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The Role of Labelling in ISO 27001:2022 – Annex A 5.13 Explained

Organisations apply classification labels to relevant information assets to implement their information classification scheme.

Following the organisation’s adopted information classification scheme, ISO 27001:2022 Annex A 5.13 defines a set of procedures for information labelling.

In addition to identifying physical and electronic assets, procedures for identifying information will need to be developed that reflect the classification scheme described in 5.12.

Making labels easy to recognise and manage; otherwise, they will not be followed. Rather than getting staff to label every CRM update with a commercial in-confidence statement, it might be easier to decide de-facto that everything in the digital systems is confidential unless otherwise expressly labelled!

Using the classification scheme adopted in Annex A Control 5.12, Annex A Control 5.13 details how organisations should develop, implement, and manage a robust information labelling procedure.

What Is The Purpose of ISO 27001:2022 Annex A 5.13?

The purpose of Annex A 5.13 is two-fold; to protect information assets against security risks:

  • Information assets can be classified in a straightforward manner when they are communicated internally and externally. This is when employees and third parties can access and use the information.
  • Information processing and management can be streamlined through automation.



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Who Has Ownership of Annex A 5.13?

Information assets can be labelled by adding metadata, so metadata stewards must be accountable for properly implementing the labelling process.

All data assets must be appropriately labelled, and asset owners must make any modifications to labelling with access and modification authorisations.

General Guidelines on How to Comply With ISO 27001:2022 Annex A 5.13

Using Annex A Control 5.13, organisations can label information in compliance with four specific steps.

Establish a Procedure for Labelling Information

The information classification scheme created per Annex A Control 5.12 should be adhered to by organisations’ Information Labelling Procedures.

5.13 also requires that this Procedure applies to all information assets, whether digital or paper and that the labels must be easily recognisable.

There is no limit to what this Procedure document can contain, but Annex A Control 5.13 requires that the procedures include the following:

  • An explanation of the methods for attaching labels to information assets based on the type of storage medium and how the data is accessed.
  • For each type of information asset, where the labels should be attached.
  • For instance, an organisation may omit publishing public data as part of its information labelling process.
  • Technical, legal, or contractual limitations prevent the labelling of certain types of information.
  • Rules govern how information should be labelled when transmitted internally or externally.
  • Instructions should accompany digital assets on how to insert metadata.
  • All assets should be labelled with the same names.

Provide Adequate Training on Labelling Procedures to Employees

Personnel and other relevant stakeholders must understand how to label information correctly and manage labelled information assets before the Procedure for labelling information can be effective.

As a result, organisations should train staff and other relevant parties about the Procedure.

Digital Information Assets Should Be Tagged With Metadata

Digital information assets must be labelled using metadata per 5.13.

Metadata deployment should also facilitate easy identification and searching for information and streamline decision-making between systems related to labelled information.

Extra Precautions Should Be Taken to Label Sensitive Data That May Leave the System

The Annex A 5.13 recommendation focuses on identifying the most appropriate label for outward transfers of critical and sensitive information assets, considering the risks involved.




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Annex A 5.13 Supplementary Guidance

For data-sharing operations to be secure, it is essential to accurately identify and label classified information.

Annex A 5.13 also recommends that organisations insert additional metadata points. This is to say, the name of the process that created the information asset and the time at which it was created.

In addition, Annex A 5.13 describes the standard labelling techniques that organisations can use:

  • Physical labels
  • Headers and footers
  • Metadata
  • Watermarking
  • Rubber-stamps

Lastly, Annex A 5.13 emphasises that labelling information assets as ‘confidential’ and ‘classified’ can have unintended consequences. This may make it easier for malicious actors to discover and find sensitive information assets.

What Are the Changes and Differences From ISO 27001:2013?

ISO 27001:2022 Annex A 5.13 replaces ISO 27001:2013 Annex A 8.2.2 (Labelling of Information).

Both Annex A controls are similar to some extent, but two key differences make the ISO 27001:2022 version more comprehensive.

The Use of Metadata Has Been Required to Meet New Requirements

While the 2013 version referred to metadata as a labelling technique, it did not impose any specific obligations for compliance when using metadata.

In contrast, the 2022 version incorporates differences and changes from ISO 27001:2013.

The Use of Metadata Is Now a Requirement

In 2013, metadata was referred to as a labelling technique, but no specific compliance obligations were imposed.

Contrary to this, the 2022 version includes strict requirements for metadata techniques. For instance, the 2022 version requires the following:

  • Adding metadata to information facilitates its identification, management, and discovery.
  • It is necessary to insert metadata for the name and date of the process which created the asset.

It Is Necessary to Provide More Details in the Information Labelling Procedure

Information Labelling Procedures in the 2013 version were not required to include the minimum content as in the 2022 version.

Table of All ISO 27001:2022 Annex A Controls

In the table below you’ll find more information on each individual ISO 27001:2022 Annex A Control.

ISO 27001:2022 Organisational Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Organisational Controls Annex A 5.1 Annex A 5.1.1
Annex A 5.1.2
Policies for Information Security
Organisational Controls Annex A 5.2 Annex A 6.1.1 Information Security Roles and Responsibilities
Organisational Controls Annex A 5.3 Annex A 6.1.2 Segregation of Duties
Organisational Controls Annex A 5.4 Annex A 7.2.1 Management Responsibilities
Organisational Controls Annex A 5.5 Annex A 6.1.3 Contact With Authorities
Organisational Controls Annex A 5.6 Annex A 6.1.4 Contact With Special Interest Groups
Organisational Controls Annex A 5.7 NEW Threat Intelligence
Organisational Controls Annex A 5.8 Annex A 6.1.5
Annex A 14.1.1
Information Security in Project Management
Organisational Controls Annex A 5.9 Annex A 8.1.1
Annex A 8.1.2
Inventory of Information and Other Associated Assets
Organisational Controls Annex A 5.10 Annex A 8.1.3
Annex A 8.2.3
Acceptable Use of Information and Other Associated Assets
Organisational Controls Annex A 5.11 Annex A 8.1.4 Return of Assets
Organisational Controls Annex A 5.12 Annex A 8.2.1 Classification of Information
Organisational Controls Annex A 5.13 Annex A 8.2.2 Labelling of Information
Organisational Controls Annex A 5.14 Annex A 13.2.1
Annex A 13.2.2
Annex A 13.2.3
Information Transfer
Organisational Controls Annex A 5.15 Annex A 9.1.1
Annex A 9.1.2
Access Control
Organisational Controls Annex A 5.16 Annex A 9.2.1 Identity Management
Organisational Controls Annex A 5.17 Annex A 9.2.4
Annex A 9.3.1
Annex A 9.4.3
Authentication Information
Organisational Controls Annex A 5.18 Annex A 9.2.2
Annex A 9.2.5
Annex A 9.2.6
Access Rights
Organisational Controls Annex A 5.19 Annex A 15.1.1 Information Security in Supplier Relationships
Organisational Controls Annex A 5.20 Annex A 15.1.2 Addressing Information Security Within Supplier Agreements
Organisational Controls Annex A 5.21 Annex A 15.1.3 Managing Information Security in the ICT Supply Chain
Organisational Controls Annex A 5.22 Annex A 15.2.1
Annex A 15.2.2
Monitoring, Review and Change Management of Supplier Services
Organisational Controls Annex A 5.23 NEW Information Security for Use of Cloud Services
Organisational Controls Annex A 5.24 Annex A 16.1.1 Information Security Incident Management Planning and Preparation
Organisational Controls Annex A 5.25 Annex A 16.1.4 Assessment and Decision on Information Security Events
Organisational Controls Annex A 5.26 Annex A 16.1.5 Response to Information Security Incidents
Organisational Controls Annex A 5.27 Annex A 16.1.6 Learning From Information Security Incidents
Organisational Controls Annex A 5.28 Annex A 16.1.7 Collection of Evidence
Organisational Controls Annex A 5.29 Annex A 17.1.1
Annex A 17.1.2
Annex A 17.1.3
Information Security During Disruption
Organisational Controls Annex A 5.30 NEW ICT Readiness for Business Continuity
Organisational Controls Annex A 5.31 Annex A 18.1.1
Annex A 18.1.5
Legal, Statutory, Regulatory and Contractual Requirements
Organisational Controls Annex A 5.32 Annex A 18.1.2 Intellectual Property Rights
Organisational Controls Annex A 5.33 Annex A 18.1.3 Protection of Records
Organisational Controls Annex A 5.34 Annex A 18.1.4 Privacy and Protection of PII
Organisational Controls Annex A 5.35 Annex A 18.2.1 Independent Review of Information Security
Organisational Controls Annex A 5.36 Annex A 18.2.2
Annex A 18.2.3
Compliance With Policies, Rules and Standards for Information Security
Organisational Controls Annex A 5.37 Annex A 12.1.1 Documented Operating Procedures
ISO 27001:2022 People Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
People Controls Annex A 6.1 Annex A 7.1.1 Screening
People Controls Annex A 6.2 Annex A 7.1.2 Terms and Conditions of Employment
People Controls Annex A 6.3 Annex A 7.2.2 Information Security Awareness, Education and Training
People Controls Annex A 6.4 Annex A 7.2.3 Disciplinary Process
People Controls Annex A 6.5 Annex A 7.3.1 Responsibilities After Termination or Change of Employment
People Controls Annex A 6.6 Annex A 13.2.4 Confidentiality or Non-Disclosure Agreements
People Controls Annex A 6.7 Annex A 6.2.2 Remote Working
People Controls Annex A 6.8 Annex A 16.1.2
Annex A 16.1.3
Information Security Event Reporting
ISO 27001:2022 Physical Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Physical Controls Annex A 7.1 Annex A 11.1.1 Physical Security Perimeters
Physical Controls Annex A 7.2 Annex A 11.1.2
Annex A 11.1.6
Physical Entry
Physical Controls Annex A 7.3 Annex A 11.1.3 Securing Offices, Rooms and Facilities
Physical Controls Annex A 7.4 NEW Physical Security Monitoring
Physical Controls Annex A 7.5 Annex A 11.1.4 Protecting Against Physical and Environmental Threats
Physical Controls Annex A 7.6 Annex A 11.1.5 Working In Secure Areas
Physical Controls Annex A 7.7 Annex A 11.2.9 Clear Desk and Clear Screen
Physical Controls Annex A 7.8 Annex A 11.2.1 Equipment Siting and Protection
Physical Controls Annex A 7.9 Annex A 11.2.6 Security of Assets Off-Premises
Physical Controls Annex A 7.10 Annex A 8.3.1
Annex A 8.3.2
Annex A 8.3.3
Annex A 11.2.5
Storage Media
Physical Controls Annex A 7.11 Annex A 11.2.2 Supporting Utilities
Physical Controls Annex A 7.12 Annex A 11.2.3 Cabling Security
Physical Controls Annex A 7.13 Annex A 11.2.4 Equipment Maintenance
Physical Controls Annex A 7.14 Annex A 11.2.7 Secure Disposal or Re-Use of Equipment
ISO 27001:2022 Technological Controls
Annex A Control Type ISO/IEC 27001:2022 Annex A Identifier ISO/IEC 27001:2013 Annex A Identifier Annex A Name
Technological Controls Annex A 8.1 Annex A 6.2.1
Annex A 11.2.8
User Endpoint Devices
Technological Controls Annex A 8.2 Annex A 9.2.3 Privileged Access Rights
Technological Controls Annex A 8.3 Annex A 9.4.1 Information Access Restriction
Technological Controls Annex A 8.4 Annex A 9.4.5 Access to Source Code
Technological Controls Annex A 8.5 Annex A 9.4.2 Secure Authentication
Technological Controls Annex A 8.6 Annex A 12.1.3 Capacity Management
Technological Controls Annex A 8.7 Annex A 12.2.1 Protection Against Malware
Technological Controls Annex A 8.8 Annex A 12.6.1
Annex A 18.2.3
Management of Technical Vulnerabilities
Technological Controls Annex A 8.9 NEW Configuration Management
Technological Controls Annex A 8.10 NEW Information Deletion
Technological Controls Annex A 8.11 NEW Data Masking
Technological Controls Annex A 8.12 NEW Data Leakage Prevention
Technological Controls Annex A 8.13 Annex A 12.3.1 Information Backup
Technological Controls Annex A 8.14 Annex A 17.2.1 Redundancy of Information Processing Facilities
Technological Controls Annex A 8.15 Annex A 12.4.1
Annex A 12.4.2
Annex A 12.4.3
Logging
Technological Controls Annex A 8.16 NEW Monitoring Activities
Technological Controls Annex A 8.17 Annex A 12.4.4 Clock Synchronization
Technological Controls Annex A 8.18 Annex A 9.4.4 Use of Privileged Utility ProgramsAccess Rights
Technological Controls Annex A 8.19 Annex A 12.5.1
Annex A 12.6.2
Installation of Software on Operational Systems
Technological Controls Annex A 8.20 Annex A 13.1.1 Networks Security
Technological Controls Annex A 8.21 Annex A 13.1.2 Security of Network Services
Technological Controls Annex A 8.22 Annex A 13.1.3 Segregation of Networks
Technological Controls Annex A 8.23 NEW Web filtering
Technological Controls Annex A 8.24 Annex A 10.1.1
Annex A 10.1.2
Use of Cryptography
Technological Controls Annex A 8.25 Annex A 14.2.1 Secure Development Life Cycle
Technological Controls Annex A 8.26 Annex A 14.1.2
Annex A 14.1.3
Application Security Requirements
Technological Controls Annex A 8.27 Annex A 14.2.5 Secure System Architecture and Engineering PrinciplesLearning From Information Security Incidents
Technological Controls Annex A 8.28 NEW Secure Coding
Technological Controls Annex A 8.29 Annex A 14.2.8
Annex A 14.2.9
Security Testing in Development and Acceptance
Technological Controls Annex A 8.30 Annex A 14.2.7 Outsourced Development
Technological Controls Annex A 8.31 Annex A 12.1.4
Annex A 14.2.6
Separation of Development, Test and Production Environments
Technological Controls Annex A 8.32 Annex A 12.1.2
Annex A 14.2.2
Annex A 14.2.3
Annex A 14.2.4
Change Management
Technological Controls Annex A 8.33 Annex A 14.3.1 Test Information
Technological Controls Annex A 8.34 Annex A 12.7.1 Protection of Information Systems During Audit Testing




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David Holloway is the Chief Marketing Officer at ISMS.online, with over four years of experience in compliance and information security. As part of the leadership team, David focuses on empowering organisations to navigate complex regulatory landscapes with confidence, driving strategies that align business goals with impactful solutions. He is also the co-host of the Phishing For Trouble podcast, where he delves into high-profile cybersecurity incidents and shares valuable lessons to help businesses strengthen their security and compliance practices.

ISO 27001:2022 Annex A Controls

Organisational Controls