ISO 27002:2022 – Control 5.33 – Protection of Records

ISO 27002:2022 Control 5.33 – Best Practices for Record Protection

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.

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”.

New ISO 27002 Controls

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