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ISO 27001 controls
You cannot protect what you have not listed, or protect it well if everything looks the same.
Five controls cover assets: knowing what you hold, setting rules for its use, getting it back when people leave, classifying information by how much harm its exposure would do, and labelling it so people can tell. Done well, they become the backbone of the risk assessment. Done badly, they become a spreadsheet nobody trusts.
Back to ISO 27001 services01 · The five controls
Five controls that build on each other
List it, set the rules, get it back, rank it, mark it.
- 5.9Inventory of information and other associated assetsKeep a current list of information and the things that hold or process it, each with an owner.
- 5.10Acceptable use of information and other associated assetsWrite and share the rules for how people may use and handle them.
- 5.11Return of assetsRecover company equipment and information when someone leaves or a contract ends.
- 5.12Classification of informationSort information into levels by its sensitivity and importance.
- 5.13Labelling of informationMark information so its level is visible to the people handling it.
02 · The inventory
An inventory that stays true
Owners and sources matter more than columns.
The inventory covers more than laptops. It includes information assets (customer data, source code, contracts), the systems that hold them, the services you rely on, and the devices people use. Group them sensibly: one line per database is useful, one line per document is not.
- A named owner. A person accountable for the asset's protection and for approving access, not a team name.
- Classification. The level from your scheme, set by the owner.
- Location. Where it lives: a platform, region, office or device.
- Source of truth. The tool that keeps the line current, such as device management, the cloud console or the HR system.
- Link to risk. A reference to the risks that concern this asset.
Feed the inventory from systems that already know: device management for endpoints, the cloud account for infrastructure, the finance system for SaaS subscriptions. A hand-kept list drifts within months.
03 · Classification
Designing a classification scheme
Few levels, clear examples, handling rules people can follow.
The standard does not prescribe levels. Most companies settle on three or four. More levels sound precise but leave people guessing, and a guess defeats the point. Each level needs plain examples and rules for storing, sharing and disposing.
| Level | Illustrative data | Handling rules |
|---|---|---|
| Public | Marketing pages, published policies, job ads | Approved for release; no restriction once published |
| Internal | Org charts, internal wiki, routine email | Company systems only; share outside under agreement; normal disposal |
| Confidential | Customer data, contracts, financials, source code | Access by role; encrypted at rest and in transit; external sharing approved by owner; secure deletion |
| Restricted | Encryption keys, credentials, regulated personal or health data | Named individuals only; strongest access controls; access logged and reviewed; no copies on personal devices |
When data of several levels sits together, the set takes the highest level. A spreadsheet with one column of customer health data is Restricted.
04 · Labelling
Labelling in practice
Mark what people handle; let systems carry the rest.
- Document templates with the level in the header or footer
- Sensitivity labels in the email and file platform, where it offers them
- Tags on cloud resources and databases recording their level
- A default rule: anything unlabelled is treated as Internal
- No physical labels needed for data that never leaves a system, if the system records the level
Acceptable use (5.10) ties it together: the policy tells people what each label means for them. Return of assets (5.11) closes the loop at exit, through the leaver checklist that HR and IT both sign.
05 · Feeds risk
How the inventory feeds risk assessment
Assets and levels decide where risk work starts.
- The inventory lists what can be harmed.
- Classification says how much harm exposure, alteration or loss would cause.
- Owners judge threats and weaknesses for their assets with the security lead.
- Risks for Confidential and Restricted assets are assessed first and in most depth.
- Treatment choices go back to the asset line, so the auditor can trace both ways.
Small company
One register
- Inventory as a sheet fed by exports from device and cloud tools
- Three or four levels in a one-page standard
- Labels on templates and key folders
- Leaver checklist covering devices and access
Large company
A connected system
- Asset management database synced with discovery tools
- Automatic labelling and data loss prevention rules by level
- Classification reviewed by owners on a schedule
- Return of assets tracked in the HR workflow
06 · Evidence
What an auditor samples, and common gaps
They test the inventory against reality.
- The inventory, checked against a list the auditor draws from another source such as device management
- The classification standard and acceptable use policy, with staff acknowledgment
- A sample of documents or systems, checked for the right label or tag
- Leaver records showing devices and information returned
- Inventory with no owners. A list of things without accountable people does not meet 5.9.
- Too many levels. Six levels nobody can tell apart lead to everything marked Confidential.
- Rules without examples. "Sensitive data" with no examples leaves each person to decide.
- Labels only on paper. A scheme that ignores email, files and cloud storage misses most of the data.
- Leavers' devices untracked. No return record for a departed engineer's laptop is a finding under 5.11.
Sources: ISO/IEC 27001:2022 Annex A control names 5.9 to 5.13; ISO/IEC 27002:2022 as background (not quoted); clause 6.1.2 of ISO/IEC 27001:2022 on information security risk assessment, by title. The classification levels and examples are our own illustration.
Asset and classification questions
How many classification levels should we have?
Usually three or four.
The standard leaves it to you. Fewer levels are easier to apply correctly. Pick the smallest number that still separates data needing very different handling.
Does every file need a visible label?
No. Label what people handle and share.
Visible labels matter where people make handling decisions, such as documents and email. For data inside a system, a tag or a recorded level can be enough, combined with a default for anything unlabelled.
Is a list of laptops an asset inventory?
It is one part of it.
The inventory under 5.9 covers information and the assets associated with it: data sets, systems, services and devices. A device list alone leaves out what matters most.
Who should classify information?
The asset owner, using the published scheme.
The owner knows the data best. Security writes the scheme and checks a sample. Creators of new documents apply labels using the examples in the standard.
Related guides
Build an inventory your risk assessment can stand on.
An ISO 27001 gap analysis tests your inventory, classification and labelling against 5.9 to 5.13 and shows what to fix first.