ISO 27001:2022 Annex A 5.14 – Information Transfer Explained

Information is often most vulnerable when it is moving.

Annex A 5.14 exists to ensure that information is protected during transfer, whether it is sent electronically, shared verbally, or moved using physical media. This control focuses on reducing the risk of unauthorised access, interception, alteration, or loss while information is in transit.

The emphasis is on appropriate protection based on classification and risk, not blanket restrictions that hinder normal business activity.

ISO 27001

Quick Guide: Annex A 5.14 at a Glance

Annex A 5.14 of ISO 27001:2022 addresses the security of information transfer.

At a practical level, this means:

  • Defining rules and procedures for transferring information
  • Applying protection appropriate to the classification of information
  • Covering electronic, physical, and verbal transfers
  • Clarifying responsibilities and accountability during transfer
  • Reducing the risk of interception, loss, or misuse

The control does not mandate specific technologies or methods. It expects organisations to apply proportionate controls that reflect how information is actually shared.

In-Depth Guide to Annex A 5.14

What Is Annex A 5.14 and Why Does It Matter?

Information transfer is a routine business activity.

Examples include:

  • Email and file sharing
  • Use of collaboration platforms
  • Transfer of data to suppliers or customers
  • Movement of physical media
  • Verbal discussions of sensitive matters

Each of these introduces risk if not managed deliberately.

Annex A 5.14 ensures organisations recognise that data in transit requires protection, just as data at rest does. Many incidents occur not because systems are insecure, but because information is transferred in ways that bypass controls.

How to Implement Annex A 5.14 Effectively

A pragmatic approach to Annex A 5.14 typically includes the following elements.

1. Apply Protection Based on Classification

The level of protection applied during transfer should reflect the information’s classification.

Higher sensitivity information typically warrants:

  • Stronger controls
  • Greater oversight
  • Clearer accountability

This keeps protection proportionate and credible.

2. Define Rules for Different Transfer Types

Annex A 5.14 recognises three broad transfer types:

  • Electronic transfer
  • Physical transfer of storage media
  • Verbal transfer

Each carries different risks and benefits from tailored guidance rather than a single generic rule.

3. Manage Electronic Transfers Deliberately

For electronic transfer, organisations often consider:

  • Protection against malware
  • Ensuring information is sent to the intended recipient
  • Appropriate authentication when using public networks
  • Limitations on automated forwarding or insecure channels

The focus is on reducing common, avoidable errors.

4. Control Physical Transfer of Information

When information is transferred physically, considerations often include:

  • Secure packaging
  • Trusted and authorised couriers
  • Chain-of-custody awareness
  • Confirmation of dispatch and receipt

Physical transfer risks are often overlooked but remain relevant.

5. Address Risks in Verbal Transfer

Verbal transfer can expose sensitive information unintentionally.

Organisations often provide guidance on:

  • Avoiding sensitive discussions in public or insecure environments
  • Verifying participants before sharing information
  • Being mindful of recordings or overheard conversations

Awareness is the primary control here.

6. Clarify Responsibilities and Agreements

Where information is shared externally, organisations may define:

  • Responsibilities of sender and recipient
  • Liability in the event of a breach
  • Expectations for secure handling

Clarity reduces uncertainty and dispute.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Common Challenges and How to Overcome Them

  • Treating all transfers the same
  • Tailor controls to transfer type and information sensitivity
  • Relying on informal habits
  • Define clear, usable transfer rules
  • Focusing only on electronic transfers
  • Address physical and verbal transfers as well
  • Overcomplicating secure transfer
  • Keep controls proportionate and practical

Information transfer controls work best when they reflect real behaviour.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Final Recommendations

Annex A 5.14 is about protecting information beyond system boundaries.

When information transfer is managed effectively:

  • Data loss risk is reduced
  • Accidental disclosure is less likely
  • Accountability is clearer
  • Trust with external parties improves

Information rarely stays in one place. Treating transfer as a deliberate security activity helps ensure protection travels with it.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

The Annex Control Table

ISO 27001:2022 Organisational Controls
ISO 27001:2022 Technological Controls