Annex A 5.14: Information Transfer

Annex a 5.14: information transfer requirement means you must define and run controlled, documented methods for sending information to and from third parties (and internally), based on classification and risk. Operationalize it by standardizing approved transfer channels, security protections (encryption, access control), roles, and evidence so auditors can see consistent, repeatable transfer decisions (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Key takeaways:

• You need an “information transfer standard” plus procedures that cover email, file sharing, APIs, messaging, removable media, and physical transfer.
• Control effectiveness depends on consistent channel approvals tied to data classification and third-party terms.
• Auditors will ask for proof of operation: configurations, logs, exceptions, and real samples of transfers.

Information transfer is where good security programs quietly fail: teams classify data well, but then send it through ad hoc channels, personal inboxes, unmanaged file shares, or poorly governed integrations. Annex A 5.14 focuses on putting guardrails around those transfers so your controls hold up when information leaves a system boundary, moves between environments, or crosses an organizational boundary to a third party.

For a Compliance Officer, CCO, or GRC lead, the fastest path to maturity is to treat “transfer” as a lifecycle with decision points: (1) identify what is being transferred and why, (2) approve the channel based on classification and recipient risk, (3) protect the transfer in transit and at rest, (4) verify receipt and access, and (5) retain evidence that the transfer was controlled. Your goal is not to document every message. Your goal is to prove you have standardized mechanisms, people follow them, and exceptions are rare, approved, and traceable (ISO/IEC 27001 overview; ISMS.online Annex A control index).

This page gives requirement-level implementation guidance you can put into production quickly, with artifacts that map cleanly to ISO 27001 audit expectations.

Regulatory text

Excerpt (provided): “ISO/IEC 27001:2022 Annex A control 5.14 implementation expectation (Information Transfer).” (ISO/IEC 27001 overview; ISMS.online Annex A control index)

Operator interpretation: You must implement defined rules and secure methods for transferring information, proportionate to the information’s classification and risk, including transfers to and from third parties. The control is satisfied when:

• Approved transfer channels exist for common use cases (email, file transfer, collaboration, APIs, physical media).
• Each channel has baseline security requirements (authentication, encryption, access restrictions, logging where feasible).
• People know which channel to use for which type of information.
• Exceptions are approved, time-bounded, and evidenced.

Plain-English interpretation (what 5.14 is really asking for)

Annex a 5.14: information transfer requirement expects you to prevent “shadow transfer.” That includes:

• Sensitive files emailed externally without protections.
• Customer data exported and uploaded to unmanaged SaaS.
• Production data copied to developer laptops.
• Third-party integrations exchanging data without clear ownership, least privilege, or logging.
• Physical transfers (printed documents, shipping drives) handled without chain-of-custody.

If information crosses a boundary, you need a controlled method and a record that the method is governed.

Who it applies to

Entities: Any organization implementing ISO/IEC 27001, especially service organizations that transfer customer, employee, or partner data as part of delivery (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Operational contexts where auditors focus:

• Third-party data exchanges: SFTP, managed file transfer, EDI, API integrations, shared storage buckets.
• Customer support: sending screenshots, logs, exports, or attachments.
• Finance and HR: payroll files, bank details, tax forms, benefit enrollments.
• Engineering and analytics: data extracts for debugging, model training, or BI.
• M&A, legal, and procurement: due diligence data rooms, contracts, and confidential documents.

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

1) Define scope: “transfer” and “approved channels”

Create an Information Transfer Standard that defines:

• Transfer types: electronic (email, chat, file share, API), physical (print, courier), and hybrid (download then upload).
• Approved tools/channels (your allowlist): e.g., corporate email with secure mail features, managed file transfer, sanctioned collaboration platform, approved API gateway, approved ticketing attachments.
• Prohibited channels: personal email, consumer file shares, unapproved messaging apps, unmanaged USB storage (tailor to your environment).

Deliverable: a one-page decision table people can follow.

2) Tie transfer rules to data classification

Add explicit mapping from classification → permitted transfer methods. Example mapping (adjust to your schema):

• Public: normal channels allowed.
• Internal: corporate tools only.
• Confidential/Restricted: only channels that enforce encryption in transit, strong authentication, recipient control, and access expiry; require approval for external recipients.

If you already have classification, the missing step is operational: “If it’s Restricted, you must use X, not Y.”

3) Put technical protections on each approved channel

For each channel on the allowlist, define minimum controls you can prove:

• Identity and access: corporate SSO where possible; role-based access for shared folders; remove access when no longer needed.
• Encryption: enforce TLS for transfer; encrypt files at rest in the platform; require encrypted attachments or secure portals for high-risk content where applicable.
• Recipient controls: domain allow/deny lists, external sharing restrictions, link expiry, download blocking where feasible, watermarking for highly sensitive documents.
• Logging and monitoring: retain logs for file access/sharing, API calls, MFT transactions; alert on anomalous external sharing where feasible.
• DLP (if you have it): detect and block sensitive patterns or classification labels leaving approved boundaries.

You do not need every control everywhere. You need a defendable baseline per channel, and a rule that sensitive transfers must use channels that meet the baseline.

4) Build a repeatable approval workflow for external transfers

Define when a transfer requires explicit approval (examples):

• First-time transfer to a new third party.
• New data type (e.g., moving from contact info to financial identifiers).
• Bulk exports or recurring feeds.
• Cross-border transfers (if your privacy program requires it).

Implement a lightweight workflow:

• Request ticket (who, what, why, classification, destination, retention).
• Security/GRC review and sign-off.
• Third-party terms check (contract/DPA, confidentiality, permitted purpose).
• Implementation and validation (test transfer, verify access controls).
• Record transfer owner and review cadence.

Daydream fits naturally here as the system of record to map the requirement to a documented control operation and schedule recurring evidence capture so you can show consistent governance over time (ISO/IEC 27001 overview; ISMS.online Annex A control index).

5) Cover third-party transfers with contractual and operational controls

For transfers to third parties, align the transfer method with third-party commitments:

• Contract requires secure transmission and access controls.
• Data is limited to purpose and minimum necessary.
• Return/deletion expectations exist at termination.
• Subprocessors and onward transfers are addressed where relevant.

Operationally, maintain a simple register of recurring transfers: system → third party → data types → channel → owner → frequency → approval reference.

6) Train and enforce (lightweight, targeted)

Training should be role-based:

• Support: “How to send logs/screenshots safely.”
• Finance/HR: “How to send payroll and bank data.”
• Engineering: “How to move production data for debugging.”

Enforcement is mostly about defaults:

• Make the approved channel the easiest channel.
• Restrict or block risky channels where feasible.
• Require exceptions to be visible (ticketed) and time-bounded.

Required evidence and artifacts to retain

Auditors look for both design evidence (policies/standards) and operating evidence (real execution). Keep:

• Information Transfer Standard (approved channels, prohibited channels, security requirements).
• Data classification-to-transfer matrix.
• Configuration evidence for key platforms (screenshots/exports of sharing restrictions, external collaboration settings, SSO enforcement, MFT configs).
• Sample transfer approvals (tickets) tied to classification and third-party identity.
• Register of recurring third-party transfers (feeds, integrations, shared folders).
• Logs or reports showing external sharing events and access (where feasible).
• Exception records: rationale, approver, compensating controls, expiry date.
• Training content and completion evidence for high-risk teams.

Common exam/audit questions and hangups

Expect these in ISO 27001 audits:

• “Show me how you decide which transfer method is acceptable for Restricted data.”
• “Which tools are approved for external sharing? Where is that documented?”
• “Provide examples of transfers to third parties and the evidence of approval.”
• “How do you prevent employees from using personal email or unapproved file sharing?”
• “How do you log and review external sharing or data exports?”
• “How do you manage transfers initiated by integrations (APIs, MFT jobs) versus humans?”

Hangup: teams provide a policy but no proof of daily operation. Fix it by keeping a small, consistent evidence set each period: a few approval tickets, a sharing report, and configuration snapshots.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: “Policy-only” compliance.
   Avoid it: collect recurring samples of real transfers and approvals; store them in a control evidence folder mapped to 5.14.

2. Mistake: treating transfer as “email only.”
   Avoid it: include APIs, collaboration links, data rooms, tickets, and physical transfers in scope.

3. Mistake: no owner for recurring feeds.
   Avoid it: name a business owner and technical owner per transfer; require annual confirmation.

4. Mistake: exceptions that never expire.
   Avoid it: require an expiry date and compensating controls; review exceptions on a schedule.

5. Mistake: ignoring third-party onward transfer risk.
   Avoid it: confirm contractual limits and track where the data goes next when the third party uses subprocessors.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific regulator actions.

Operationally, weak transfer controls create predictable incident patterns: misdirected emails, public links, misconfigured shared folders, and over-permissioned integrations. The business risk is disproportionate because transfers often include concentrated datasets (exports, reports, backups) and cross the boundary where your direct control is weakest.

Practical 30/60/90-day execution plan

First 30 days (stabilize and document)

• Publish an Information Transfer Standard with an allowlist/denylist.
• Create the classification-to-transfer matrix and socialize it with Support, HR, Finance, Engineering.
• Inventory high-risk transfer paths: recurring feeds, shared folders with external users, top integrations, and top manual export workflows.
• Set up an approval ticket template for new external transfers and bulk exports.
• Start evidence capture: configuration snapshots and a small sample of transfers.

Days 31–60 (implement controls and reduce variance)

• Tighten platform configurations: external sharing restrictions, link expiry defaults, SSO requirements where feasible.
• Implement DLP rules or basic guardrails for the highest-risk channels if available in your stack.
• Stand up a “recurring transfers register” and assign owners.
• Add contract checklist items for third-party transfers (secure transmission, access controls, return/deletion).

Days 61–90 (operationalize and prove effectiveness)

• Run a targeted internal audit: pick several real transfers and verify they followed the standard.
• Review exceptions, close stale ones, and force time bounds.
• Add a lightweight recurring review: external sharing report review, transfer register owner attestations.
• In Daydream, map Annex A 5.14 to your documented control operation and schedule recurring evidence tasks so you can answer audit requests in hours, not weeks (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Frequently Asked Questions

Does Annex A 5.14 require encryption for every transfer?

The control expects protections appropriate to the information and risk, so you should require stronger protections for higher classifications. Write explicit rules so teams know which transfers must use encrypted or access-controlled channels (ISO/IEC 27001 overview; ISMS.online Annex A control index).

What counts as “information transfer” in practice?

Treat any movement of information across a trust boundary as transfer: external email, file sharing links, API integrations, MFT jobs, and physical media. If the recipient is a third party or a separate environment, put it in scope.

How do I handle customer-requested channels (for example, “just email it”)?

Offer approved secure options by default and document an exception process when the customer insists on a weaker channel. Keep the exception approval, the rationale, and compensating controls with an expiry date.

Do we need to log every file sent to a third party?

You need evidence that transfers are controlled and traceable where feasible. Focus on logging and reporting for approved platforms (file sharing, MFT, API gateway) and keep samples that show consistent operation.

What evidence is strongest for auditors?

A clear transfer standard, a classification-to-channel matrix, platform configuration exports, and real samples of approvals and transfer logs. Auditors want to see the control working, not just written.

How should we govern automated transfers like APIs and nightly file drops?

Treat them as recurring transfers with named owners, documented data elements, approved endpoints, authentication method, and logging. Review access and necessity periodically, and document changes through change management.