Annex A 5.13: Labelling of Information

Annex a 5.13: labelling of information requirement means you must define and apply a consistent information labelling scheme that matches your classification rules and handling requirements, then prove it operates in real workflows. Operationalize it by standardizing labels, embedding them in systems and templates, training users, and keeping recurring evidence for audits. ¹

Key takeaways:

• Create a label taxonomy tied to classification levels and handling rules, then make it usable in daily tools. ¹
• Prove operation with evidence: labelled samples, system configurations, training/acknowledgements, and periodic checks. ¹
• Focus on “label drives handling” (storage, sharing, retention, encryption), not cosmetic headers. ¹

Information labelling is the control that turns your classification policy from a document into a behavior. If people cannot tell what a file is (public vs confidential) at the moment they create, share, store, or print it, then your other controls degrade quickly: access control becomes inconsistent, DLP rules misfire, retention schedules get ignored, and third parties receive sensitive data without guardrails.

Annex A 5.13 expects you to implement labelling in a way that fits how your organization actually works, across common information types (documents, spreadsheets, email, tickets, chat exports, source code, reports) and across storage locations (endpoints, SaaS, collaboration platforms, shared drives). The goal is operational clarity: a label communicates handling expectations and triggers the right protections. ¹

For a CCO or GRC lead, the fastest path is to keep the scheme simple, bind it tightly to handling rules, and instrument it where the work happens. Then build an evidence pack you can refresh on a predictable cadence, so auditors see repeatable control operation rather than a one-time rollout. ¹

Regulatory text

Provided excerpt: “ISO/IEC 27001:2022 Annex A control 5.13 implementation expectation (Labelling of Information).” ¹

Operator interpretation (what you must do):

• Define a labelling approach for information that aligns to your organization’s classification scheme and handling requirements. ¹
• Apply labels in practice across relevant information assets and channels, so recipients can recognize sensitivity and required handling. ¹
• Maintain evidence that labelling is designed, implemented, communicated, and operating as intended. ¹

This control is usually assessed as: “Do you have a defined scheme?” and “Can you show it is consistently applied where it matters?” ¹

Plain-English interpretation of the requirement

You need a standard set of labels (and rules for using them) so that staff and third parties can immediately identify how to handle information. The label should be visible and durable (stays with the information or is clearly associated with it) and should map to concrete protections like who can access it, where it can be stored, whether it must be encrypted, and whether it can be shared externally. ¹

A practical benchmark: if someone receives a file or email, the label should answer “What is this?” and “What am I allowed to do with it?” without guessing.

Who it applies to (entity and operational context)

Applies to:

• Service organizations implementing an ISMS and seeking alignment/certification against ISO/IEC 27001. ¹

Operational contexts where auditors expect to see labelling working:

• Internal collaboration: shared drives, SharePoint/Google Drive, Teams/Slack attachments, knowledge bases.
• Email and messaging: outbound customer communications, finance/legal HR exchanges, support escalations.
• Engineering workflows: design docs, source code repositories, build artifacts, incident postmortems.
• Third-party exchanges: file transfers, ticketing portals, customer/vendor data rooms.

Scope decision you must make (and document):

• Which information types must be labelled (all documents vs only sensitive classes; customer data vs internal-only; structured vs unstructured data). Keep the scope realistic, then expand. ¹

What you actually need to do (step-by-step)

1) Define your classification-to-label mapping

Create a short mapping table that connects:

• Classification level (example: Public / Internal / Confidential / Restricted)
• Label text and visual marker (header/footer, watermark, email subject tag, metadata tag)
• Handling rules (allowed storage locations, encryption requirements, sharing restrictions, retention/disposal rules)
• Owner (who can change classification/label)
• Exception process (how to deviate and who approves)

Keep labels few and unambiguous. If users debate between two labels, you will get inconsistent application.

2) Specify where labels must appear (by channel)

Document channel-specific rules, for example:

• Documents/PDFs: header/footer + metadata label where supported.
• Spreadsheets/exports: label on first tab and filename convention for exports.
• Email: subject prefix or sensitivity tag, plus a standard footer for certain classes.
• Tickets: required field for classification when attaching customer data.

Write these rules as “must/should” statements so they are auditable.

3) Build the label into templates and systems

Operationalization lives in defaults:

• Update document templates with pre-set label placeholders.
• Configure collaboration platform sensitivity labels (where available) to enforce encryption/sharing restrictions tied to the label.
• Configure DLP rules to detect/alert/block based on label plus content patterns (label alone is easy to bypass; content alone yields noise).
• Add mandatory classification fields to intake workflows (support portals, HR requests, legal reviews) where sensitive data is common.

If your tooling cannot enforce labels, require visible labels and backstop with review and DLP monitoring.

4) Define roles and decision rights

Minimum set:

• Information owner(s): defines classification and approves exceptions.
• System owners: implement label configurations.
• Users: apply labels at creation and before external sharing.
• Security/GRC: monitors adherence, runs periodic checks, maintains evidence.

Write down who can downgrade a label, and under what conditions.

5) Train for the decisions people actually face

Training must include:

• Real examples from your environment (customer exports, contracts, architecture diagrams, incident evidence).
• “If/then” rules (If customer identifiers appear, then label = Confidential/Restricted).
• External sharing rules by label.
• How to label in each major tool used by staff.

Also train third parties who handle your information, if they access your systems or exchange files routinely.

6) Implement monitoring and recurring assurance

Pick a lightweight operating rhythm:

• Sample labelled artifacts from key repositories.
• Review outbound sharing logs for sensitive labels.
• Validate that system configurations still enforce the intended restrictions.
• Track exceptions and corrective actions.

Daydream (or your GRC system) becomes useful here as the control operations hub: document the control, assign owners, schedule recurring evidence tasks, and keep a clean audit trail of samples and reviews without rebuilding the same binder each audit cycle. ¹

Required evidence and artifacts to retain

Auditors typically want both design evidence and operational evidence.

Design artifacts

• Information classification policy and the label taxonomy/mapping table.
• Labelling standard/work instruction (where labels are required and how to apply them).
• Handling requirements by label (storage, sharing, encryption, retention).
• Tool configuration standards (for sensitivity labels, DLP, email tags, templates).
• Exception procedure (approval workflow + criteria).

Operational artifacts

• Screenshots/exported configs from key platforms showing labels and enforcement behavior (where applicable).
• Samples of labelled documents/emails/tickets (sanitized if needed) showing consistent application.
• Training materials + completion records or policy acknowledgements.
• Periodic review reports (sampling results, issues found, remediation tickets).
• Exception register with approvals and expiry dates.

Common exam/audit questions and hangups

Common auditor questions

• “Show me your labels and how they map to classification and handling.”
• “Where is labelling required, and how do you enforce it in tools?”
• “Provide examples of labelled information from different teams.”
• “How do you prevent a user from sharing ‘Restricted’ data externally?”
• “How do you manage mislabelling and downgrades?”

Frequent hangups

• Labels exist on paper, but no one applies them consistently.
• Labels appear only in a document header, with no link to access control or sharing restrictions.
• Labels are applied in one platform (email) but not where sensitive data actually lives (file storage, tickets, exports).

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails audits	How to avoid it
Too many labels	Users guess; results are inconsistent	Keep a small set of labels tied to specific handling rules
Cosmetic labelling	Labels don’t change behavior	Bind labels to sharing/storage controls where possible; otherwise enforce through process checks
No downgrade rules	“Confidential” becomes permanent or arbitrary	Define who can downgrade and require justification
Ignoring exports	Data leaks often happen in spreadsheets/CSV exports	Add export labelling rules and DLP monitoring for common export paths
One-time rollout	Evidence goes stale	Schedule recurring sampling and retain artifacts each cycle

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog, so this page does not list specific actions or penalties. ¹

Risk-wise, weak labelling increases the chance of unauthorized disclosure because staff and third parties cannot reliably identify sensitive information at the point of handling. It also complicates incident response: you spend time determining what data was involved because the sensitivity is not clearly marked or searchable.

A practical 30/60/90-day execution plan

These phases are sequencing guidance; adjust to your change-management capacity.

First 30 days (Immediate)

• Confirm your classification levels and define the label taxonomy (names, definitions, handling rules).
• Decide scope for initial rollout (teams, repositories, and information types).
• Publish a short labelling standard (1–2 pages) plus examples.
• Update core templates (docs, slides, spreadsheets) with label placeholders.
• Stand up an evidence folder and start capturing: policy, mapping table, templates, and one or two labelled samples per core team.

Next 60 days (Near-term)

• Configure labels in primary collaboration/email tools where supported; align label settings with handling requirements.
• Add required classification fields in workflows that frequently process sensitive data (support tickets, customer requests, HR/legal).
• Train targeted groups (security, support, finance, HR, engineering leads) with job-based examples.
• Run the first sampling review; document findings and remediation actions.

Next 90 days (Stabilize + prove operation)

• Expand scope to remaining teams and key third-party exchange paths.
• Tighten enforcement: external sharing restrictions by label, alerting for mislabelled sensitive content.
• Establish recurring control operation: periodic sampling, exception review, configuration checks.
• Package an “audit-ready” evidence set in Daydream: last review report, system configs, samples, training evidence, and exception register. ¹

Frequently Asked Questions

Do we have to label every single document and message?

ISO 27001 expects labelling to be implemented where it is relevant and effective, aligned to your classification approach. Define scope by information type and channel, then expand as you mature. ¹

Can we rely on metadata labels only (no header/footer)?

Metadata-only can work if it is consistently visible to users and travels with the file across common workflows. Many teams still add a visible marker for clarity, especially for exports and printed materials.

How do we handle information that contains multiple classifications?

Use the highest applicable classification/label for the combined artifact, and apply the strictest handling rules tied to that label. Document this rule in your labelling standard so reviewers see consistent decisions.

What about data in SaaS apps like ticketing systems and CRMs?

Treat records and attachments as information assets subject to labelling rules. Where the tool supports fields/tags, make classification required for sensitive workflows and retain configuration screenshots as evidence.

How do we prove this control operates without drowning in evidence?

Use a recurring sampling approach across a few key repositories and outbound sharing paths, and retain the sample set plus results each cycle. A GRC system like Daydream helps you schedule the cadence and store the evidence trail without rebuilding it for each audit. ¹

How should we address third parties who receive our labelled information?

Include label handling expectations in contract language or security addenda and provide a simple label-handling guide for engaged third parties. Then validate in due diligence and during periodic reviews that they can follow the handling rules.

Footnotes

1. ISO/IEC 27001 overview; ISMS.online Annex A control index