ISO 27001 A.5.33: Protection of records
Records are not just files sitting on a server - they are evidence. Financial records, audit logs, personnel files, contracts, risk assessments, incident reports - these all need to be protected from loss, tampering, unauthorised access, and accidental destruction for as long as the law or your contracts require.
Work through the ISO 27001 assessment, record supporting evidence and review the gaps in your answers.
Requirement summary
Records shall be protected from loss, destruction, falsification, unauthorized access and unauthorized release in accordance with legal, statutory, regulatory and contractual requirements.
Check the source wording and scope in ISO/IEC 27001:2022. The guidance below explains how to approach a review.
In Plain Language
The retention periods and protection standards are usually dictated by legal and regulatory requirements. You cannot decide to delete financial records after two years because you are running low on storage. And you cannot store sensitive personnel records on an unprotected shared drive.
Auditors will check that you can guarantee the integrity, availability, and confidentiality of records throughout their entire retention period. That includes protection against deliberate tampering, accidental loss, and something people often forget - technology obsolescence making old electronic records unreadable.
How to Implement
Create a records management policy and classification scheme. Identify every type of record your organisation must maintain and the applicable retention requirements. Build a retention schedule covering the record type, the legal or regulatory basis for keeping it, minimum and maximum retention periods, storage location and format, access restrictions, and disposal method.
Choose appropriate storage for different record types. Electronic records belong in managed repositories with access controls, version control, and backup. Use records management systems that enforce retention policies and prevent premature deletion. For anything you need to keep long-term, think carefully about format longevity and plan for migration as technology changes.
Protect records from unauthorised modification. Set access controls that restrict who can create, modify, and delete records. Log all access and changes with audit trails. For critical records, consider write-once storage, digital signatures, or other integrity verification mechanisms. The goal: no one can alter a record without it being detected.
Back up records properly and include records storage in your business continuity plan with appropriate RTOs and RPOs. Keep off-site copies of critical records. For physical records, ensure proper storage conditions - climate control and fire suppression - and consider digitising them for preservation.
Set up secure disposal procedures for when retention periods expire. Use cross-cut shredding for physical records and cryptographic erasure or physical destruction for electronic media. Document every disposal: what was destroyed, when, by whom, and how. Get certificates of destruction where appropriate.
Audit your records management practices regularly. Check that retention schedules are followed, records are properly protected, and disposal happens securely and on time.
Evidence to review
- Records retention schedule with legal and regulatory basis for retention periods
- Records management policy and procedures
- Access control configurations for records storage systems
- Backup and disaster recovery provisions for records
- Records disposal logs with destruction certificates where applicable
Common Mistakes
- No records retention schedule defining what must be kept and for how long
- Records are stored in unmanaged locations without access controls or backup
- No protection against unauthorized modification of records
- Records disposal is ad hoc without documented secure destruction procedures
- Electronic records become inaccessible due to technology obsolescence
Related Controls Across Frameworks
| Framework | Control ID | Relationship |
|---|---|---|
| SOC 2 | SOC 2 CC6.1: Logical and Physical Access - Security Software, Infrastructure, and Architectures | Partial overlap |
| GDPR | GDPR Art.5(1)(e): Storage Limitation | Related |
| GDPR | GDPR Art.17: Right to Erasure ('Right to Be Forgotten') | Partial overlap |
| NIS2 | NIS2 Art.21(2)(a): Policies on Risk Analysis and Information System Security | Partial overlap |
Frequently Asked Questions
How do we determine retention periods for records?
How do we protect electronic records from technology obsolescence?
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Work through the ISO 27001 assessment, record supporting evidence and review the gaps in your answers.
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