ISO 27001 Data Handling Matrix Template

by Poorva Dange

ISO 27001 Data Handling Matrix Template: Guide for Creating the Document for ISO 27001

Organizations need to handle information correctly to ensure that it remains protected and compliant with the relevant data protection laws. Information security management systems help companies fulfill this requirement and demonstrate to their clients and partners that they prioritize the security of any data they take care of. One of the tools that can support ISO 27001 implementation and compliance with Annex A controls is a Data Handling Matrix. This guide will discuss what ISO 27001 data handling matrix is, why it is essential, and how to create it for one’s organization.

ISO 27001 Data Handling Matrix Template

Why Proper Handling of Information Is Vital for Achieving ISO 27001

ISO/IEC 27001 is an international standard that establishes requirements for an organization’s information security management system (ISMS). In particular, this standard focuses on protecting the organization’s information from breaches, leaks, or other unwanted interactions.

While dealing with data security, organizations need to consider all types of information they store, collect, and handle. These data may differ significantly in their classification and sensitivity – for instance, ranging from strictly private customer information to openly available marketing assets. Different data assets need to be treated differently – this is what the handling matrix helps control.

What Are the ISO 27001 Data Handling Matrix Best Practices?

A data handling matrix is a set of requirements or instructions for properly handling different classes of information. It can be a document or a sheet presented as an image, which is usually posted in all work locations.

The matrix’s primary functions are to instruct, regulate, and, ultimately, protect sensitive data through standardized and properly followed procedures. It is vital to include the following instructions in the created data handling matrix:

  • Policy Guidance – the data handling matrix should serve as a useful guide for all employees concerning the proper ways of handling different sets of information;

  • Compliance – the matrix should explicitly state what data protection regulations and standards the organization follows (for instance, ISO 27001 Annex A controls 8.2, 8.4, and 5.12, or external laws, such as GDPR or CCPA);

  • Risk Reduction – by presenting specific sets of rules, the matrix eliminates the possibility of mishandling data and reduces the associated risks greatly;

  • Standardization – creating a reliable set of instructions for all workers helps eliminate mistakes and improper data processing procedures.

The data handling matrix is a vital part of the organization’s information classification policy. In particular, it contains the necessary controls for all classes of information that the company works with. Thus, having a good understanding of how to handle this information is essential when dealing with Annex A controls related to information security.

What Main Elements Should be Included in ISO 27001 Data Handling Matrix for Better Security?

There are several critical components that should be included in the ISO 27001 data handling matrix when an organization works towards ISO/IEC 27001 compliance. These are data classification, data lifecycle, handling rules or controls, and relevant roles and responsibilities. All of these parts are interconnected and should be taken into consideration when data handling policy and procedures are established within an ISMS framework.

Classification Levels

As mentioned above, the data classification system determines how the information will be handled depending on its sensitivity and importance. It usually comprises several levels – ranging from the lowest confidentiality to the highest.

The standard way to classify data is to separate it into the following categories: Public, Internal, Confidential, and Restricted/Secret.

Data Classification Meaning Handling Instructions Reference
Public Designated for external use and contains no sensitive or confidential information Easy to handle; no special security controls required; can be shared freely Annex A 8.2 (Information classification)
Internal Designated for internal use only and contains non-sensitive information Should only be freely shared within the organization Annex A 8.2 (Information classification)
Confidential Contains sensitive, confidential, and internal information that could cause serious harm if shared Needs moderate security controls in place to protect it Annex A 8.2 (Information classification)
Restricted/Secret Contains the most sensitive data; disclosure or loss would result in grave harm to stakeholders Must be kept securely and under stringent controls (Annex A 8.2, 8.4, 8.24, 8.5, etc.)

For each level, a data handling matrix should provide specific instructions on how to store, use, transmit, process, or dispose of data to ensure its protection.

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Lifecycle of the Information

The data lifecycle is another crucial element for the data handling matrix. The data lifecycle generally comprises creation/acquisition, storage, processing, transmission, and disposal. The handling requirements for each stage should be elaborated on data classification levels in order to instruct workers with regards to the proper use and management of different categories of data.

Some data protection obligations may apply during the creation or acquisition of the information asset. For instance, encryption requirements or retention policies should be taken into consideration. When considering storage, there are further encryption requirements, alongside secure storage of data and adherence to physical security controls for paper-based information.

When it comes to processing, the data handling instructions should include guidelines concerning data anonymization, use, accessibility, and retention periods. Specific processing instructions also include limitations imposed on data transfers, storage, and physical access.

Transmitting involves securing the transfer through methods such as email and file transfer encryption, and secure communication methods. Transmission also comprises secure printing, faxing, and mailing of information, which require following certain secure practices, as well. When considering data disposal, the data handling matrix should feature guidelines on secure disposal, storage media destruction, and information redaction methods.

Another important element of the information handling matrix should feature rules and requirements that will have to be followed by different role groups: the data owners, custodians, and users.

What Are the Benefits of the ISO 27001 Data Handling Matrix?

When considering creating data handling procedures, it is also essential to bear in mind the data handling matrix benefits, which can help identify the requirements for the document better. Below are some of the main advantages of incorporating a data handling matrix into one’s information security management system:

  • A reliable information classification and consequent data handling help the organization operate reliably within the confines of Annex A. Controls covered by the data handling matrix are mostly found in Annex A paragraph 8.2 (information classification) and concern information classification, security levels, protection, and handling requirements for the data stored, processed, and transmitted by the organization.

  • By having clearly defined sets of instructions for each classification level and data lifecycle, an organization reduces the likelihood of mishandling data and associated adverse aftermath considerably. A standardized set of instructions also makes the security procedures clear for the workers, thus promoting good data security culture within the workplace.

  • Moreover, when creating the information classification and data handling instructions, the company demonstrates its commitment to the clients and stakeholders, as it visibly fulfills all legal and standard requirements for information security and data protection.

  • Additionally, ISO/IEC 27001 data handling matrix is a helpful tool for audits: the clearly defined rules help prepare a reliable set of evidence for the auditors, making the conformance verification significantly easier.

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How to Create the ISO 27001 Data Handling Matrix Template for Your Company?

Developing the data handling instructions for a company is the task of gathering, analyzing, and structuring all relevant information that concerns one’s company’s data sets. In order to structure the data handling matrix correctly, it is essential to follow several basic steps, which are as follows:

Step 1: Develop an Information Classification Policy for One’s Organization

Before making any specific data handling instructions, it is necessary to develop a reliable, clear information classification policy for the company. This policy statement should define the basic levels of data sensitivity and the corresponding security classifications.

Step 2: Identify All Information Assets Owned by the Organization

The second step focuses on identifying and analyzing all of the organization’s information assets. It involves a complete overview of how each information set is processed and stored, as well as who handles it regularly.

Step 3: Classify Information Sets According to the Developed Policy

Having defined the specific policy and identified all of the information sets owned by the organization, it is possible to proceed to data classification. This step usually involves labelling each information category with the designated security level in order to distinguish what sets of information require which level of security controls.

It is usually advisable to consult company personnel who regularly handle specific sets of data in order to provide reliable, relevant classification.

Step 4: Identify and Define Data Handling Requirements for Each Set of Information

The fourth step deals with defining data handling requirements for each data set and its processing stage. Here, it is essential to define how each set of data will be created, stored, processed, transmitted, and disposed of according to the Annex A controls.

Step 5: Define Roles and Responsibilities

The fifth step involves defining what roles are to be performed and by whom. Usually, it is appropriate to distinguish between data owners, custodians, users, and other possible role categories.

According to ISO/IEC 27001 Annex A controls, data owners are the ones responsible for ensuring that data is properly protected and secured within the organization. Custodians, in turn, are the ones who are responsible for actually implementing the protection and security measures.

Final Step: Educate and Train Company Members Regarding the New Procedures and Policy

Finally, the defined instructions should be implemented, and all the company members should be educated and trained concerning the created information classification policy and the data handling procedures.

As the handling instructions become fully implemented, it is also necessary to provide clear and easy-to-follow guidelines, which can be presented as a data handling matrix to facilitate the workers’ understanding of the created policy and rules. The data handling rules sheet should feature a presentation of the defined rules in a clear, easy-to-use manner. It is also important to conduct regular training and refreshers once the new procedures are adopted.


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