ISO 27002:2022, Control 5.33 – Protection of Records

ISO 27002:2022 Revised Controls

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Records are a nebulous concept that some organisations struggle to classify and manage, for compliance purposes.

Records, within the scope of ICT, are another term for the data and information an organisation retains and/or uses to carry out its day to day business activities, including (but not limited to):

  1. Individual events
  2. Transactions
  3. Work processes
  4. Activities
  5. Functions

ISO defines records in the scope of their standards as “any set of information, regardless of its structure or form”, including “a document, a collection of data or other types of information which are created, captured and managed in the course of business”, including a record’s metadata.

Purpose of Control 5.33

Any organisation has an obligation to ensure that the data it holds – including but not limited to any persons, financial information or areas of operation – is kept safe and secure, and internal procedures remain compliant with all prevailing requirements.

Control 5.33 deals with the protection of business records against 5 major events:

  1. Loss
  2. Destruction
  3. Falsification
  4. Unauthorised access
  5. Unauthorised release or publication

Attributes Table

Control 5.33 is a preventive control that maintains risk by creating guidelines and procedures – including retention schedules – that fulfil an organisation’s legal, statutory, regulatory and contractual requirements relating to the protection and availability of any records that it holds.

Control TypeInformation Security PropertiesCybersecurity ConceptsOperational CapabilitiesSecurity Domains
#Preventive#Confidentiality
#Integrity
#Availability
#Identify
#Protect
#Legal and Compliance
#Asset Management
#Information Protection
#Defence
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General Guidance on Control 5.33

Control 5.33 acknowledges that an organisation’s needs are fluid when it comes to the amount and type of records that are required to do business from one day to the next.

As such, Control 5.33 categorises record management into 4 main attributes:

  1. Authenticity
  2. Reliability
  3. Integrity
  4. Useability

Within the scope of these attributes, Control 5.33 asks organisations to:

  1. Draft and publish guidelines that deal with four main functions, alongside topic-specific policies that caters to the underlying nature of the records in question:

    a) Record storage
    b) Record handling chain of custody
    c) Record disposal
    d) Preventing manipulation
  2. Maintain a functional records retention schedule that clearly outlines the length of time that records of differing types should be retained, relating to their individual business function.
  3. Create storage and handling procedures that take into account:

    a) any prevailing laws that deal with commercial record keeping
    b) “community and societal” expectations of how an organisation should handle its records
  4. Implement procedures that destroy records in a safe and appropriate manner the moment they’re not needed (after leaving the retention period).
  5. Classify records for protection (including appropriate retention periods and storage media used) based on their security risk, and various types, including (but not limited to):

    a) Accounting records
    b) Business transactions
    c) Personnel records
    d) Legal records
  6. Ensure that any storage procedures cater for an acceptable timeframe for retrieval, should the organisation be asked to produce them by a third party, or for internal use.
  7. Where electronic media is used to store records, consider and mitigate the possibility of access to or retrieval of records being inhibited by technological amendments, including the retention of cryptographic information (see Control 8.24).
  8. Adhere to manufacturer guidelines when storing or handling records on or via electronic media, including adequate consideration for the natural deterioration of said media.

Changes and Differences from ISO 27002:2013

27002:2022-5.33 replaces 27002:2013-18.1.3 (Protection of records), with various additions in the form of individual guidance points and general processes that need to be adhered to.

In the 2022 control, ISO acknowledge the importance of defining what constitutes a business record. 27002:2022-5.33 contains numerous examples of what ISO considers a record to be (see above), that are absent from 27002:2013-18.1.3.

Control 5.33 also focuses an organisation’s attention on two main guidance points that aren’t contained in its 2013 counterpart (guidelines 1 and 2 above), which in turn form the basis of an organisation’s record policy – in particular, a retention schedule that dictates how long records should be kept for, and any media-specific requirements.

Metadata has also made an appearance in records management for the first time. 27002:2013-18.1.3 contains no mention of it, whereas 27002:2022-5.33 considers it to be an “essential component”.

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New Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
5.7NewThreat intelligence
5.23NewInformation security for use of cloud services
5.30NewICT readiness for business continuity
7.4NewPhysical security monitoring
8.9NewConfiguration management
8.10NewInformation deletion
8.11NewData masking
8.12NewData leakage prevention
8.16NewMonitoring activities
8.23NewWeb filtering
8.28NewSecure coding

Organisational Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
5.105.1.1, 05.1.2Policies for information security
5.206.1.1Information security roles and responsibilities
5.306.1.2Segregation of duties
5.407.2.1Management responsibilities
5.506.1.3Contact with authorities
5.606.1.4Contact with special interest groups
5.7NewThreat intelligence
5.806.1.5, 14.1.1Information security in project management
5.908.1.1, 08.1.2Inventory of information and other associated assets
5.1008.1.3, 08.2.3Acceptable use of information and other associated assets
5.1108.1.4Return of assets
5.12 08.2.1Classification of information
5.1308.2.2Labelling of information
5.1413.2.1, 13.2.2, 13.2.3Information transfer
5.1509.1.1, 09.1.2Access control
5.1609.2.1Identity management
5.17 09.2.4, 09.3.1, 09.4.3Authentication information
5.1809.2.2, 09.2.5, 09.2.6Access rights
5.1915.1.1Information security in supplier relationships
5.2015.1.2Addressing information security within supplier agreements
5.2115.1.3Managing information security in the ICT supply chain
5.2215.2.1, 15.2.2Monitoring, review and change management of supplier services
5.23NewInformation security for use of cloud services
5.2416.1.1Information security incident management planning and preparation
5.2516.1.4Assessment and decision on information security events
5.2616.1.5Response to information security incidents
5.2716.1.6Learning from information security incidents
5.2816.1.7Collection of evidence
5.2917.1.1, 17.1.2, 17.1.3Information security during disruption
5.30NewICT readiness for business continuity
5.3118.1.1, 18.1.5Legal, statutory, regulatory and contractual requirements
5.3218.1.2Intellectual property rights
5.3318.1.3Protection of records
5.3418.1.4Privacy and protection of PII
5.3518.2.1Independent review of information security
5.3618.2.2, 18.2.3Compliance with policies, rules and standards for information security
5.3712.1.1Documented operating procedures

People Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
6.107.1.1Screening
6.207.1.2Terms and conditions of employment
6.307.2.2Information security awareness, education and training
6.407.2.3Disciplinary process
6.507.3.1Responsibilities after termination or change of employment
6.613.2.4Confidentiality or non-disclosure agreements
6.706.2.2Remote working
6.816.1.2, 16.1.3Information security event reporting

Physical Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
7.111.1.1Physical security perimeters
7.211.1.2, 11.1.6Physical entry
7.311.1.3Securing offices, rooms and facilities
7.4NewPhysical security monitoring
7.511.1.4Protecting against physical and environmental threats
7.611.1.5Working in secure areas
7.711.2.9Clear desk and clear screen
7.811.2.1Equipment siting and protection
7.911.2.6Security of assets off-premises
7.1008.3.1, 08.3.2, 08.3.3, 11.2.5Storage media
7.1111.2.2Supporting utilities
7.1211.2.3Cabling security
7.1311.2.4Equipment maintenance
7.1411.2.7Secure disposal or re-use of equipment

Technological Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
8.106.2.1, 11.2.8User endpoint devices
8.209.2.3Privileged access rights
8.309.4.1Information access restriction
8.409.4.5Access to source code
8.509.4.2Secure authentication
8.612.1.3Capacity management
8.712.2.1Protection against malware
8.812.6.1, 18.2.3Management of technical vulnerabilities
8.9NewConfiguration management
8.10NewInformation deletion
8.11NewData masking
8.12NewData leakage prevention
8.1312.3.1Information backup
8.1417.2.1Redundancy of information processing facilities
8.1512.4.1, 12.4.2, 12.4.3Logging
8.16NewMonitoring activities
8.1712.4.4Clock synchronization
8.1809.4.4Use of privileged utility programs
8.1912.5.1, 12.6.2Installation of software on operational systems
8.2013.1.1Networks security
8.2113.1.2Security of network services
8.2213.1.3Segregation of networks
8.23NewWeb filtering
8.2410.1.1, 10.1.2Use of cryptography
8.2514.2.1Secure development life cycle
8.2614.1.2, 14.1.3Application security requirements
8.2714.2.5Secure system architecture and engineering principles
8.28NewSecure coding
8.2914.2.8, 14.2.9Security testing in development and acceptance
8.3014.2.7Outsourced development
8.3112.1.4, 14.2.6Separation of development, test and production environments
8.3212.1.2, 14.2.2, 14.2.3, 14.2.4Change management
8.3314.3.1Test information
8.3412.7.1Protection of information systems during audit testing
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