What evidence do auditors commonly ask for on A.5.33 Protection of records?

Statement of Applicability entry for control A.5.33, showing inclusion or justified exclusion, implementation status and the risks it treats; Records handling guidelines covering storage, chain of custody, tamper prevention and disposal, aligned with the records management policy; A retention schedule listing record types, retention periods, legal basis and permitted storage media; Evidence of controlled destruction at the end of retention periods; Procedures and tests demonstrating that electronic records remain readable across format and technology changes.

What is the most common gap auditors find on A.5.33?

No retention schedule exists, so records are either kept forever or deleted early

ISO/IEC 27001:2022 · Organizational controls

`A.5.33` Protection of records

Records are to be safeguarded against being lost, destroyed, falsified, accessed without authorization or released without authorization. Purpose (stated in ISO/IEC 27002:2022): ensures compliance with legal, regulatory and contractual obligations and societal expectations for protecting and keeping records available. As an Annex A reference control, it is compared with the controls determined in risk treatment (6.1.3 c) and recorded in the Statement of Applicability as included or excluded, with the justification and implementation status (6.1.3 d); implementation guidance is ISO/IEC 27002:2022 5.33.

Source: ISO/IEC 27001:2022, A.5.33. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27001:2022 in the compliance library.

Clauses 4 to 10 are the management-system requirements: none of them can be excluded when an organisation claims conformity. The 93 Annex A controls are a reference set: one may be excluded with a justification in the Statement of Applicability. Certification bodies assess conformity; the evidence lists here are what auditors commonly ask for, not a list the standard prescribes.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Evidence of controlled destruction at the end of retention periods · Data governance / DLP tooling
Procedures and tests demonstrating that electronic records remain readable across format and technology changes · Policy repository / GRC workspace

governing documentDocuments that govern the control

Statement of Applicability entry for control A.5.33, showing inclusion or justified exclusion, implementation status and the risks it treats · Policy repository / GRC workspace
Records handling guidelines covering storage, chain of custody, tamper prevention and disposal, aligned with the records management policy · Policy repository / GRC workspace
A retention schedule listing record types, retention periods, legal basis and permitted storage media · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

No retention schedule exists, so records are either kept forever or deleted early
Encrypted archives cannot be opened because the keys were not retained
Legacy formats can no longer be read and no migration was planned
Records are held in systems that allow alteration without any audit trail

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

A.5.32 Intellectual property rights · A.5.34 Privacy and protection of personal identifiable information (PII)