ISO 27001:2022 Annex A 5.33 – Protection of Records Explained

Records quietly underpin trust, accountability, and compliance.
When they are lost, altered, or inaccessible, the damage is rarely technical — it’s organisational.

Annex A 5.33 exists to ensure organisations protect records from loss, damage, unauthorised access, falsification, and destruction, while keeping them usable, reliable, and legally defensible for as long as they are required.

This control is about governance and integrity, not storage alone.

ISO 27001

Quick Guide: Annex A 5.33 at a Glance

Annex A 5.33 of ISO 27001:2022 focuses on the protection of organisational records.

At a practical level, this means:

  • Identifying records that need protection
  • Preserving integrity, authenticity, reliability, and usability
  • Protecting records from loss, damage, or unauthorised change
  • Defining retention and secure disposal requirements
  • Ensuring records remain accessible for legitimate business and legal needs

The control does not prescribe a single records management system or technology. It expects organisations to apply appropriate protection based on record type, risk, and obligation.

In-Depth Guide to Annex A 5.33

What Is Annex A 5.33 and Why Does It Matter?

Records provide evidence of:

  • Decisions
  • Transactions
  • Activities
  • Compliance with legal and contractual obligations

They may exist in many forms, including:

  • Documents and datasets
  • Logs and system records
  • Transaction histories
  • Personnel, legal, financial, or operational records

If records are poorly protected:

  • Evidence may be challenged or rejected
  • Regulatory or legal obligations may be breached
  • Disputes become harder to resolve
  • Trust in organisational processes is undermined

Annex A 5.33 ensures records are protected deliberately throughout their lifecycle, not treated as static files sitting on storage.

How to Implement Annex A 5.33 Effectively

A pragmatic approach to Annex A 5.33 typically includes the following elements.

1. Identify and Categorise Records

Organisations should identify what constitutes a record in their context.

This often includes:

  • Business and operational records
  • Legal and contractual records
  • Financial and accounting records
  • Personnel and HR records
  • Security and audit records

Categorisation helps determine protection, retention, and disposal needs.

2. Protect Record Integrity and Authenticity

Records should remain accurate and trustworthy.

Organisations typically ensure:

  • Records cannot be altered without authorisation
  • Changes are controlled and traceable
  • Originals and authoritative versions are identifiable

Integrity is often more critical than confidentiality for records.

3. Control Access to Records

Records should only be accessible to those with a legitimate need.

Access controls should:

  • Reflect sensitivity and legal obligations
  • Prevent unauthorised viewing, modification, or deletion
  • Be reviewed as roles and responsibilities change

Access control supports both security and accountability.

4. Define Retention Requirements

Records should be retained for as long as required — and no longer.

Retention schedules are often based on:

  • Legal or regulatory requirements
  • Contractual obligations
  • Business need and risk

Keeping records indefinitely increases cost and exposure without adding value.

5. Ensure Secure Storage and Handling

Storage arrangements should protect records against:

  • Loss or accidental deletion
  • Damage or degradation
  • Environmental or technical failure

For electronic records, organisations should consider:

  • Technology change and obsolescence
  • Media deterioration
  • Continued ability to retrieve and interpret records
6. Dispose of Records Securely

Once retention periods expire, records should be disposed of securely.

Disposal should:

  • Prevent recovery or reconstruction
  • Be appropriate to the record’s sensitivity
  • Be documented where required

Failure to dispose of records is as much a risk as disposing of them too early.

7. Maintain Chain of Custody Where Required

For certain records, particularly those with legal or evidential value, organisations may need to:

  • Track handling and access
  • Preserve provenance and context
  • Demonstrate control over the record lifecycle

This supports defensibility if records are challenged.

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

Records management requirements vary widely.

Annex A 5.33 recognises that:

  • Record types and volumes change over time
  • Legal and societal expectations evolve
  • Technology affects how records are stored and retrieved

The control allows flexibility, but expects organisations to apply structure, consistency, and intent.

Common Challenges and How to Overcome Them

  • Unclear definition of what constitutes a record
  • Agree and document record categories relevant to the organisation
  • Focusing only on storage, not integrity
  • Protect records against unauthorised change
  • Keeping records indefinitely “just in case”
  • Apply defined retention and disposal rules
  • Inability to retrieve records when needed
  • Ensure records remain usable and accessible over time

Records fail most often through neglect, not attack.

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 5.33 is about preserving trust in organisational evidence.

When records are protected effectively:

  • Legal and regulatory obligations are easier to meet
  • Decisions are defensible
  • Disputes are easier to resolve
  • Operational confidence improves

Records are only valuable if they can be trusted.
Annex A 5.33 ensures organisations protect that trust deliberately and consistently.

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