ISO 27001:2022 Annex A 5.14 Information transfer for AI Companies

ISO 27001 Annex A 5.14 Information transfer is a security control that mandates organizations to establish rules, procedures, and agreements for secure data exchange. For AI companies, this control is essential to prevent interception of model weights and training datasets, ensuring integrity and confidentiality across high-stakes digital and physical transfer channels.

The core purpose of ISO 27001 Annex A 5.14 Information transfer is ensuring the security of your information whenever it moves. While this control is a fundamental requirement for any business, it presents high-stakes challenges for AI companies. You aren’t just emailing PDFs; you are piping terabytes of sensitive training data between S3 buckets, pushing proprietary weights to Hugging Face, and streaming inference data to mobile edge devices.

Information ‘in transit’ is at its highest risk. For an AI company, this includes your training datasets, proprietary algorithms, and the models that power your revenue. A single intercepted API call or a misconfigured bucket transfer isn’t just a breach; it is a competitor’s payday. This guide breaks down Annex A 5.14 for the AI stack.

The “No-BS” Translation: Decoding the Requirement

Let’s strip away the academic language. Annex A 5.14 is about defining the rules of the road for your data. It stops your Junior Dev from WeTransferring your customer database to a contractor.

The Auditor’s View (ISO 27001)	The AI Company View (Reality)
“Information transfer rules, procedures and agreements shall be in place for all types of transfer facilities.”	Define the Safe Channels. If you send code, use Git over SSH. If you send passwords, use 1Password. If you send datasets, use a private S3 link. Do not send passwords via Slack DM.
“Information transferred in electronic messaging shall be protected.”	Encryption is mandatory. TLS 1.2+ for everything. Don’t use FTP. Don’t use HTTP. If you are piping data between microservices, use mTLS.
“Transfer policies shall cover physical media.”	Don’t mail hard drives unencrypted. If you have to ship a drive full of training data to a data centre, it better be BitLocker encrypted, and you better track the FedEx number.

The Business Case: Why This Actually Matters for AI Companies

Why should a founder care about “transfer protocols”? Because insecure transfers are the easiest way to leak IP without being hacked.

The Sales Angle

Enterprise clients will ask: “How is data protected in transit?” and “Do you allow data transfer to personal devices?”. If your answer is “We use standard protocols,” that is weak. If your answer is “We enforce TLS 1.3 for all external traffic, block USB storage on all endpoints, and require Data Transfer Agreements for all third parties,” you win the contract. Annex A 5.14 proves you control the flow of data.

The Risk Angle

The “Man-in-the-Middle” Attack: If you transfer model weights over HTTP or an unverified connection, an attacker can intercept and modify them. They could inject a “backdoor” into your model that triggers only on specific inputs. You would deploy a compromised model to production without knowing. Secure transfer protocols (hashing/signing) prevent this.

DORA, NIS2 and AI Regulation: Secure Pipes Required

Regulators are obsessed with how data moves between entities. Annex A 5.14 is your compliance shield.

• DORA (Article 9): Requires financial entities to ensure the security of data transfer channels. If you feed data into a bank’s AI system, your API transfer protocols must meet their high standards.
• NIS2 Directive: Focuses on supply chain security. You must secure the data flows between you and your suppliers (e.g., data labelling firms). Unsecured email transfers of data are a direct violation.
• EU AI Act: High-risk AI systems must ensure data governance. This includes the integrity of training data. If data is corrupted during transfer from storage to training, your model is non-compliant.

ISO 27001 Toolkit vs SaaS Platforms: The Transfer Trap

SaaS platforms often fail to capture the nuance of how AI companies move data. Here is why the ISO 27001 Toolkit is the better choice.

Feature	ISO 27001 Toolkit (Hightable.io)	Online SaaS Platform
Customisation	Protocol Agnostic. Define rules for gRPC, REST, SFTP, or physical couriers in a Word doc. It adapts to your stack.	Web-Centric. Most platforms assume you only use HTTPS. They struggle to document complex MLOps pipelines or physical data shipments.
Ownership	Your Agreements. You keep the Data Transfer Agreements (DTAs) signed by your partners.	Rented Process. If you leave the platform, you lose the audit trail of approved transfer methods.
Simplicity	A Policy Document. Engineers read a clear policy: “Do not use WeTransfer.” Simple.	Confusion. Platforms try to “monitor” transfers, often generating thousands of false positive alerts that teams ignore.
Cost	One-off fee. Pay once, secure forever.	Subscription Bloat. Paying monthly for a tool that just lists your approved transfer methods is a waste of capital.

The Unique Transfer Risks in AI Workflows

Standard information transfer risks—like a misaddressed email—are magnified in an AI context. Here is what Annex A 5.14 looks like in your world.

Exposure of Sensitive Training Datasets

Transferring a multi-terabyte dataset containing PII to an offshore data labelling partner via an unencrypted S3 bucket is a disaster waiting to happen. Annex A 5.14 requires you to define the only allowed method for this (e.g., “Private S3 Link with IP Whitelisting”).

Disruption of Algorithmic and MLOps Processes

Imagine a man-in-the-middle attack that alters a neural network model file during transfer. If you use Python’s pickle format, this is even worse—they can execute arbitrary code on your servers. Annex A 5.14 mandates the use of secure formats (like .safetensors) and integrity checks (SHA256 hashes) during transfer.

Vulnerabilities in the AI Supply Chain

You push models to Hugging Face or pull base models from OpenAI. Each of these is a transfer. Using unofficial tools or personal API keys to bypass rate limits (“Shadow IT”) creates invisible data leaks. You must formally approve these channels.

Understanding the Core Demands of Annex A 5.14

Compliance with Annex A 5.14 is not about having a policy document; it’s about proving that the policy lives in your daily operations.

• Comprehensive Policy: You must have an “Information Transfer Policy.” It defines how you move data.
• Fit-for-Purpose Protection: Don’t encrypt the lunch menu. Do encrypt the model weights. Apply protection proportional to the classification (Annex A 5.12).
• Verifiable Audit Trail: If you transferred data, prove it. System logs (AWS CloudTrail) are your best friend here.

Your Actionable Roadmap for Compliance

The standard explicitly covers three distinct methods of information transfer.

Securing Electronic Transfers

• Encryption: Mandate TLS 1.2 or higher for all web traffic. Enforce encryption at rest for transfer staging areas (e.g., S3 buckets).
• Strong Authentication: Use API Keys or OAuth tokens for machine-to-machine transfers. Never transfer data to an unauthenticated endpoint.
• pre-signed URLs: For large file transfers, use short-lived pre-signed URLs instead of long-lived credentials.

Securing Physical Media Transfers

If you must ship a hard drive (e.g., AWS Snowball):

• Encryption: The drive must be encrypted (BitLocker/FileVault).
• Tracking: Use a courier with end-to-end tracking and signature requirement.
• Tamper-Evidence: Use tamper-evident bags. If the bag is open, do not mount the drive.

Securing Verbal Transfers

Don’t talk about the new architecture in the coffee shop.

• Environment: Discuss “Confidential” data only in secure meeting rooms or private calls.
• Verification: If someone calls asking for data, verify their identity (call them back on a known number) before “verbally transferring” the password.

The Evidence Locker: What the Auditor Needs to See

When the audit week arrives, prepare these artifacts:

• Information Transfer Policy (PDF): The signed document setting the rules.
• Data Transfer Agreements (DTAs): Signed contracts with your data labellers or third-party vendors.
• Transfer Logs (CSV): An export from AWS CloudTrail or your MFT (Managed File Transfer) solution showing a secure transfer.
• Configuration Screenshots (Images): Evidence that you enforce TLS 1.2+ on your load balancers.

Common Pitfalls & Auditor Traps

Here are the top 3 ways AI companies fail this control:

• The “Slack DM” Leak: You have a policy that says “No secrets in Slack,” but the auditor finds a PEM key in a screenshot of a Slack channel. Instant non-conformity.
• The “WeTransfer” Habit: Employees use free file transfer tools because the corporate VPN is slow. This is “Shadow IT” and a major transfer risk.
• The “Unsigned” API: You send data to an internal API without mutual TLS (mTLS) or signing. An attacker on the network can spoof the transfer.

Handling Exceptions: The “Break Glass” Protocol

Sometimes, the VPN breaks, and you need to send a log file to support now. You need a protocol for this.

The Emergency Transfer Workflow:

• Trigger: Standard secure channels are unavailable during a P0 incident.
• Approval: CTO/CISO approves use of an alternative method (e.g., Encrypted Signal Message).
• Mitigation: File is encrypted with a strong password before upload. Password sent via a separate channel.
• Log: Incident ticket records the exception and the file hash.

The Process Layer: “The Standard Operating Procedure (SOP)”

How to operationalise A 5.14 using your existing stack (AWS, Slack).

• Step 1: Classification (Automated). Check the tag on the S3 bucket. If Confidential, proceed to Step 2.
• Step 2: Encryption (Automated). Ensure the transfer channel (HTTPS) is encrypted. If transferring to a partner, encrypt the file with their public PGP key.
• Step 3: Transfer (Manual/Automated). Initiate the transfer using the approved tool (e.g., aws s3 cp).
• Step 4: Verification (Automated). Compute the SHA256 hash of the received file and compare it to the source. If they match, success.

Ultimately, the High Table toolkit is more than just a compliance tool; it’s a strategic advantage. It allows you to turn the rigorous demands of ISO 27001 into a source of operational resilience and a powerful demonstration of trust to your clients and partners.

ISO 27001 Annex A 5.14 for AI Companies FAQ

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