ISO 27001:2022 Annex A 8.33 – Test Information Explained

Test environments are essential.
Using real data in them, without control, is one of the fastest ways to create a breach.

Annex A 8.33 exists to ensure organisations select, protect, use, and dispose of test information appropriately, reducing the risk of unauthorised access, data leakage, and misuse while still enabling effective testing.

This control is about protecting information outside production, where discipline often slips.

ISO 27001

Quick Guide: Annex A 8.33 at a Glance

Annex A 8.33 focuses on test information used in development, testing, and acceptance environments.

In practice, this includes:

  • Selecting appropriate information for testing
  • Avoiding use of sensitive or live data where possible
  • Applying controls when real data is required
  • Restricting access to test information
  • Recording and monitoring use of sensitive test data
  • Securely removing test information after use

The control does not prevent testing.
It ensures test data does not become an unmanaged security liability.

In-Depth Guidance on Annex A 8.33

Why Test Information Is a Security Risk

Test environments often have:

  • Weaker access controls
  • Broader user access
  • Reduced monitoring
  • Less rigorous configuration

When real or sensitive information is introduced into these environments:

  • Confidentiality risk increases significantly
  • Data protection obligations may be breached
  • Attackers target them as “soft entry points”
  • Insider misuse becomes easier

Annex A 8.33 ensures organisations apply the same level of thought to test data as they do to live data, even if the controls differ.

This control replaces ISO 27001:2013 Annex A 14.3.1, with clearer emphasis on data masking and removal.

Practical Implementation Guidance

1. Select Test Information Deliberately

Organisations should consider what information is genuinely required to achieve reliable test results.

Where possible:

  • Synthetic or anonymised data is preferable
  • Minimal datasets should be used
  • Sensitive information should be avoided

More data does not equal better testing.

2. Avoid Using Production Data by Default

Live or production data should not automatically be used for testing.

Where production data is proposed:

  • The need should be justified
  • Approval should be obtained
  • Risks should be understood and accepted

Uncontrolled copying of live data is a common compliance failure.

3. Protect Test Information Appropriately

When sensitive information is used in test environments, organisations should consider controls such as:

  • Data masking
  • Data anonymisation or pseudonymisation
  • Removal of unnecessary attributes
  • Reduced dataset size

The objective is to retain test value while reducing exposure.

4. Apply Access Controls to Test Environments

Test environments should not be treated as open systems.

Access should be:

  • Restricted to authorised users
  • Aligned with role and responsibility
  • Reviewed periodically

Default credentials and shared accounts increase risk significantly.

5. Record and Monitor Use of Sensitive Test Data

Where sensitive information is used:

  • Copying, access, and use should be logged
  • Activities should be traceable
  • An audit trail should be maintained

Visibility supports accountability and investigation if issues arise.

6. Separate Test Data Handling From Production Processes

Test information handling should be:

  • Clearly distinguished from live operations
  • Governed by defined procedures

This reduces accidental crossover between environments and controls.

7. Secure Storage of Test Information

Test data should be:

  • Stored securely
  • Protected against unauthorised access
  • Backed up appropriately if required

Lower criticality does not justify poor protection.

8. Remove Test Information After Use

Once testing is complete:

  • Test information should be securely removed
  • Copies should be eliminated
  • Retention should not exceed what is necessary

Old test data is often forgotten — and later discovered during incidents.

9. Include Third Parties and Suppliers

Annex A 8.33 applies equally where:

  • Testing is outsourced
  • Suppliers manage test environments

Suppliers should:

  • Follow agreed test data handling rules
  • Apply equivalent protection
  • Support audit and assurance

External testing does not reduce internal responsibility.

10. Align With Data Protection and Privacy Obligations

Where test data includes personal information:

  • Privacy obligations apply fully
  • Data minimisation principles should be respected
  • Retention and deletion should be controlled

Test environments are not exempt from regulation.

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

  • Copying full production databases into test environments
  • Use anonymised or masked data sets
  • Weak access controls in non-production systems
  • Apply role-based access and monitoring
  • Test data retained indefinitely
  • Remove data once testing is complete
  • No audit trail for test data use
  • Log and review access and copying activity

Most test data incidents are caused by convenience over control.

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 8.33 is about preventing non-production environments from becoming high-risk blind spots.

When test information is managed effectively:

  • Confidentiality risk reduces
  • Data protection compliance improves
  • Development and testing remain effective
  • Audit and assurance outcomes strengthen

Test environments are essential.
Uncontrolled test data is not.

Annex A 8.33 ensures organisations test safely, not carelessly.

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