What is a risk in compliance?
Risk management is at the heart of every compliance framework: ISO 27001, SOC 2, GDPR. Yet most teams treat it like a checkbox. Here's what it actually means, and how to think about it properly.
A customer just asked about your security posture. You open your risk register and realize it’s a spreadsheet someone filled in 18 months ago and never touched since.
Sound familiar?
Before you can manage risks, you need to understand what a risk actually is.
Risk = threat × vulnerability
In information security, a risk is not just “something bad that could happen.” It’s the product of two things:
- A threat: something dangerous or harmful that could occur (a cyberattack, a data leak, a fire in your server room).
- A vulnerability: a weakness that could be exploited (no backups, no access controls, no encryption).
Remove either one, and the risk disappears.
No threat? No risk. There’s no risk of an avalanche in central London.
No vulnerability? No risk either. An attacker with no entry point is just a person standing outside a locked building with no doors.
This matters because most teams focus on threats without auditing their vulnerabilities, or patch vulnerabilities without checking if there’s actually a credible threat. Both are a waste of time. This is why it is key to have a deep understanding of your company context.
A concrete example
Say one of your developers leaves the company. Nobody revokes their GitHub access. One potential threat: a disgruntled ex-employee. One vulnerability: active credentials with no expiry.
The resulting risk: your codebase gets tampered with or leaked.
| Component | In this scenario |
|---|---|
| Threat | Disgruntled ex-employee |
| Vulnerability | Active credentials post-offboarding |
| Risk | Code leak or sabotage, reputational and contractual damage |
Simple to write. But is it worth fixing?
Probability and impact: the two questions that actually matter
Let’s put numbers on this:
You hire and lose roughly 5 people per year. Each departure without proper offboarding carries an estimated exposure of €20,000 (breach investigation, legal fees, customer notification). Probability it happens badly: once every 4 years.
Annual loss (ALE): €5,000/year.
Cost of a fancy automated identity management platform: €800/month = €9,600/year.
The math doesn’t hold. A €9,600/year tool to cover a €5,000/year risk makes no sense. A better fix: a one-page offboarding checklist and a Slack reminder to IT. Costs nothing. Solves the problem.
Now flip it. A ransomware attack hits your infrastructure and you have no offline backups:
| Component | In this scenario |
|---|---|
| Threat | Ransomware attack |
| Vulnerability | No immutable backups |
| Risk | Complete data loss, operations shutdown, ransom payment |
Probability: ransomware attacks on SMBs are up every year. This is not a theoretical threat.
Impact: average ransom demand for a small company sits around €80,000—before you factor in a week of downtime, customer churn, and potential GDPR fines. Realistic total: €500,000+.
Cost of a proper immutable backup solution: €200/month = €12,000 over 5 years.
That’s a €488,000 benefit over five years. The decision is obvious.
The four ways to treat a risk
Once you’ve evaluated a risk, you have four options:
- Reduce it — implement a control (backup system, access policy, encryption).
- Transfer it — get cyber insurance, use a SaaS that absorbs the liability.
- Avoid it — stop the activity that creates the risk entirely.
- Accept it — document that you’ve made a conscious decision to live with it.
Most frameworks (ISO 27001, SOC 2) require you to pick one of these for every identified risk. “We didn’t think about it” is not an option.
Why this matters for compliance
ISO 27001 is literally built around risk management. The entire framework exists to make you identify your risks, evaluate them, and treat them systematically. SOC 2 Trust Services Criteria follow the same logic.
A compliance audit isn’t checking whether you have zero risks. It’s checking whether you have a rational process to understand and manage them.
Which means a risk register full of “high” ratings and no treatment decisions is worse than useless: it shows your auditor you’ve identified problems and ignored them.
A practical starting point
Before your next audit, ask yourself:
- Do we have a list of assets that matter? (data, systems, people, processes)
- For each one, what’s the credible threat and where’s the vulnerability?
- Have we estimated the probability and impact, with actual numbers?
- Have we made an explicit decision on how to treat each risk?
If the answer to any of these is “not really,” you’re not managing risk as you should.