ISO 27001:2022 Annex A 8.24 – Use of Cryptography Explained

Encryption is not a “nice to have”.
Used properly, it is one of the most effective controls for protecting information.
Used poorly, it creates risk, fragility, and false confidence.

Annex A 8.24 exists to ensure organisations use cryptography in a controlled, consistent, and risk-appropriate way, protecting information confidentiality, integrity, authenticity, and availability.

This control is about governance of cryptography, not just switching encryption on.

ISO 27001

Quick Guide: Annex A 8.24 at a Glance

Annex A 8.24 of ISO 27001:2022 focuses on the use of cryptographic techniques.

At a practical level, this means:

  • Defining when and how cryptography is used
  • Selecting appropriate cryptographic methods based on risk
  • Managing cryptographic keys securely
  • Considering legal, regulatory, and contractual constraints
  • Assigning clear responsibility for cryptographic controls

The control does not mandate specific algorithms or products. It expects clear rules, ownership, and disciplined implementation.

In-Depth Guide to Annex A 8.24

What Is Annex A 8.24 and Why Does It Matter?

Cryptography is used to:

  • Protect data in transit
  • Protect data at rest
  • Authenticate users and systems
  • Ensure integrity of information
  • Support non-repudiation

However, cryptography introduces risk when:

  • Algorithms are weak or outdated
  • Keys are poorly managed
  • Encryption is applied inconsistently
  • Legal or export restrictions are ignored
  • Encrypted data becomes unrecoverable

Annex A 8.24 ensures organisations use cryptography deliberately and safely, rather than relying on ad hoc or default implementations.

This control replaces ISO 27001:2013 Annex A 10.1.1 and 10.1.2, consolidating cryptographic use and key management into a single, clearer requirement.

How to Implement Annex A 8.24 Effectively

A pragmatic approach to Annex A 8.24 typically includes the following elements.

1. Define a Cryptography Policy

Organisations should establish a policy covering:

  • When cryptography is required
  • What it is used to protect
  • Approved cryptographic approaches
  • Roles and responsibilities

The policy should align with:

  • Information classification
  • Risk assessment outcomes
  • Legal and regulatory obligations

Cryptography without policy quickly becomes inconsistent.

2. Identify Where Cryptography Is Required

Cryptography should be applied where it supports security objectives, such as:

  • Protecting sensitive data in transit over networks
  • Protecting data stored on devices, media, or cloud platforms
  • Authenticating systems, users, or services
  • Protecting backups and archives

Not all information requires the same level of cryptographic protection.

3. Select Cryptographic Methods Based on Risk

Organisations should consider:

  • Sensitivity of the information
  • Threat environment
  • Likelihood and impact of compromise

This informs:

  • Choice of algorithm
  • Key length and strength
  • Whether encryption, signing, or hashing is appropriate

Strong cryptography applied in the wrong place is still ineffective.

4. Establish Clear Rules for Cryptographic Use

Annex A 8.24 expects organisations to define and enforce rules covering:

  • Approved algorithms and standards
  • Acceptable cryptographic implementations
  • Prohibited or deprecated techniques

This prevents:

  • Use of weak or obsolete encryption
  • Inconsistent implementations across systems
  • Vendor-specific shortcuts that increase risk

Standards reduce variability — and variability is risk.

5. Implement Robust Key Management

Key management is central to Annex A 8.24.

Organisations should define processes for:

  • Key generation
  • Key storage and protection
  • Key distribution and activation
  • Key rotation and expiry
  • Revocation of compromised keys
  • Secure destruction of keys

Poor key management undermines even the strongest encryption.

6. Protect Cryptographic Keys Appropriately

Keys should be protected against:

  • Unauthorised access
  • Loss or corruption
  • Accidental disclosure

Controls may include:

  • Access restriction
  • Hardware or software protection mechanisms
  • Separation of duties

Keys often require stronger protection than the data they protect.

7. Define Roles and Responsibilities

Annex A 8.24 expects clarity on:

  • Who approves cryptographic standards
  • Who manages cryptographic keys
  • Who is responsible for implementation and oversight

Cryptography without ownership degrades rapidly.

8. Consider Impact on Other Security Controls

Encryption can affect:

  • Malware inspection
  • Content monitoring
  • Data loss prevention

Organisations should ensure:

  • Compensating controls exist where visibility is reduced
  • Encryption does not unintentionally disable other protections

Security controls should work together, not blind each other.

9. Address Legal, Regulatory, and Contractual Constraints

Cryptography is subject to:

  • Export and import controls
  • National legislation
  • Sector-specific regulation

Organisations should consider:

  • Cross-border data transfer implications
  • Lawful access and disclosure requirements
  • Contractual obligations with suppliers and customers

Ignoring legal constraints creates compliance risk.

10. Manage Use of External Cryptographic Services

Where cryptography is provided by third parties, organisations should ensure:

  • Security responsibilities are defined
  • Key ownership and access are clear
  • Continuity and availability are considered

Outsourced cryptography is still organisational risk.

11. Review Cryptographic Controls Regularly

Cryptographic effectiveness changes over time.

Organisations should periodically review:

  • Algorithms and key lengths
  • Compliance with current standards
  • Emerging vulnerabilities or weaknesses

Cryptography that was strong yesterday may be weak tomorrow.

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 8.24 does not require:

  • Encryption everywhere
  • Constant algorithm changes
  • Specialist cryptographic expertise for all staff

It does require organisations to:

  • Apply cryptography where it matters
  • Manage keys properly
  • Understand the consequences of encrypted data

Lost keys can be as damaging as stolen data.

Common Challenges and How to Overcome Them

  • Encryption enabled without key management
  • Define and enforce end-to-end key lifecycle controls
  • Different systems using inconsistent standards
  • Establish approved cryptographic standards
  • Keys accessible to too many people
  • Restrict and monitor key access
  • Ignoring legal restrictions on encryption
  • Assess regulatory and contractual constraints early

Cryptography fails most often through governance gaps.

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 8.24 is about using cryptography as a controlled security capability, not a checkbox.

When cryptography is implemented effectively:

  • Confidentiality is preserved
  • Integrity can be verified
  • Authentication is stronger
  • Trust in information systems increases

Encryption protects information.
Governance protects encryption.

Annex A 8.24 ensures organisations do both.

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