ISO 27001:2022 Annex A 5.28 – Collection of Evidence Explained

When incidents escalate, evidence quality determines outcomes.

Annex A 5.28 exists to ensure organisations collect, handle, and preserve evidence from information security incidents in a way that is reliable, defensible, and fit for purpose, including disciplinary, legal, regulatory, and contractual use.

This control is about credibility under scrutiny.

ISO 27001

Quick Guide: Annex A 5.28 at a Glance

Annex A 5.28 of ISO 27001:2022 focuses on the collection and preservation of evidence related to information security incidents.

At a practical level, this means:

  • Identifying what evidence should be collected during incidents
  • Collecting evidence in a timely and controlled manner
  • Ensuring evidence integrity and authenticity
  • Preserving evidence so it remains admissible and reliable
  • Using competent and authorised personnel for evidence handling

The control does not require forensic-level investigation for every incident. It expects a planned, legally aware approach that ensures evidence is not compromised through haste or poor handling.

In-Depth Guide to Annex A 5.28

What Is Annex A 5.28 and Why Does It Matter?

Evidence collected during an incident may later be required for:

  • Internal disciplinary action
  • Regulatory investigation
  • Civil or criminal legal proceedings
  • Contractual dispute resolution
  • Root cause and technical analysis

If evidence is incomplete, altered, or poorly handled:

  • Legal action may be undermined
  • Regulatory findings may be challenged
  • Accountability may be lost
  • The organisation’s credibility may suffer

Annex A 5.28 ensures organisations treat evidence as a security asset, not a by-product of incident response.

How to Implement Annex A 5.28 Effectively

A pragmatic approach to Annex A 5.28 typically includes the following elements.

1. Define Evidence Collection Procedures in Advance

Evidence collection should not be improvised during incidents.

Organisations benefit from defining:

  • What types of evidence may be relevant
  • How evidence should be collected
  • How evidence integrity is protected
  • How evidence is recorded and stored

Predefined procedures reduce error under pressure.

2. Identify Types of Evidence to Be Collected

Evidence may include, but is not limited to:

  • System and application logs
  • Access and authentication records
  • Network traffic data
  • Device and system states
  • Storage media and backups
  • Communications or transaction records

Relevance depends on incident type, impact, and context.

3. Protect Evidence Integrity and Authenticity

Evidence must be demonstrably reliable.

Organisations typically ensure that:

  • Records are complete and unaltered
  • Access to evidence is restricted
  • Copies are accurate representations of originals
  • Collection activities are logged and traceable

Any compromise of integrity reduces evidential value.

4. Ensure Systems Are Capable of Supporting Evidence Collection

Evidence can only be collected if systems support it.

This includes ensuring that:

  • Logging and monitoring are operational
  • Time synchronisation is consistent
  • Storage capacity supports retention needs

Evidence gaps often originate from system limitations, not process failures.

5. Use Competent and Authorised Personnel

Evidence collection should be performed by individuals who:

  • Understand incident handling and evidence requirements
  • Are trained in relevant procedures
  • Are legally entitled to collect digital evidence where required

Unqualified handling increases legal and procedural risk.

6. Consider Legal and Jurisdictional Requirements

Evidence may be subject to:

  • Legal admissibility rules
  • Regulatory expectations
  • Jurisdictional constraints
  • Privacy and employment law

Organisations should avoid assumptions and, where necessary, seek legal advice or involve appropriate authorities early.

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.

Practical Considerations During Incidents

During incident response, organisations often need to balance:

  • Rapid containment and recovery
  • Preservation of evidence
  • Operational continuity

Annex A 5.28 does not prevent containment actions. It expects evidence considerations to be integrated, not ignored.

Where evidence collection could conflict with containment or legal requirements, decisions should be deliberate, justified, and recorded.

Common Challenges and How to Overcome Them

  • Destroying or overwriting evidence during recovery
  • Consider evidential impact before remediation actions
  • Assuming evidence relevance too early
  • Preserve first, assess relevance later
  • Uncontrolled access to evidence
  • Restrict handling to authorised personnel
  • Lack of system capability to collect evidence
  • Ensure logging and monitoring are operational and adequate

Evidence handling fails most often through haste, not intent.

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 5.28 is about protecting the integrity of facts.

When evidence is collected and preserved correctly:

  • Investigations are more effective
  • Legal and disciplinary actions are defensible
  • Regulatory engagement is smoother
  • Incident learning is more reliable

Not every incident leads to legal action.
But when it does, the quality of evidence determines the outcome.

Annex A 5.28 ensures organisations are prepared for that reality.

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