Annex A 5.33: Protection of Records

Annex a 5.33: protection of records requirement means you must identify which information security and business records need preservation, then protect them against loss, destruction, falsification, unauthorized access, and premature disposal across their full lifecycle. Operationalize it by defining record classes, retention rules, storage and access controls, and audit-ready evidence of ongoing operation (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Key takeaways:

• Treat “records” as controlled assets with defined owners, retention, integrity controls, and disposal rules.
• Protect both digital and physical records with access control, tamper-evidence, backup, and restore testing.
• Auditors look for repeatable operation: a record inventory, retention schedule, and recurring evidence capture (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Most ISO 27001 programs document policies and run technical controls, but fail audits on a simpler issue: you cannot prove what happened because the records are incomplete, inconsistent, or unprotected. Annex A 5.33 focuses on records as evidence, not just data. A “record” is any information you rely on to demonstrate decisions, transactions, security events, compliance outcomes, or control operation. That includes logs, access approvals, incident tickets, change records, risk assessments, supplier reviews, HR onboarding evidence, and even meeting minutes when they document security decisions.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat records like a governed inventory: define what must be kept, for how long, where it lives, who can access it, how integrity is preserved, and how disposal is controlled. Then you capture proof that this is happening in day-to-day operations, not just written down. This page gives requirement-level implementation guidance you can hand to control owners, IT, Security, and Legal to stand up an audit-ready “protection of records” control with minimal churn (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Regulatory text

Excerpt (provided): “ISO/IEC 27001:2022 Annex A control 5.33 implementation expectation (Protection of Records).” (ISO/IEC 27001 overview; ISMS.online Annex A control index)

Operator meaning: You need a defined approach to protect records from the moment they are created or received until they are disposed of, including safeguards for confidentiality (prevent unauthorized access), integrity (prevent alteration/falsification), availability (prevent loss), and compliance (retain for required periods and dispose defensibly). Your implementation should be demonstrable through repeatable procedures and evidence, not informal practice (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Plain-English interpretation (what 5.33 is really asking for)

Annex A 5.33 expects you to answer five audit questions with confidence:

1. What are your records? Not “everything in SharePoint.” Specific record categories tied to business and security obligations.
2. Who owns them? Named roles accountable for retention, access, and disposal decisions.
3. Where are they stored? Approved systems and physical locations, with controls that match sensitivity.
4. How do you prevent tampering or loss? Access controls, immutability where needed, backups, and monitoring.
5. How do you prove it? Evidence that retention rules exist and that records were protected and available when needed (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Who it applies to

Entity types: Service organizations pursuing or maintaining ISO/IEC 27001 certification (ISO/IEC 27001 overview).

Operational context: Applies anywhere records are generated, processed, transmitted, or stored, including:

• GRC platforms, ticketing systems, HRIS, finance tools, CRM, shared drives, collaboration suites, code repos.
• Security tooling that produces logs and alerts.
• Physical records: signed contracts, visitor logs, paper HR files, archived media.
• Third-party managed systems where your records reside (for example, outsourced payroll or managed SIEM). You still need governance and retrieval ability even if the third party hosts the system.

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

Step 1: Define “record” for your ISMS scope

Create a short definition and boundary statement:

• What counts as a record (evidence of an activity/decision/transaction/control operation).
• What does not (drafts or transient communications) unless your organization treats them as records.

Deliverable: Records Protection Standard (or “Records Management and Protection Procedure”) mapped to Annex A 5.33 (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Step 2: Build a records inventory that auditors can sample

Create a table and keep it current. Minimum fields:

• Record category (e.g., access requests, incident records, change approvals, supplier due diligence).
• System of record (tool/location).
• Owner (role).
• Confidentiality classification (if you have one).
• Retention period and trigger (e.g., “X years after termination,” “X years after contract end”).
• Protection method (access control group, encryption at rest if applicable, immutable storage, physical lock).
• Backup/restore coverage (yes/no and where proven).

Tip: Start with records that prove your ISMS operates: risk assessments, internal audits, management review outputs, incident response evidence, asset inventory, access reviews, training completion, supplier reviews.

Deliverable: Record Register (Records Inventory).

Step 3: Establish retention and legal hold rules (without boiling the ocean)

You need one authoritative retention schedule for in-scope records. Align it with:

• Contractual retention commitments.
• Regulatory retention and privacy requirements applicable to your org (coordinate with Legal).
• Business needs (e.g., dispute resolution, customer audit support).

Operational requirements:

• Records cannot be deleted before retention expires unless an exception is approved.
• A legal hold process overrides normal disposal when required.

Deliverables:

• Retention Schedule (by record class).
• Legal Hold Procedure (roles, triggers, notification, tracking).

Step 4: Implement access control and integrity protections per record class

Controls should match the record’s risk. Common patterns:

• Role-based access for records repositories (least privilege).
• Separation of duties for sensitive records (e.g., change approvals vs implementers).
• Immutable logging for audit/security logs where tamper resistance matters.
• Versioning + restricted delete for controlled documents and approvals.
• Physical protection: locked cabinets, controlled access rooms, sign-in logs for archives.

Deliverable: Access Control Matrix for Records Repositories (system, groups/roles, permissions, owner).

Step 5: Make records findable and retrievable under time pressure

Audits and incidents fail when teams cannot retrieve evidence. Implement:

• Naming conventions or metadata tagging for key record types.
• Centralized storage locations (reduce “shadow evidence” in personal inboxes).
• Searchable archives (especially for tickets, approvals, and logs).

Deliverable: Retrieval SOP (how to locate top record types, who can export, and how exports are protected).

Step 6: Prove availability through backup and restore testing for record systems

For systems holding required records, you need documented backups and periodic restore validation appropriate to risk. Focus on:

• GRC platform exports or backup approach.
• Ticketing system data export and retention settings.
• Security logs retention configuration and retrieval tests.

Deliverables:

• Backup configuration evidence for each record system.
• Restore/retrieval test record (what was tested, when, by whom, outcome, follow-ups).

Step 7: Control disposal and destruction (digital and physical)

Define a disposal workflow:

• Eligibility check (retention satisfied, not on legal hold).
• Approved disposal method (secure deletion, media destruction, shredding).
• Disposal authorization and logging.

Deliverables:

• Disposal Procedure
• Destruction Certificates / Disposal Logs (including third-party destruction where used)

Step 8: Operationalize recurring evidence capture (the part most teams miss)

Annex A 5.33 commonly fails due to “we do it but can’t prove it.” Set up recurring collection:

• Quarterly sample: pick a few record categories and demonstrate retention + access + retrieval.
• Track exceptions (missing record, wrong permissions, early deletion) with corrective actions.
• Store evidence in one audit folder with clear indexing.

This is where Daydream typically fits: teams map Annex A 5.33 to a documented control operation and automate recurring evidence capture so the audit package is built continuously rather than assembled under deadline (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Required evidence and artifacts to retain

Use this as your audit checklist:

Artifact	What it proves	Owner
Records Protection Standard / Procedure	Defined control design for 5.33	GRC / Compliance
Records Inventory (Record Register)	You know what records exist and where	Record owners + GRC
Retention Schedule	Retention and disposal rules are defined	Legal + Compliance
Legal Hold Procedure + hold register	Disposal is paused when required	Legal
Access Control Matrix + screenshots/exports	Least privilege and controlled access	IT/Security
Configuration evidence (retention settings)	Systems enforce retention where possible	System admins
Backup evidence + restore/retrieval test	Records remain available	IT
Disposal logs / destruction certificates	Controlled, defensible destruction	Facilities/IT/Third party mgmt
Sampling results + corrective actions	Control operates continuously	GRC + control owners

Common exam/audit questions and hangups

Auditors and cert bodies often probe these angles:

• “Show me your record register. How do you keep it current?”
• “Pick one control (e.g., access review). Where is the evidence stored, and who can alter or delete it?”
• “Demonstrate retrieval: produce an incident record from last quarter and show it has not been modified.”
• “Where are backups for your GRC/ticketing system? Show a restore or export test.”
• “How do you prevent early deletion in SaaS tools with user-managed retention settings?”
• “How do you apply legal holds to cloud collaboration content?”

Hangups:

• Evidence scattered across email, DMs, personal drives.
• Admin roles too broad (any admin can delete or edit records without trace).
• Retention policies exist but are not configured in the tools that generate the records.

Frequent implementation mistakes (and how to avoid them)

1. Treating “records” as “documents.” Records include logs, tickets, approvals, and exports. Fix: inventory by business process, not file type.
2. No owner per record class. Fix: assign accountable owners (role-based) who approve retention and access.
3. Relying on “we can always get it from the tool.” SaaS defaults change and users delete content. Fix: configure retention and export/backup paths.
4. Ignoring integrity. A record that can be edited without trace fails its purpose. Fix: use immutable logging for audit/security logs and strict permissions for evidence repositories.
5. No disposal controls. Teams keep everything forever or delete ad hoc. Fix: implement disposal workflow + legal hold override.

Risk implications (why operators care)

Weak record protection increases:

• Certification risk: inability to demonstrate ISMS operation during surveillance and recert audits (ISO/IEC 27001 overview).
• Incident response risk: incomplete timelines and inability to validate containment steps because logs are missing or unreliable.
• Legal and contractual risk: failure to produce records during disputes, customer audits, or regulatory inquiries; accidental deletion under legal hold.
• Privacy risk: over-retention of personal data and uncontrolled copies in collaboration tools.

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Assign a single control owner for Annex A 5.33.
• Draft the Records Protection Standard and agree on what counts as a record in-scope.
• Build an initial Record Register focused on high-value evidence: risk, audit, incident, access, change, supplier due diligence.
• Identify systems of record and current retention settings (SaaS and on-prem).
• Stand up an “audit evidence repository” with controlled access and versioning.

Next 60 days (implement and prove)

• Finalize retention schedule with Legal input and document legal hold workflow.
• Configure retention and access controls in the top record systems (ticketing, GRC, SIEM/log platform, HRIS as applicable).
• Implement backup/export approach for key SaaS record systems.
• Run a retrieval drill: select multiple record categories and demonstrate you can retrieve complete, unaltered records.
• Start recurring evidence capture (calendar-based or automated). Map each evidence item to Annex A 5.33.

By 90 days (operationalize and harden)

• Expand record register coverage to remaining in-scope processes and physical records.
• Formalize disposal workflow and start logging destructions.
• Run an internal audit test specific to 5.33: sample records, verify retention, verify access, verify integrity, verify retrieval.
• Track corrective actions to closure and update the record register and procedures based on findings.
• If you use Daydream, configure continuous control monitoring and evidence collection for the systems that hold critical records so audits become a byproduct of operations (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Frequently Asked Questions

What counts as a “record” for Annex A 5.33?

Treat any information that proves a decision, action, transaction, or control operation as a record, including tickets, logs, approvals, and reports. If you would show it to an auditor or customer to prove something happened, it belongs in your record inventory (ISO/IEC 27001 overview; ISMS.online Annex A control index).

Do we need immutable storage for all records?

No. Apply stronger integrity controls to records where tampering risk is material, like security logs, incident timelines, and change approvals. For lower-risk records, controlled access, versioning, and audit trails may be sufficient (ISO/IEC 27001 overview; ISMS.online Annex A control index).

How do we handle records stored in third-party SaaS tools?

Document the SaaS system as the system of record, configure retention settings where available, and ensure you have an export/backup and retrieval procedure. Also confirm the third party contractually supports retention, legal hold, and timely access to your records.

What evidence do auditors usually sample for 5.33?

They typically pick a few record types (incident record, access approval, change approval, internal audit output) and test retention, access control, and retrievability. Plan for sampling by keeping a record register and a clean evidence repository mapped to 5.33.

We have a retention policy, but teams still keep evidence in email. Is that a failure?

It becomes a finding when you cannot consistently retrieve complete records or cannot control access and deletion. Fix it by defining approved repositories for evidence and requiring records to be saved there, with periodic sampling to validate behavior.

How do we prove “protection” without generating busywork?

Focus on system configurations and recurring sampling. Automated exports, access control reports, retention configuration screenshots/exports, and periodic retrieval drills create strong evidence with low operational overhead (ISO/IEC 27001 overview; ISMS.online Annex A control index).