ISO 27001 A.5.14: Information transfer
Information is at its most vulnerable when it is moving. Whether someone is emailing a spreadsheet, uploading files to a client portal, shipping a hard drive, or even discussing sensitive matters over the phone, the risk of interception, modification, or loss is real. This control ensures you have clear rules for how information gets transferred securely.
Work through the ISO 27001 assessment, record supporting evidence and review the gaps in your answers.
Requirement summary
Information transfer rules, procedures, or agreements shall be in place for all types of transfer facilities within the organization and between the organization and other parties.
Check the source wording and scope in ISO/IEC 27001:2022. The guidance below explains how to approach a review.
In Plain Language
The rules need to account for the classification level of the information and the transfer method being used. Sending an internal memo is not the same as transferring customer financial data to a third-party auditor. Each scenario needs defined security requirements.
For external transfers, you also need formal agreements with the other party covering security requirements, responsibilities, and what happens if something goes wrong. Auditors will look for evidence that you are not just relying on people to "do the right thing" - you need documented procedures and technical controls backing them up.
How to Implement
Write an information transfer policy covering every method your organisation uses. For each method, define security requirements based on classification level.
For electronic transfers, set minimum encryption standards. Enforce TLS for email (opportunistic TLS is not enough for sensitive data), use SFTP or encrypted web portals for file transfers, and require TLS 1.2 or higher for API communications. Ban unencrypted methods for anything classified as confidential or above.
For physical media, define packaging and shipping requirements. Sensitive media needs tamper-evident packaging, tracked couriers, and verified delivery. Encrypt data on removable media before shipping and send the encryption key through a separate channel.
Set up formal information transfer agreements with external parties. Cover what information will be transferred, which methods are permitted, security requirements during and after transfer, who is responsible for protection, breach notification obligations, and data retention and disposal rules.
Enforce the policy with technical controls. Use email DLP to catch sensitive information going to unauthorised recipients. Configure file sharing platforms to require authentication and encryption. Block consumer file sharing services and personal email for business use. Provide approved secure alternatives so people are not tempted to work around the rules.
Log sensitive transfers, especially those involving external parties. Record the date, parties, transfer method, content description, and delivery confirmation. Review logs periodically to spot policy violations or unusual patterns.
Evidence to review
- Documented information transfer policy covering all transfer methods and classification levels
- Information transfer agreements with external parties
- Technical controls enforcing transfer security such as encryption and DLP configurations
- Logs of sensitive information transfers with confirmation of receipt
- Records of approved secure transfer tools and channels
Common Mistakes
- No formal policy governing information transfer methods and requirements
- Sensitive information is transferred via unencrypted email or consumer file sharing services
- External transfer agreements do not specify security requirements
- No logging or tracking of sensitive information transfers
- Personnel use personal email or unauthorized cloud services for business transfers
Related Controls Across Frameworks
| Framework | Control ID | Relationship |
|---|---|---|
| SOC 2 | SOC 2 CC6.7: Logical and Physical Access - Transmission of Data | Related |
| GDPR | GDPR Art.46: Transfers Subject to Appropriate Safeguards | Related |
| GDPR | GDPR Art.32: Security of Processing | Related |
| NIS2 | NIS2 Art.21(2)(d): Supply Chain Security | Related |
Frequently Asked Questions
What encryption should we use for email transfers?
Do we need transfer agreements with every external party we share information with?
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Work through the ISO 27001 assessment, record supporting evidence and review the gaps in your answers.
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