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ISO/IEC 27001:2022 Annex A Control 5.14 exists to address this exact problem. It requires organisations to ensure that information is protected whenever it is transferred, regardless of format, medium, or destination. This control shifts security thinking beyond static storage and access, focusing instead on how information behaves in motion.
This article provides a complete, audit-ready explanation of Annex A 5.14—what it requires, how to implement it correctly, how auditors assess it, and how it integrates with the wider Information Security Management System (ISMS).
Understanding ISO 27001 Annex A 5.14 — Information Transfer
Annex A 5.14 is formally titled “Information Transfer” in ISO/IEC 27001:2022. Its purpose is to ensure that information maintains its confidentiality, integrity, and availability while being transferred internally or externally.
Unlike access control or asset management controls, Annex A 5.14 does not focus on who can access information or how it is stored. Instead, it focuses on what happens when information moves—a phase where data is frequently exposed to interception, leakage, corruption, or misuse.
This control recognises that many serious security incidents occur not because systems are poorly secured, but because information is transferred without appropriate safeguards.
What ISO 27001 Requires Under Annex A 5.14
ISO 27001 requires organisations to establish rules, procedures, and safeguards for the secure transfer of information. These rules must apply to all relevant forms of transfer, both internal and external.
At a minimum, organisations must:
- Define how information may be transferred
- Protect information during transfer
- Ensure recipients are authorised
- Prevent unauthorised access, alteration, or loss
- Maintain accountability and traceability
- Apply risk-based safeguards proportional to sensitivity
Annex A 5.14 does not prescribe specific technologies or tools. Instead, it requires organisations to determine appropriate controls based on their risk assessment, business context, and legal obligations.
Types of Information Transfer Covered by Annex A 5.14
One of the most important aspects of Annex A 5.14 is its broad scope. It applies to all forms of information transfer, not just digital data.
Electronic Information Transfer
Electronic transfers are the most common—and often the most misunderstood. These include:
- Email attachments
- Cloud file sharing
- Secure portals
- APIs and system integrations
- Instant messaging platforms
- File transfer protocols (SFTP, FTPS)
- Collaboration tools
For electronic transfers, organisations must consider encryption, authentication, recipient validation, malware protection, and monitoring.
Physical Information Transfer
Physical transfers involve tangible media and assets, including:
- USB drives
- External hard drives
- Backup tapes
- Printed documents
- Laptops or devices containing data
ISO 27001 requires organisations to ensure physical transfers are logged, authorised, tracked, and protected against loss, theft, or tampering.
Verbal Information Transfer
Verbal transfer is often overlooked but explicitly included under Annex A 5.14. This includes:
- Meetings
- Phone calls
- Video conferences
- Informal discussions
- On-site conversations
Sensitive information must not be discussed in insecure environments, and organisations must define when and how verbal information may be shared safely.
Why Information Transfer Is a High-Risk Activity
Information transfer represents one of the most vulnerable moments in the information lifecycle. Even organisations with strong perimeter security can experience breaches during data movement.
Common risks include:
- Sending information to the wrong recipient
- Interception during transmission
- Use of unsecured communication channels
- Loss of physical media
- Inadequate third-party protections
- Lack of traceability or accountability
Annex A 5.14 exists to ensure these risks are identified, assessed, and controlled rather than left to individual discretion.
Information Transfer and the CIA Triad
Annex A 5.14 directly supports the three foundational principles of ISO 27001.
Confidentiality
Controls ensure that information is accessible only to authorised recipients during transfer. Encryption, authentication, secure channels, and recipient validation are key confidentiality safeguards.
Integrity
Information must not be altered, corrupted, or manipulated while in transit. Integrity controls include checksums, secure protocols, version control, and logging.
Availability
Transfers must not compromise availability. Controls must ensure information reaches its destination reliably and remains accessible to authorised users.
Policies and Procedures Required for Annex A 5.14
To comply with Annex A 5.14, organisations must document and implement clear, enforceable rules governing information transfer.
Information Transfer Policy
An information transfer policy defines:
- Approved transfer methods
- Prohibited transfer methods
- Classification-based handling rules
- Encryption requirements
- Third-party transfer conditions
- Responsibilities and approvals
- Incident reporting requirements
The policy must apply to employees, contractors, and relevant third parties.
Supporting Procedures
Procedures operationalise the policy and explain how secure transfer occurs in practice. These may include:
- Secure email procedures
- File sharing and collaboration rules
- Physical media handling processes
- Secure disposal after transfer
- Incident escalation procedures
- Third-party onboarding requirements
Auditors expect policies and procedures to align with actual practices, not theoretical controls.
Secure Information Transfer Controls in Practice
Annex A 5.14 allows flexibility in how organisations implement safeguards, provided they are risk-based and effective.
Encryption and Secure Channels
Encryption is a core safeguard for electronic transfers, particularly for sensitive or regulated data. Secure transfer channels may include:
- Encrypted email gateways
- Secure file transfer services
- VPN-protected connections
- TLS-secured APIs
Encryption decisions should be documented and aligned with risk classification.
Authentication and Recipient Validation
Organisations must ensure that information is sent only to authorised recipients. This includes:
- Identity verification
- Role-based access
- Multi-factor authentication
- Recipient approval workflows
Sending information to the wrong party is a common audit finding and breach cause.
Third-Party Information Transfer
Where information is transferred to external parties, organisations must ensure:
- Contractual security obligations exist
- Transfer methods are agreed and documented
- Responsibilities are clearly defined
- Monitoring and review mechanisms are in place
Supplier agreements often serve as key evidence for Annex A 5.14 compliance.
Evidence and Audit Expectations for Annex A 5.14
ISO 27001 certification audits focus heavily on evidence, not intent. Auditors assess whether information transfer controls are implemented, followed, and effective.
Typical audit evidence includes:
- Information transfer policies
- Secure transfer procedures
- Training and awareness records
- Encryption configurations
- Transfer logs or records
- Supplier contracts and NDAs
- Incident records related to transfers
Auditors will often interview staff to confirm awareness of secure transfer requirements.
Common Audit Findings for Annex A 5.14
Organisations frequently fail Annex A 5.14 audits due to gaps between policy and practice.
Common nonconformities include:
- Undefined rules for information transfer
- Insecure file sharing practices
- Lack of encryption for sensitive transfers
- No tracking of physical media
- Verbal disclosure of sensitive data in public settings
- Weak supplier controls
These findings typically indicate systemic governance weaknesses rather than isolated errors.
Relationship Between Annex A 5.14 and Other Controls
Annex A 5.14 does not operate in isolation. It works closely with several other ISO 27001 controls.
Relationship With Annex A 5.10 (Acceptable Use)
Acceptable use policies define how assets may be used, while Annex A 5.14 defines how information may be transferred using those assets.
Relationship With Annex A 5.15 (Access Control)
Access control governs who can access information. Annex A 5.14 governs how information moves once access is granted.
Relationship With Incident Management Controls
Improper information transfer often triggers incident response processes. Clear transfer controls reduce incident frequency and severity.
Information Classification and Transfer Rules
Effective information transfer depends on proper classification. Organisations should align transfer rules with information sensitivity.
Typical classification-based rules include:
- Public information: Minimal restrictions
- Internal information: Approved channels only
- Confidential information: Encrypted transfer required
- Restricted information: Strict controls, approvals, and logging
Classification ensures proportional security rather than blanket restrictions.
Verbal Information Transfer Controls
Verbal transfer is frequently underestimated in risk assessments. ISO 27001 expects organisations to manage this risk intentionally.
Controls may include:
- Guidelines for secure discussions
- Restrictions on public conversations
- Use of private meeting spaces
- Secure conferencing platforms
- Awareness training for staff
Auditors increasingly assess verbal information handling, particularly in regulated industries.
Implementing Annex A 5.14 in Cloud and Remote Environments
Modern organisations rely heavily on cloud services and remote work. Annex A 5.14 must be applied in these environments.
Key considerations include:
- Cloud provider security controls
- Shared responsibility models
- Secure collaboration tools
- Remote access safeguards
- Data residency and jurisdiction risks
Information transfer controls must reflect how data flows across cloud platforms and remote users.
Continuous Improvement and Annex A 5.14
Annex A 5.14 is not a one-time implementation. It must be reviewed and improved continuously as part of the ISMS lifecycle.
Improvement activities include:
- Reviewing incidents related to transfer
- Updating policies after near misses
- Enhancing encryption and tooling
- Refining supplier requirements
- Strengthening awareness programmes
These improvements demonstrate maturity and support ISO 27001 Clause 10 requirements.
Practical Example: Annex A 5.14 in Action
A project manager shares sensitive project documentation with an external contractor. Before access is granted:
- The contractor signs a confidentiality agreement
- Access is provided through a secure portal
- Multi-factor authentication is enforced
- Access is time-limited
- Download activity is logged
- Access is revoked after project completion
This scenario demonstrates compliant, auditable information transfer aligned with Annex A 5.14.
Why Annex A 5.14 Is Critical for Modern Organisations
As organisations become more interconnected, information transfer becomes constant. Annex A 5.14 ensures that security does not stop at system boundaries.
This control:
- Reduces data leakage risk
- Protects intellectual property
- Supports regulatory compliance
- Builds trust with partners and customers
- Strengthens overall ISMS maturity
Without effective information transfer controls, even strong access controls and encryption at rest can be undermined.
Final Thoughts on Annex A 5.14
ISO/IEC 27001:2022 Annex A 5.14 addresses one of the most practical and high-risk aspects of information security: how data moves. By defining clear rules, enforcing safeguards, and maintaining evidence, organisations can significantly reduce transfer-related risks.
When implemented correctly, Annex A 5.14 transforms information transfer from an informal activity into a governed, auditable, and secure process—fully aligned with the principles of ISO 27001.
