← Back to all work
Case study · Governance, Risk & Compliance

Turning a certificate into an actual security program

Ownership of Lightmatter's ISO 27001:2013 → 2022 transition and full-scope re-certification, the build-out of the policy library and risk framework beneath it, and the governance restructuring that put security in front of the executive team.

Role
Head of IT, Security & Facilities
Company
Lightmatter — Mountain View, CA
Sector
Silicon photonics · AI compute
Timeframe
2024 – 2026
The challenge

A certificate on the wall, and very little behind it.

Lightmatter is building the photonic interconnect for the next era of AI compute — the kind of company whose customers and investors ask hard security questions early.

On paper the company was ISO 27001:2013 certified. In practice the steering committee's own assessment was blunt: minimal formal controls, with no dedicated security staff or leadership, minimal tooling, and checkbox-only compliance. Meanwhile the 2022 revision of the standard was coming, bringing eleven new controls with it. The task was not to renew a certificate — it was to build the program the certificate was supposed to represent.

Key workstreams

What the work actually was.

01

ISO 27001:2013 → 2022 transition

Owned the transition end to end — gap assessment, risk-to-control mapping, policy development, internal audit, and external audit — including all eleven controls new to the 2022 revision. All 65 risks mapped to controls.

02

Full-scope re-certification, clean

Delivered full-scope re-certification with A-LIGN, certified 8 September 2025 with zero non-conformities: 93 Annex A controls plus management clauses tested across 20 in-scope systems, backed by 300+ evidence artifacts from five business functions. Secured a three-year certification runway.

03

A policy library from a standing start

Directed creation of the information security policy library — 15 policies developed and published across 2025, covering the full set of ISO 27001 Annex A policy requirements.

04

Governance put in front of the executives

Restructured the ISMS Steering Committee to add C-level and VP membership — CFO, General Counsel, SVP Operations, and VPs of Software, Product, People, and Photonics — and moved cadence from twice yearly to quarterly. Now chairs the combined IT & Security Steering Committee with formal decisions recorded each quarter.

05

Continuous controls monitoring

Deployed a continuous controls-monitoring platform, integrated across 13 systems, replacing manual evidence collection with automated control-to-evidence mapping.

06

Third-party risk, automated end to end

Rebuilt vendor risk from spreadsheet coordination into an automated workflow — procurement intake now triggers an automated risk assessment in the controls-monitoring platform, so security review happens before vendor approval rather than after. Live 31 March 2026.

Results & impact

What it delivered.

0Non-conformities, full-scope re-certification
93Annex A controls tested, 20 in-scope systems
300+Evidence artifacts across five business functions
15Security policies published in 2025
28Applications covered by user access reviews
13Systems integrated for continuous monitoring

“The company was already certified. What it didn't have was a security program. Passing a full-scope 2022 audit with zero non-conformities was the proof that we'd built one.”

Areas of impact

Four ways it mattered.

Substance

Turned checkbox compliance into controls that hold up under a full-scope audit.

Rigor

Zero non-conformities across 93 controls and 300+ pieces of evidence.

Governance

Security moved from an IT topic to a quarterly executive decision forum.

Automation

Evidence and vendor risk automated, so the program scales without headcount.