Annex A 7.10: Storage Media
Annex a 7.10: storage media requirement means you must control the full lifecycle of storage media (physical and virtual) so information is protected during use, transport, reuse, and disposal. Operationalize it by inventorying media types, defining handling rules by data classification, restricting use and movement, encrypting where feasible, and retaining auditable records that prove the process runs.
Key takeaways:
- Treat “storage media” as a lifecycle control: issuance, use, movement, storage, reuse, and destruction all need rules and evidence.
- Most audit failures are evidence failures: you did work, but can’t prove it consistently across teams and third parties.
- Make it executable with a media standard, approvals for removable media, encryption requirements, and certified destruction with chain-of-custody.
Compliance leaders usually get tripped up on Annex A 7.10 because it looks “IT-ish,” but auditors test it as a governance and evidence control. Storage media is any mechanism that can hold information: laptops and servers, removable USB drives, external hard drives, backup tapes, mobile devices, paper records, and cloud snapshots. The operational goal is simple: prevent data loss, unauthorized disclosure, and integrity issues caused by mishandled media across its lifecycle.
This requirement shows up in real operations where exceptions happen: a developer copies logs to a USB stick, a third party ships a drive for data migration, a team decommissions old laptops, or backup tapes go offsite. If you don’t have clear rules, approvals, and records, those moments become uncontrolled data exfiltration paths.
This page gives requirement-level implementation guidance you can hand to IT, Security Operations, Workplace/IT Asset Management, and Procurement/TPRM. It prioritizes actions you can implement quickly, along with the specific artifacts an ISO 27001 auditor will ask for. Control intent and framing align to ISO/IEC 27001 and Annex A summaries 1.
Regulatory text
Provided excerpt: “ISO/IEC 27001:2022 Annex A control 7.10 implementation expectation (Storage Media).” 1
What the operator must do (requirement meaning): Implement documented, consistently followed controls for how storage media is selected, authorized, protected, transported, reused, and securely disposed of, so information on that media remains confidential, intact, and available as required. Your auditor will expect this to be practical and testable, not a policy that lives in a wiki. 1
Plain-English interpretation
Annex a 7.10: storage media requirement expects you to prevent “easy” data loss paths by controlling:
- What media is allowed (and what is banned).
- Who can write data to media (and under what approval).
- How data is protected on the media (encryption, access controls, labeling).
- How media moves (shipping, couriers, check-out/check-in, offsite storage).
- How media is reused or retired (wiping, degaussing, shredding, certified destruction).
- How you prove it happened (logs, tickets, certificates, inventories).
If you can demonstrate lifecycle control and evidence, auditors typically accept that your approach is risk-based and scoped to your environment. 1
Who it applies to (entity and operational context)
Applies to: Any organization implementing ISO/IEC 27001, especially service organizations handling customer data or regulated data, where storage media is issued to staff, used in production operations, or handled by third parties. 1
Operational areas in scope (typical):
- End-user computing: laptops, desktops, mobile devices, local storage, printing.
- Infrastructure and operations: servers, SAN/NAS, backup appliances, tape libraries, removable drives used for break-glass recovery.
- Cloud operations: cloud block storage snapshots, object storage lifecycle policies, image backups (treat as “media equivalents” in procedure).
- Workplace/Facilities: secure storage cabinets, shredding consoles, mailroom shipping controls.
- Third parties: offsite backup storage, e-waste recyclers, managed IT providers, data center movers.
What you actually need to do (step-by-step)
Use this sequence to make the control testable quickly.
1) Define “storage media” for your ISMS scope
Create a one-page definition and list of media types you control:
- Physical: USB drives, external HDD/SSD, backup tapes, DVDs, printed records, decommissioned drives.
- Embedded: laptop SSDs, server disks, mobile devices.
- Logical equivalents: cloud snapshots/backup images and exports, where your process controls serve the same purpose.
Output: Storage Media Standard (or section within your Information Handling Standard) mapped to Annex A 7.10. 2
2) Classify data and map protections to media handling rules
Build a simple matrix that binds data classification to handling requirements.
Example decision matrix (adapt to your taxonomy):
| Data type | Allowed on removable media? | Encryption required? | Transport allowed? | Destruction requirement |
|---|---|---|---|---|
| Public | Yes | Recommended | Yes | Standard disposal |
| Internal | By exception | Yes | With tracking | Verified wipe or destruction |
| Confidential/Customer | Only with documented approval | Yes (strongly required) | Only with chain-of-custody | Certified destruction |
| Restricted (secrets/keys) | No | N/A | N/A | N/A |
Output: Data Classification-to-Media Handling Matrix approved by Security and IT. 3
3) Control removable media through policy + technical enforcement
For most environments, the highest-risk gap is uncontrolled USB storage.
Operational controls to implement:
- Default deny: block mass storage devices on endpoints except approved device IDs or approved roles.
- Exception workflow: require a ticket with business justification, data type, encryption method, and return/destruction plan.
- Approved encrypted media: issue organization-owned encrypted drives when exceptions are granted.
- Logging: retain endpoint logs or DLP events that show device insertion and file transfer where feasible.
Evidence goal: Show you can prevent casual copying, and exceptions are governed and recorded. 2
4) Secure storage and movement (on-site and off-site)
Define and enforce:
- Secure storage locations for media not in use (locked cabinets/rooms, access lists).
- Check-out/check-in for portable media and backup media (who, what, when, purpose).
- Transport controls: tamper-evident packaging, approved couriers, tracking numbers, and documented chain-of-custody.
- Third-party handling: contract clauses requiring secure transport and destruction, plus proof (see third-party section below).
Evidence goal: You can reconstruct who had the media and when, especially during shipping. 3
5) Reuse, sanitization, and secure disposal
This is where audits often go from “policy review” to “show me the proof.”
Implement:
- Sanitization standard by media type (wipe vs cryptographic erase vs physical destruction).
- Disposition workflow integrated with IT asset management: decommission request, approval, execution, verification, closure.
- Destruction proof: certificates of destruction from e-waste or shredding providers; internal verification logs for wiping.
Add spot checks: sample disposed assets monthly/quarterly for completed paperwork and proof.
Evidence goal: No device leaves your control without a documented, verified sanitization/destruction step. 2
6) Manage third parties that handle your media
Treat this as a third-party risk control as much as a security control.
Minimum requirements for third parties who store, transport, wipe, or destroy media:
- Contract terms: confidentiality, secure handling, incident notification, subcontractor controls.
- Operational proof: chain-of-custody records, destruction certificates, facility/security attestations if available.
- Right to audit or periodic reviews: you need a mechanism to re-validate performance.
Practical tip: If you cannot obtain strong evidence from the third party, you can reduce scope by changing the operating model (for example, cryptographic erase before shipping drives out). 3
7) Make it auditable: map 7.10 to recurring evidence capture
The fastest path to assessment readiness is a repeatable evidence package.
Set up:
- A control owner (IT Asset Manager, Security Ops, or GRC).
- A control operating cadence (ongoing, with periodic sampling).
- A central evidence folder structure aligned to the control’s lifecycle.
Daydream can help by turning Annex A 7.10 into a control checklist and evidence request list that runs on a schedule, so teams provide the same artifacts each cycle rather than rebuilding them during the audit. 1
Required evidence and artifacts to retain
Auditors typically want both design evidence (documents) and operating evidence (records).
Design artifacts
- Storage Media Standard / Media Handling Procedure (mapped to Annex A 7.10). 2
- Data classification policy and handling matrix for media. 3
- Removable media exception process (ticket workflow definition, approvals required).
- Sanitization and disposal standard (by media type).
- Third-party requirements for media handling (contract addendum language or security requirements).
Operating artifacts
- Inventory of organization-issued encrypted removable media (issuance records).
- Endpoint control evidence (configuration screenshots/export, device control policy, DLP policy, or MDM settings) and sample logs.
- Media movement logs: check-out/check-in sheets, shipping manifests, tracking, chain-of-custody forms.
- Disposal records: wipe logs, cryptographic erase logs, decommission tickets, certificates of destruction.
- Sampling reports: periodic review results with exceptions and remediation actions.
Common exam/audit questions and hangups
Expect these questions and prepare “show me” answers:
-
“What counts as storage media here?”
Have your defined list and scope statement ready, including how you treat cloud backups/snapshots. -
“Can employees use USB drives?”
Answer with your default stance, technical enforcement, and exception workflow; provide sample tickets and device inventory. -
“How do you ensure media is sanitized before disposal?”
Provide the procedure and a sample of closed disposal records with proof (wipe logs or destruction certificates). -
“How do you control third parties who destroy drives?”
Show contracts, due diligence, and the evidence you receive per destruction event. -
“How do you know the control works?”
Show a recurring sampling plan and results, including exceptions tracked to closure.
Frequent implementation mistakes and how to avoid them
| Mistake | Why it fails in audits | Fix |
|---|---|---|
| Policy says “encrypt removable media,” but no enforcement | Auditors test implementation, not intent | Implement endpoint device control, issue approved encrypted drives, and keep exception tickets |
| “Disposal” is handled informally by IT | No chain-of-custody; no proof of sanitization | Tie disposal to asset management workflow and require wipe/destruction evidence to close tickets |
| Third-party destruction without certificates | You can’t prove data was destroyed | Require certificates and chain-of-custody in contract and procurement checklist |
| No definition of what “media” includes | Gaps appear (paper records, tapes, exports) | Publish a media taxonomy and update annually or when new tech is introduced |
| Evidence is scattered across teams | Audit becomes a scramble | Centralize evidence collection and assign a single control owner |
Enforcement context and risk implications
No public enforcement cases were provided in the source catalog for this specific ISO control, so this page avoids naming enforcement outcomes without citations. Practically, weak storage media controls increase the likelihood and impact of data exposure events through lost devices, mis-shipped drives, improper disposal, and uncontrolled exports. That risk often shows up as customer audit findings, failed ISO surveillance audits, and contractual noncompliance with customer security requirements. 3
Practical 30/60/90-day execution plan
Use phased execution (not calendar-bound commitments) to get to auditable operation quickly.
First 30 days (establish control design + stop the biggest leaks)
- Assign a control owner and define storage media types in scope.
- Publish a Storage Media Standard with clear “allowed vs prohibited” rules.
- Decide default stance on removable media and set an exception process.
- Start a media inventory for any organization-issued removable drives.
- Select required evidence items and set up a central evidence repository.
Days 31–60 (implement operational workflows + third-party controls)
- Implement or tighten endpoint controls for USB/mass storage; document configurations.
- Implement check-out/check-in and transport chain-of-custody for portable media and backups.
- Update third-party contracts or add security addenda for media storage/destruction providers.
- Define sanitization and disposal workflow integrated with asset management tickets.
Days 61–90 (prove ongoing operation + close audit gaps)
- Run a sampling cycle: removable media exceptions, shipments, and disposal records.
- Remediate exceptions and document corrective actions.
- Conduct a tabletop: “lost encrypted drive” or “mis-shipped backup media” to validate incident hooks.
- Package the evidence set for audit: design docs + operating samples + sampling results.
Frequently Asked Questions
Does Annex a 7.10: storage media requirement cover cloud backups and snapshots?
Yes in practice, because they function as stored copies of information that can be exported, retained, or deleted. Treat them as “media equivalents” and document lifecycle controls for creation, access, retention, and secure deletion aligned to your procedures. 3
Are USB drives completely prohibited under ISO 27001?
ISO 27001 does not mandate a blanket ban in the excerpt provided. Auditors look for defined rules, risk-based exceptions, and evidence that controls are enforced and monitored. 2
What evidence is strongest for secure disposal?
Closed decommission tickets tied to asset IDs, wipe/erase logs (or system outputs), and certificates of destruction from a qualified third party form a strong evidence set. Pair them with a documented sanitization standard so auditors can see what “done” means. 2
How do we handle employee-owned devices that might store company data?
Treat BYOD endpoints as storage media in scope if they can store or cache company information. Use MDM controls, containerization rules, and offboarding steps that include secure removal of corporate data, then retain evidence of policy enforcement. 3
What should we require from a third party that destroys drives?
Require chain-of-custody documentation, certificates of destruction per batch or asset, incident notification obligations, and limits on subcontracting. Keep those records with your asset disposition tickets to prove end-to-end lifecycle control. 3
How do we make this control sustainable for audits?
Convert it into a recurring evidence routine: monthly or quarterly sampling of exceptions, shipments, and disposals, with documented results and remediation. Daydream can track the control, schedule evidence requests, and keep artifacts audit-ready without rebuilding the package each assessment cycle. 1
Footnotes
Frequently Asked Questions
Does Annex a 7.10: storage media requirement cover cloud backups and snapshots?
Yes in practice, because they function as stored copies of information that can be exported, retained, or deleted. Treat them as “media equivalents” and document lifecycle controls for creation, access, retention, and secure deletion aligned to your procedures. (Source: ISO/IEC 27001 overview)
Are USB drives completely prohibited under ISO 27001?
ISO 27001 does not mandate a blanket ban in the excerpt provided. Auditors look for defined rules, risk-based exceptions, and evidence that controls are enforced and monitored. (Source: ISMS.online Annex A control index)
What evidence is strongest for secure disposal?
Closed decommission tickets tied to asset IDs, wipe/erase logs (or system outputs), and certificates of destruction from a qualified third party form a strong evidence set. Pair them with a documented sanitization standard so auditors can see what “done” means. (Source: ISMS.online Annex A control index)
How do we handle employee-owned devices that might store company data?
Treat BYOD endpoints as storage media in scope if they can store or cache company information. Use MDM controls, containerization rules, and offboarding steps that include secure removal of corporate data, then retain evidence of policy enforcement. (Source: ISO/IEC 27001 overview)
What should we require from a third party that destroys drives?
Require chain-of-custody documentation, certificates of destruction per batch or asset, incident notification obligations, and limits on subcontracting. Keep those records with your asset disposition tickets to prove end-to-end lifecycle control. (Source: ISO/IEC 27001 overview)
How do we make this control sustainable for audits?
Convert it into a recurring evidence routine: monthly or quarterly sampling of exceptions, shipments, and disposals, with documented results and remediation. Daydream can track the control, schedule evidence requests, and keep artifacts audit-ready without rebuilding the package each assessment cycle. (Source: ISO/IEC 27001 overview; ISMS.online Annex A control index)
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