ISO 27001:2022 Annex A Control 5.12: Classification of Information
Annex A control 5.12 of the 2022 version of the ISO 27001 standard can be mapped to ISO 27001:2013 Annex A 8.2.1.

Classifying information is a fundamental process that allows organisations to group their assets into relevant categories based on their level of sensitivity and required protection levels. As stated in Annex A 5.12, information needs to be classified based on criteria such as legal requirements, criticality and sensitivity.
Any classification should be reflective of the specific business activity of the organisation without impeding or complicating it. Information designed for public consumption should be marked as such, while sensitive data must be subject to a higher level of security.
This is the purpose of Annex A 5.12 – to ensure that organisational assets are protected by the correct classification of information.
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Annex A 5.12 at a glance
- Purpose: ensure organisational assets are protected by the correct classification of information.
- Classify information by legal requirements, criticality and sensitivity.
- It is a preventative control that guards against both over- and under-classification.
- Weigh confidentiality, integrity and availability against the business need to use data.
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Why is Annex A 5.12 important?
This annex is a preventative control designed to help organisations more easily identify risks by determining the correct level of protection for each information asset, based on factors like importance and sensitivity.
Annex A 5.12 cautions against the over or under classification of information. Businesses must consider availability, confidentiality, and integrity when assigning assets to their representative categories. This helps to ensure that the scheme of classification balances the need for information with the security requirements.
Taking responsibility
It is the responsibility of the asset owners to make sure that the classification scheme is implemented correctly. Those with pertinent information assets are held accountable through Annex A 5.12, asking asset owners to consider the business needs and potential impact of compromised information.
To implement the Annex successfully, organisations need to take a topical approach, considering each business unit’s specific information needs, and evaluating the level of sensitivity and criticality.
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Five criteria for a classification scheme
- Set a topic-specific policy that reflects specific business needs.
- Prioritise legal obligations over the organisation's internal classification.
- Review and update classifications as value, importance and sensitivity change.
- Align terminology with other organisations for consistent interpretation when sharing information.
- Ensure organisational consistency so every department shares the same understanding.
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The criteria of Annex A 5.12
Annex A Control 5.12 outlines how organisations should follow key criteria when implementing a classification scheme. These are:
Establishing a topic-specific policy and addressing specific business needs
The Annex mandates that organisations stick to topic-specific policies and that the classification scheme and levels should consider specific business needs when classifying information assets.
Organisations must balance their specific business needs for the availability and use of data with the requirement for maintaining security and confidentiality.
Considering legal obligations
Certain laws may require organisations to emphasise safeguarding the integrity, confidentiality, and availability of information. As such, legal obligations must be prioritised over the organisation’s internal classification when categorising assets.
A risk-based approach allows businesses to assess the potential impact of a security breach or compromise on information assets. This allows for security measures to be prioritised.
Regularly updating and reviewing the classification
Control 5.12 recognises that the value, importance, and sensitivity of information can change over time, and organisations need to review their classifications regularly to make any necessary updates.
It is also essential to consult with other organisations to share information and resolve any disparities.
Recognising the distinct levels, standards, and terminology used by different organisations
Organisations may diverge in information classification, but this can lead to potential risks when information is exchanged. As such, organisations have a responsibility to collaborate and work together to establish uniformity in information classification. This can help to promote consistent interpretation of classification levels.
Organisational consistency
Every department must have a shared understanding of the classification levels and protocols used, in order to ensure uniformity of classifications across the entire organisation.
Implementing the right classification system
Of course, there isn’t a one-size-fits-all classification system that can be applied to every organisation’s specific needs. Organisations have the flexibility to establish and define their classification levels that work for their requirements. However, Annex 5.12 illustrates that an effective classification scheme separates information which:
| Impact if disclosed | Severity |
|---|---|
| Causes no harm | None |
| Minor reputational damage or minor operational impact | Minor |
| Significant short-term impact on operations or business objectives | Significant |
| Seriously impacts long-term business objectives or risks the organisation’s survival | Severe |
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What changed from ISO 27001:2013
- The 2013 version had no requirement for consistency when classifications are shared between organisations.
- ISO 27001:2022 requires organisations to collaborate for uniformity in classification and interpretation.
- 2022 also explicitly requires topic-specific policies.
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How has control 5.12 changed from ISO 27001:2013?
In the previous version of ISO 27001, there was no mention of the need for consistency in classification systems when information is shared between organisations. ISO 27001:2022 stipulates that organisations collaborate with their counterparts to ensure uniformity in the classification and understanding of information assets.
The updated version of the standard also explicitly requires organisations to develop policies tailored to specific topics.
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In Hicomply's experience
In our experience, classification only holds up when it is applied consistently and kept current — a scheme that lives in a spreadsheet quickly drifts out of date as assets change. Treat it as a continuous control across the whole business, review it whenever the value or sensitivity of information shifts, and reuse the same asset inventory across every framework you run rather than rebuilding it each time.
Our ISO 27001 Hub and free compliance tools are a practical place to start.
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