | Information |
|---|---|
| CRM | Customer and prospect information |
| HR platform | Employee information |
| GitHub | Source code and technical information |
| Business and customer communications | |
| Accounting platform | Financial information |
| Support platform | Customer support records |
| E-signature platform | Contracts and personal information |
| AI SaaS | Depends on information submitted by users |
The information should be classified according to the organization’s classification framework.
10. SaaS Security Assessment
The level of supplier assessment should be proportionate to risk.
Possible assessment areas include:
Organization and Governance
- Security policies.
- Security governance.
- Security certifications.
- Independent assurance reports.
Access Control
- MFA.
- SSO.
- RBAC.
- Privileged access.
- User lifecycle management.
Data Protection
- Encryption.
- Data segregation.
- Data retention.
- Data deletion.
- Data export.
Infrastructure Security
- Network security.
- Vulnerability management.
- Secure development.
- Security monitoring.
Incident Management
- Incident response.
- Security incident notification.
- Customer communication.
- Investigation support.
Availability
- Business continuity.
- Disaster recovery.
- Service availability.
- Backup and recovery.
Privacy
- Data processing.
- Subprocessors.
- Data location.
- Data subject requirements.
- Data deletion.
Not every SaaS application requires the same depth of assessment.
11. SaaS Supplier Risk Classification
A simple risk model may be used.
| Supplier Risk | Typical Characteristics |
|---|---|
| Low | Limited business impact and no sensitive information |
| Medium | Internal business information or moderate operational dependency |
| High | Sensitive information, customer data, or important business dependency |
| Critical | Critical business service, highly sensitive information, or significant customer/operational dependency |
Risk classification should be based on the organization’s approved supplier risk methodology.
12. SaaS Approval Process
A practical approval process is:
Business Need → Data Assessment → Risk Assessment → Security/Privacy Review → Supplier Assessment → Contract Review → Approval → Configuration → User Access → Periodic Review
Before approving a high-risk SaaS application, consider:
- What data will be uploaded?
- Is customer data involved?
- Is personal information involved?
- Is source code involved?
- Is the application business-critical?
- Does it support SSO/MFA?
- Who will have administrative access?
- Where is data processed?
- What contractual protections exist?
- How are incidents reported?
- What happens when the contract ends?
13. Shadow IT
Employees may sometimes adopt SaaS applications without formal approval.
Examples:
- Unapproved file-sharing platforms.
- Personal AI tools.
- Personal cloud storage.
- Unapproved project-management applications.
- Unapproved collaboration tools.
- Browser-based data-processing services.
The organization should have a process to identify and manage unauthorized SaaS use.
Shadow IT Process
Detect → Identify Application → Identify Users → Determine Data → Assess Risk → Approve / Restrict / Remove → Update Register
The objective should be risk reduction rather than simply maintaining a list of prohibited applications.
14. SaaS Access Management
Access should follow the organization’s access-control process.
Joiner
New employee → Business approval → Account creation → Appropriate access
Mover
Role change → Access review → Modify permissions → Remove unnecessary access
Leaver
Employee departure → Disable account → Revoke sessions/tokens → Transfer business data → Confirm closure
For important SaaS applications, SSO and automated provisioning/deprovisioning can reduce access-management risks.
15. SaaS Administrative Access
Administrative access should receive additional protection.
Recommended controls may include:
- MFA.
- SSO.
- Least privilege.
- Separate administrative accounts where appropriate.
- Limited number of administrators.
- Access approval.
- Periodic access review.
- Logging.
- Monitoring.
- Emergency access procedures.
Example:
GitHub Organization Administrator
→ CTO/Engineering approval
→ MFA required
→ Limited administrators
→ Periodic access review
→ Administrative activity logged where available
16. SaaS Integrations and API Access
The register should identify significant integrations.
Examples:
- SaaS ↔ Microsoft 365
- SaaS ↔ HR platform
- SaaS ↔ CRM
- SaaS ↔ AWS
- SaaS ↔ GitHub
- SaaS ↔ Identity Provider
Record:
- Integration purpose.
- Systems involved.
- Data exchanged.
- Authentication method.
- API credentials/service accounts.
- Owner.
- Security requirements.
- Risk.
API keys and secrets should not be stored in the SaaS Application Register.
17. SaaS Data Location
Where relevant, record:
- Hosting country/region.
- Processing locations.
- Backup locations.
- Subprocessor locations.
- Data transfer arrangements.
This can be particularly important for:
- Customer information.
- Employee information.
- Personal data.
- Financial information.
- Regulated information.
If the provider’s exact location is unknown, record the limitation and identify the evidence or supplier documentation used.
18. Contractual Requirements
Important SaaS contracts should be reviewed for relevant security requirements.
Consider:
- Confidentiality.
- Data protection.
- Security requirements.
- Incident notification.
- Breach notification.
- Availability commitments.
- Service levels.
- Subprocessors.
- Data location.
- Data retention.
- Data deletion.
- Audit or assurance information.
- Business continuity.
- Termination assistance.
The register should record the status of important contractual requirements rather than reproducing the entire contract.
19. Security Assurance Evidence
Depending on the application’s risk, evidence may include:
- ISO/IEC 27001 certificate.
- SOC 2 report.
- Independent penetration test summary.
- Security questionnaire.
- Security architecture information.
- Privacy documentation.
- Data Processing Agreement.
- Business continuity information.
- Incident response information.
- Supplier security assessment.
The presence of a certification or report does not automatically mean the SaaS application is suitable for the organization’s specific use case. The organization should assess the evidence in context.
20. SaaS Privacy Assessment
Where personal data is processed, assess:
- What personal data is processed?
- Why is it processed?
- Who is the data controller/processor in the relevant context?
- Where is the data processed?
- Who are the subprocessors?
- How long is data retained?
- How can data be deleted?
- What security measures are provided?
- What happens after contract termination?
Applicable privacy requirements should be determined based on the organization’s jurisdictions, data subjects, services, and contracts.
21. SaaS Business Continuity
For critical SaaS applications, consider:
- Service availability.
- Provider outage procedures.
- Data export capability.
- Backup arrangements.
- Alternative processes.
- Recovery procedures.
- Provider disaster recovery information.
- Business continuity dependencies.
Example:
Critical SaaS CRM unavailable
Potential response:
→ Activate business continuity procedure
→ Use available exported customer information if appropriate
→ Communicate internally
→ Monitor supplier status
→ Restore normal operations
→ Review incident and supplier performance
22. SaaS Renewal Review
Before renewing a significant SaaS application, review:
- Business requirement.
- Current users.
- Current access permissions.
- Data processed.
- Security assessment.
- Privacy requirements.
- Supplier performance.
- Incidents.
- Contract changes.
- Pricing and licensing.
- Business continuity.
- Alternative solutions.
- Data retention and deletion requirements.
This helps prevent unnecessary SaaS subscriptions and reduces unused or unmanaged applications.
23. SaaS Application Retirement
When a SaaS application is no longer required:
Business Approval → Data Export/Retention Assessment → Access Removal → Integration Removal → Contract Termination → Data Deletion/Return → Verification → Register Update
Verify:
- User accounts are disabled.
- API integrations are removed.
- Tokens/API credentials are revoked.
- Data is returned or deleted as required.
- Backups are addressed.
- Supplier termination is documented.
- Evidence is retained.
24. SaaS Risk Register Linkage
Important SaaS applications should be linked to relevant risks.
Example:
SaaS: Customer Support Platform
Risk: Unauthorized disclosure of customer information.
Threat: Compromised user account.
Existing Controls:
- SSO.
- MFA.
- RBAC.
- Access reviews.
- Logging.
- Supplier security assessment.
Risk Owner: Support Manager / appropriate designated risk owner.
Related SaaS ID: SaaS-006
This provides traceability:
SaaS → Information → Risk → Control → Evidence
25. SaaS Application Review
During periodic review, confirm:
- Is the application still required?
- Is the owner still correct?
- Is the supplier still approved?
- Has the data processed changed?
- Has classification changed?
- Are users still appropriate?
- Are privileged users still appropriate?
- Are integrations still required?
- Has the supplier changed its security posture?
- Have contracts changed?
- Are privacy requirements still satisfied?
- Has the risk changed?
- Is the application still business-critical?
- Is renewal appropriate?
26. Suggested Review Frequency
Review frequency should be risk-based.
| SaaS Category | Example Review |
|---|---|
| Critical SaaS | Quarterly or risk-based |
| High-risk SaaS | At least annually or when significant changes occur |
| Sensitive-data SaaS | At least annually or risk-based |
| Medium-risk SaaS | Annually |
| Low-risk SaaS | Periodically |
| New SaaS application | Before approval |
| Major supplier change | Event-driven |
| Contract renewal | Before renewal |
These are example frequencies and should be adapted to organizational risk.
27. Audit Evidence
Potential audit evidence includes:
- SaaS Application Register.
- SaaS approval records.
- Supplier assessments.
- Security questionnaires.
- SOC 2/ISO 27001 reports where applicable.
- Contracts.
- Data Processing Agreements.
- Access reviews.
- SSO/MFA configuration.
- User provisioning/deprovisioning records.
- Supplier risk assessments.
- Privacy assessments.
- Incident records.
- Business continuity assessments.
- Renewal reviews.
- SaaS retirement records.
An auditor may select a SaaS application and trace:
Application → Owner → Data → Classification → Supplier → Risk → Security Requirements → Access → Evidence
28. Common Mistakes
Mistake 1 — Only Listing Paid Applications
Free or trial SaaS applications can also create security risks if organizational information is entered into them.
Mistake 2 — No Business Owner
IT should not automatically become the owner of every SaaS application.
Mistake 3 — Ignoring AI SaaS
AI applications may process sensitive business or customer information and should be evaluated according to their use and risk.
Mistake 4 — No Data Assessment
Knowing the SaaS name is not enough. The organization should understand what information is processed.
Mistake 5 — Relying Only on Vendor Certifications
A vendor’s ISO 27001 certificate or SOC 2 report is useful evidence, but the organization should still assess whether the service meets its specific requirements.
Mistake 6 — No Offboarding
SaaS applications should have a defined retirement process, including access removal and data handling.
Mistake 7 — Ignoring Integrations
API connections and SSO integrations can create additional security dependencies.
29. Startup-Friendly Implementation
A startup can implement SaaS governance without creating a complicated procurement process.
Minimum Process
1. Identify
Create a list of business SaaS applications.
2. Assign Owners
Assign one accountable owner to each important application.
3. Identify Data
Record what information is processed.
4. Classify
Apply the organization’s information classification.
5. Assess Risk
Consider data sensitivity, business dependency, integrations, and supplier risk.
6. Review Security
Check appropriate security assurance and controls.
7. Approve
Obtain appropriate business/security approval.
8. Control Access
Use SSO, MFA, RBAC, and periodic access reviews where appropriate.
9. Review
Review important SaaS applications periodically.
10. Retire
Remove access and manage data appropriately when the application is no longer required.
A spreadsheet or GRC platform is sufficient for many early-stage organizations. A dedicated SaaS Management Platform (SMP/SAM) can be considered as the number of applications, users, and integrations grows.
30. Minimum SaaS Application Register
For a small startup, the following fields provide a practical starting point:
| SaaS ID | Application | Provider | Purpose | Owner | Data | Classification | Criticality | Users | MFA/SSO | Supplier Risk | Renewal | Status |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| SaaS-001 | CRM | Provider | Sales | Sales Head | Customer Data | Confidential | High | 15 | SSO/MFA | High | Date | Approved |
| SaaS-002 | Code Repository | Provider | Development | CTO | Source Code | Confidential | Critical | 20 | SSO/MFA | High | Date | Approved |
| SaaS-003 | HR Platform | Provider | HR | HR Manager | Employee Data | Restricted | High | 50 | SSO/MFA | High | Date | Approved |
| SaaS-004 | Collaboration | Provider | Communication | IT Manager | Business Data | Internal | High | 50 | SSO/MFA | Medium | Date | Approved |
31. Relationship With Other ISMS Documents
The SaaS Application Register should connect with:
SaaS Application Register
↓
Identifies third-party applications
Information & Asset Inventory
↓
Identifies information and associated assets
Asset Ownership Register
↓
Assigns accountable owners
Asset Classification Procedure
↓
Determines information protection requirements
Supplier Security Assessment
↓
Evaluates supplier security
Risk Register
↓
Records SaaS-related risks
Access Control
↓
Controls users and privileged access
Privacy / Data Protection Assessment
↓
Evaluates personal data processing
Contract / DPA Review
↓
Establishes contractual requirements
Business Continuity
↓
Addresses critical SaaS dependency
Incident Management
↓
Addresses SaaS security incidents
Internal Audit
↓
Verifies implementation and effectiveness
32. Quick Audit Checklist
- Important SaaS applications have been identified.
- SaaS owners are assigned.
- Technical custodians are identified where appropriate.
- Business purpose is documented.
- Information processed is identified.
- Information classification is recorded.
- Business criticality is assessed.
- Supplier risk is assessed.
- Security requirements are reviewed.
- Privacy requirements are assessed where applicable.
- Contracts and relevant agreements are reviewed.
- SSO/MFA is implemented where appropriate.
- Administrative access is controlled.
- User access is periodically reviewed.
- Important integrations are documented.
- Renewal reviews are performed.
- SaaS retirement and data deletion requirements are defined.
- Shadow IT is addressed.
- Relevant risks are linked.
- Supporting evidence is available for audit.
33. Final Principle
A good SaaS Application Register should answer:
What SaaS applications do we use?
Why do we use them?
Who owns them?
What information do they process?
How sensitive is that information?
Who can access the application?
How secure is the supplier?
What happens if the service becomes unavailable?
What happens when we stop using it?
The practical lifecycle is:
Discover → Assess → Approve → Assign Owner → Configure Securely → Control Access → Monitor → Review → Renew or Retire
