ISO 27001:2022 Annex A 7.10 – Storage Media Explained

Storage media is small, portable, and easy to forget.
That is exactly why it represents one of the highest physical data loss risks.

Annex A 7.10 exists to ensure organisations protect information stored on storage media throughout its entire lifecycle, from acquisition and use through to reuse, transfer, and disposal.

This control is about preventing silent data loss and uncontrolled disclosure.

ISO 27001

Quick Guide: Annex A 7.10 at a Glance

Annex A 7.10 of ISO 27001:2022 focuses on secure management of storage media.

At a practical level, this means:

  • Managing storage media based on information sensitivity
  • Controlling use of removable and fixed media
  • Protecting media from loss, theft, damage, or malware
  • Ensuring secure reuse and disposal
  • Reducing uncontrolled copying and transfer of information

The control applies to both digital and physical media, including removable media, fixed disks, backups, and paper records.

In-Depth Guide to Annex A 7.10

What Is Annex A 7.10 and Why Does It Matter?

Storage media frequently contributes to serious incidents because it is:

  • Portable
  • Easy to duplicate
  • Often poorly tracked
  • Frequently overlooked during disposal

Common risks include:

  • Lost or stolen USB drives
  • Malware introduced via removable media
  • Unauthorised copying of sensitive data
  • Data exposure through reused or discarded equipment

Annex A 7.10 ensures organisations do not treat storage media as a convenience tool, but as a controlled information asset.

The 2022 version consolidates multiple legacy controls into a single, lifecycle-focused control.

How to Implement Annex A 7.10 Effectively

A pragmatic approach to Annex A 7.10 typically includes the following elements.

1. Define a Storage Media Management Policy

Organisations should define rules covering:

  • Acquisition and use of storage media
  • Authorisation requirements
  • Handling, storage, and transport
  • Reuse and disposal

A topic-specific policy for removable media is explicitly expected in ISO 27001:2022.

2. Control Use of Removable Storage Media

Removable media introduces the highest risk.

Organisations typically consider:

  • Restricting use unless there is a defined business need
  • Applying authorisation for off-site removal
  • Keeping records of removable media use where risk justifies it

Uncontrolled removable media use is a common audit and incident finding.

3. Protect Storage Media Based on Information Classification

Storage media should be protected in line with the sensitivity of the information it holds.

This may include:

  • Secure storage when not in use
  • Encryption where confidentiality is critical
  • Environmental and physical protection

Protection should follow the data, not the device type.

4. Prevent Malware and Unauthorised Transfer

Storage media can introduce malicious code.

Controls may include:

  • Monitoring transfers to and from storage media
  • Restricting ports or interfaces where not required
  • Applying scanning or detection controls

Storage media should not bypass other security controls.

5. Maintain Integrity and Availability of Information

Storage media degrades over time.

Organisations should consider:

  • Replacing media before failure
  • Maintaining multiple copies of important information
  • Avoiding single points of failure

Data loss due to media degradation is still common.

6. Secure Transfer of Storage Media

When storage media or physical documents are transferred:

  • Risk of interception or loss should be considered
  • Couriers or transfer methods should be selected carefully
  • Packaging and handling should reflect sensitivity

Physical transfer is often underestimated compared to electronic transfer.

7. Secure Reuse of Storage Media

Before reuse within the organisation:

  • Sensitive information should be irreversibly removed
  • Media should be reformatted or securely wiped
  • Reuse should be authorised

Reuse without sanitisation is a frequent source of accidental disclosure.

8. Secure Disposal of Storage Media

When storage media is no longer required:

  • Disposal methods should reflect data sensitivity
  • Media containing sensitive information should be destroyed securely
  • Disposal activities should be recorded

Combining multiple disposed media can increase cumulative risk.

9. Manage Third-Party Disposal Carefully

If external disposal services are used:

  • Due diligence should be performed
  • Contractual controls should be in place
  • Disposal activities should be verifiable

Disposal failures often occur outside organisational control.

10. Address Damaged or Faulty Media

Damaged media may still contain recoverable information.

Organisations should assess:

  • Whether repair is appropriate
  • Whether destruction is required
  • Risk of data recovery

Physical damage does not guarantee data loss.

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

Annex A 7.10 does not require:

  • Banning all removable media
  • Complex tracking of every device
  • Identical controls for all media

It does require organisations to:

  • Apply lifecycle thinking
  • Treat storage media as an information risk
  • Avoid unmanaged reuse or disposal

Media-related incidents are usually quiet — and discovered too late.

Common Challenges and How to Overcome Them

  • Uncontrolled USB and removable media use
  • Restrict and authorise based on business need
  • Assuming disposal equals data destruction
  • Apply secure wiping or physical destruction
  • Ignoring paper and physical records
  • Apply storage media controls consistently
  • Poor oversight of third-party disposal
  • Perform due diligence and maintain records

Storage media failures rarely involve attackers — just oversight.

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 7.10 is about controlling information in its most portable form.

When storage media is managed effectively:

  • Data loss risk is reduced
  • Malware introduction is controlled
  • Confidentiality is preserved beyond system boundaries
  • Disposal does not become disclosure

Data does not disappear when systems change.
Annex A 7.10 ensures it is controlled until the very end.

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