ISO 27001:2022 Clause 7.5.1 Documented Information

In this guide, I will show you exactly how to implement ISO 27001 Clause 7.5.1 and ensure you pass your audit. You will get a complete walkthrough of the control, practical implementation examples, and access to the ISO 27001 templates and toolkit that make compliance easy.

I am Stuart Barker, an ISO 27001 Lead Auditor with over 30 years of experience conducting hundreds of audits. I will cut through the jargon to show you exactly what changed in the 2022 update and provide you with plain-English advice to get you certified.

There is a lot of documentation required for ISO 27001.

Key Takeaways: ISO 27001 Clause 7.5.1 Documented Information

ISO 27001 Clause 7.5.1 defines the scope of documentation required for an Information Security Management System (ISMS). It is the foundational “Inventory Clause.” The standard operates on the premise that “if it isn’t written down, it doesn’t exist.” However, the goal is not to create a mountain of paperwork but to document exactly what is necessary to ensure the effectiveness of your security management.

Core requirements for compliance include:

• Mandatory Documents: The standard explicitly requires certain documents (like the Information Security Policy, Risk Assessment, and Statement of Applicability). These are non-negotiable.
• Necessary for Effectiveness: Beyond the mandatory list, you must document any process or procedure that is critical to your specific ISMS. If a process is complex or carries high risk (e.g., “How to configure the Firewall”), it must be documented to ensure consistency.
• Tailored Approach: The extent of documented information can differ from one organization to another. A small startup needs less documentation than a multinational bank. Complexity depends on the size of the organization and the competence of its people.
• Evidence of Operation: Documentation isn’t just policies (what you say you do); it is also records (proof that you did it). Logs, minutes from meetings, and completed forms are all “documented information” under this clause.

Audit Focus: Auditors will look for “The Evidence Gap”:

1. Missing Mandatory Docs: “I cannot find your ‘Statement of Applicability.’ This is a major nonconformity.”
2. Process vs. Reality: “You have a 50-page Incident Response policy, but your team says they just use a 1-page checklist. Your documentation does not reflect reality.”
3. Complexity Trap: “You have documented every single mouse click for onboarding a user. Is this necessary for effectiveness, or is it creating a maintenance burden you can’t keep up with?”

Mandatory Documents Checklist (Audit Prep):

Document Name	Clause Reference	Why it matters?
Scope of the ISMS	Clause 4.3	Defines what is protected (and what isn’t).
Information Security Policy	Clause 5.2	High-level commitment from leadership.
Risk Assessment Process	Clause 6.1.2	How you calculate risk (Impact x Likelihood).
Risk Treatment Plan	Clause 6.1.3	The specific actions you will take to fix risks.
Statement of Applicability (SoA)	Clause 6.1.3	The master list of which Annex A controls apply.
Objectives	Clause 6.2	Measurable security goals (e.g., “99.9% Uptime”).
Evidence of Competence	Clause 7.2	Training records and certificates for staff.
Operational Planning	Clause 8.1	Procedures for secure operations.
Risk Assessment Results	Clause 8.2	The Risk Register itself.
Internal Audit Program	Clause 9.2	The schedule of what you will audit and when.
Management Review Minutes	Clause 9.3	Proof that leadership reviewed the system.
Nonconformity Logs	Clause 10.2	Records of things that went wrong & fixes.

What is ISO 27001 Clause 7.5.1?

ISO 27001 Clause 7.5.1 Documented Information is about documentation, documentation, documentation.

The ISO 27001 standard for ISO 27001 certification wants you to document pretty much everything. It is one of the ISO 27001 controls.

Often the ISO 27001 certification is about the minutia of documentation rather than whether you are actually secure. Unless you are buying an ISO 27001 Toolkit you are going to have a lot of ISO 27001 documents to create.

Compliance with the standard may not make you more secure.

We are not here to defend it, rather to show you how to do it.

Hopefully saving you some time and money along the way.

ISO 27001 Clause 7.5.1 Definition

ISO 27001 defines ISO 27001 Documented Information as:

The organisation’s information security management system shall include:
a) documented information required by this International Standard; and
b) documented information determined by the organisation as being necessary for the effectiveness of the information security management system.

ISO 27001:2022 Clause 7.5.1 Documented Information

Watch the ISO 27001 Clause 7.5.1 Tutorial

Watch the ISO 27001 Clause 7.5.1 Documented Information tutorial – How to implement ISO 27001 Clause 7.5.1 Documented Information

ISO 27001 Clause 7.5.1 Implementation Guide 

There are many ways to document your information security management system. Some are more efficient and proven than others.

Our ISO 27001 Toolkit has been built over 20 years and is used globally by thousands of businesses who want to save vast amounts of time and money.

You may be considering an Information Security Management System online solution.

These software solutions can be a great help to information security managers in larger organisations but they come at a massive cost.

Which ever route you go .. document everything.

Guidance on Documented Information

There is further guidance provided in the ISO 27001 Annex A Controls that was revised in 2022 with changes to the ISO 27002 standard and specifically calls out required communications. Let’s take a look at what Annex A says.

In broad brush terms, without exception, everything needs documenting. Everything.

It would be fruitless to list every ISO 27001 2022 control here as we have provided a complete guide to the ISO 27001 controls that includes the ISO 27002 / Annex A controls. Just be assured that you are going to have document everything.

I am not sure I have mentioned that you will have to document everything enough.

Lets take just a couple of examples to whet your appetite:

ISO 27002 Clause 5.1 Policies for Information Security

Information security policy and topic-specific policies should be defined, approved by management, published, communicated to and acknowledged by relevant personnel and relevant interested parties, and reviewed at planned intervals and if significant changes occur.

ISO 27002 Clause 5.1 Policies for Information Security

Here we see we need to document Information Security Policies.

ISO 27002 Clause 5.24 Information security incident management planning and preparation

The organisation should plan and prepare for managing information security incidents by defining, establishing and communicating information security incident management processes, roles and responsibilities

ISO 27002 Clause 5.24 Information security incident management planning and preparation

Documenting the incident management process is a key step so that everyone knows what to do if things go wrong. The basics would be to document ‘how to report and incident’ and ‘who is responsible for information security’.

ISO 27002 Clause 6.4 Disciplinary Process

A disciplinary process should be formalised and communicated to take actions against personnel and other relevant interested parties who have committed an information security policy violation.

ISO 27002 Clause 6.4 Disciplinary Process

This is usually the function of the HR department and part of good HR practice. HR will have many documentation requirements of their own but we are interested for ISO 27001 certification in ensuring that they have documented the disciplinary process. The disciplinary process must include steps for what happens if staff breach information security.

How to comply

How do you demonstrate compliance to ISO 27001 Documented Information?

Having a documented information security management system, documented policies and document records of the effective operation of your processes will show you comply with ISO 27001 clause 7.5.1

You need the appropriate document mark up and you need to ensure that they are updated at least within the last 12 months.

Fast Track ISO 27001 Clause 7.5.1 Compliance with the ISO 27001 Toolkit

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Own Your ISMS, Don’t Rent It

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For ISO 27001 Clause 7.5.1 (Documented information), the requirement is absolute: the organization must document its entire Information Security Management System (ISMS). This includes all documentation required by the standard itself, as well as anything the organization deems necessary for its effectiveness. In the world of ISO, if it isn’t written down, it doesn’t exist.

While SaaS compliance platforms often try to sell you “automated document creation” or complex “integrated ISMS dashboards,” they cannot actually write the specific details of your unique business processes or ensure that your physical operations match your digital records, those are human governance and operational tasks. The High Table ISO 27001 Toolkit is the logical choice because it provides the documentation framework you need without a recurring subscription fee.

1. Ownership: You Own Your ISMS Documentation Forever

SaaS platforms act as a middleman for your compliance evidence. If you define your ISMS and store your required documents inside their proprietary system, you are essentially renting your own compliance status.

• The Toolkit Advantage: You receive the Documents and Records Policy and every single mandatory template in fully editable Word/Excel formats. These files are yours forever. You maintain permanent ownership of your standards (such as your specific disciplinary process or incident management plans), ensuring you are always ready for an audit without an ongoing “rental” fee.

2. Simplicity: Governance for Real-World Documentation

Clause 7.5.1 is about evidence and record-keeping. You don’t need a complex new software interface to manage what a well-structured set of Word policies and Excel records already do perfectly.

• The Toolkit Advantage: Your team already handles data and documents daily. What they need is the governance layer to prove to an auditor that every mandatory part of the standard is covered. The Toolkit provides auditor-approved templates that formalize your existing work into a compliant framework, without forcing your team to learn a new software platform just to look up a policy.

3. Cost: A One-Off Fee vs. The “Document Count” Tax

Many compliance SaaS platforms charge more based on the number of “documents,” “users,” or “approval workflows” you manage. For a clause that requires you to document nearly everything, these monthly costs can scale aggressively for very little added value.

• The Toolkit Advantage: You pay a single, one-off fee for the entire toolkit. Whether you manage 50 documents or 500, the cost of your ISMS Documentation Framework remains the same. You save your budget for actual security improvements rather than an expensive compliance dashboard.

4. Freedom: No Vendor Lock-In for Your Security Strategy

SaaS tools often mandate specific ways to report on and monitor “documented information.” If their system doesn’t match your unique branding or specialized industry requirements, the tool becomes a bottleneck to efficiency.

• The Toolkit Advantage: The High Table Toolkit is 100% technology-agnostic. You can tailor the Documentation Procedures to match exactly how you operate, whether you use a centralised “Operations Manual” approach or decentralised team-based storage. You maintain total freedom to evolve your security strategy without being constrained by the technical limitations of a rented SaaS platform.

Summary: For Clause 7.5.1, the auditor wants to see a complete, documented ISMS with the appropriate version control and management approval (e.g., policy documents and records of effective operation). The High Table ISO 27001 Toolkit provides the governance framework to satisfy this requirement immediately. It is the most direct, cost-effective way to achieve compliance using permanent documentation that you own and control.

What are the ISO 27001:2022 Changes to ISO 27001 Documented Information?

Great news. There are no material changes to ISO 27001 Clause 7.5.1 in the 2022 update. There is a general update across the standard to replace the words ‘International Standard’ to the word ‘document’. But this is not material but refers to how the standard refers to itself in the text.

ISO 27001 Clause 7.5.1 Templates

ISO 27001 templates are a great way to implement your information security management system. Whilst an ISO 27001 Toolkit can save you up to 30x in consulting fees and allow you to deliver up to 10x faster these individual templates help meet the specific requirements of ISO 27001 clause 7.5.1

ISO 27001 Clause 7.5.1 FAQ