ISO 27001 Document and Record Policy is a security control that establishes a framework for managing an organization’s Information Security Management System (ISMS) documentation. The primary implementation requirement is standardizing document creation, version control, and secure storage, which provides the business benefit of ensuring information integrity, preventing version mix-ups, and providing clear audit evidence.
ISO 27001 Document and Record Policy
In this guide, you will learn what an ISO 27001 Document and Record Policy is, how to write it yourself and I give you a template you can download and use right away.
Table of contents
- ISO 27001 Document and Record Policy
- What is an ISO 27001 Document and Record Policy?
- ISO 27001 Document and Record Policy Example
- How to write an ISO 27001 Document and Record Policy
- ISO 27001 Document and Record Policy Walkthrough Video
- How to implement ISO 27001 Document and Record Policy
- How to audit ISO 27001 Document and Record Policy
- ISO 27001 Document and Record Policy Template
- How the ISO 27001 toolkit can help
- Applicability of an ISO 27001 Document and Record Policy to Small Businesses, Tech Startups, and AI Companies
- Information security standards that need an ISO 27001 Document and Record Policy
- ISO 27001 Document and Record Policy Applicable Laws and Related Standards
- Related ISO 27001 Controls and Further Reading
- ISO 27001 Document and Record Policy FAQ
What is an ISO 27001 Document and Record Policy?
An ISO 27001 Document and Record Policy is your company’s simple rulebook for handling important paperwork and digital files. Think of it as a guide to help you keep things organised, up-to-date, and safe. It’s all about making sure you know where your documents are, what they say, and who can see them.
This policy is a set of guidelines that tells you and your team how to manage all your important documents and records. It covers everything from creating and approving documents to storing, updating, and getting rid of them. The goal is to make sure your information is accurate, available when you need it, and secure.
This ISO 27001 Document and Record Policy summary outlines the critical framework required to manage ISMS documentation. From initial creation to secure disposal, these requirements ensure that your information security governance remains accurate, accessible, and auditable.
| Aspect | Requirement Context | Implementation Objective |
|---|---|---|
| Why | Maintain ISMS integrity and provide audit evidence. | To prevent version mix-ups and ensure a single source of truth for security protocols. |
| When | At the onset of building the Information Security Management System. | To lay the groundwork for all subsequent security documents, such as password or incident policies. |
| Who | All personnel, from interns to senior management and IT staff. | To ensure a unified team effort in handling sensitive information and records. |
| Where | Applicable across shared drives, physical cabinets, and cloud environments. | To maintain consistent security rules regardless of physical location or remote work status. |
| How | Policy dissemination, training, and structured folder management. | To establish a repeatable system for managing, checking, and auditing document compliance. |
ISO 27001 Document and Record Policy Example
An example ISO 27001 Document and Record Policy:
How to write an ISO 27001 Document and Record Policy
Writing the policy should be easy and straightforward. Start with an introduction that explains its purpose. Then, create sections for how to create, review, approve, distribute, store, and get rid of documents. Use simple language and avoid jargon so everyone can understand it.
Time needed: 1 hour and 30 minutes.
How to write an ISO 27001 Document and Record Policy
- Create your version control and document mark-up
ISO 27001 documents require version control of the author, the change, the date and the version as well as document mark up such as document classification.
- Write the ISO 27001 Document and Record Policy contents page
Document Contents Page
Documents and Records Policy
Purpose
Scope
Principle
Creating and Updating
Availability of documents
Document Storage
Version Control and Approval
Policy documents
Operational Documents and Records
Example of Records
Preservation of legibility
Obsolete documents and records
Documents of External Origin
Document Classification - Write the ISO 27001 Document and Record Policy purpose
The purpose of this policy is the control of documents and records in the information security management system.
- Write the ISO 27001 Document and Record Policy principle
Documents required for the information security management system are controlled, managed and available.
- Write the ISO 27001 Document and Record Policy scope
The documented information security management system.
Documented information required by ISO 27001.
Documented information determined by the company as being necessary for the effectiveness of the Information Security Management System.
All employees and third-party users. - Describe the requirements when creating and updating documentation
When creating and updating documented information, the company ensure appropriate
– identification and description (e.g., a title, date, author, or reference number),
– format (e.g., language, software version, graphics) and media (e.g., paper, electronic), and review and approval for suitability and adequacy. - Explain the approach to availability of documents
The latest approved version of document is presented to the appropriate users and are available and suitable for use, where and when it is needed.
- Document the document storage controls
Documents are stored in the document management technology implemented at the company.
Working documents for the information security management system are stored in the information security project / team folder.
Live documents and records are held within the relevant departments folder in a secure environment.
All stored documents are subject to access controls and adhere to the access control policy.
Documents and records are available to those that require them for their role. - Describe the process of version control and approval
Policy documents
Policy documents are subject to change as a result of the continual improvement process.
Changes to policy documents are done by the information security management team.
Policy documents are approved by the Management Review Team.
Policy documentation version control history is maintained which captures as a minimum the author, the date, the change, the new version number.
Policy version controls follows an x.y numbering system where x is the release and y is the iteration. The release number is updated periodically as part of a periodic review for all policies and the policies issued as a release set.
Operational Documents and Records
Operational documents and records are updated by the document and / or process owner as part of day-to-day operations and as required.
Changes to operational documents and records are done by the process owner.
Operational documentation version control history is maintained which captures as a minimum the author, the date, the change, the new version number.
Records may have version control history which is maintained which may capture as a minimum the author, the date, the change, the new version number. - Provide examples of records
Records are evidence of an event and used for operational management and auditing. They include but are not limited to
– Meeting minutes
– Training records
– Audit Reports
– Incident Reports - Explain preservation of legibility
Documents are created and available in electronic format using standard, supported office applications or in native operational systems.
- Describe the controls for obsolete documents and records
Obsolete documents and records required for audit and/or legal and regulatory purposes are archived in line with the data retention policy and removed from general accessibility.
Obsolete documents and records that are not required for audit and/or legal and regulatory purposes are deleted in line the data retention policy. - Set out the controls for documents of external origin
Documented information of external origin determined by the company to be necessary for the planning and operation of the Information Security Management System are identified, as appropriate, and controlled.
- Explain the approach to document classification
Documents are classified in line with the Information Classification and Handling policy.
ISO 27001 Document and Record Policy Walkthrough Video
How to implement ISO 27001 Document and Record Policy
Implementing a robust ISO 27001 Document and Record Policy is the foundational step in building an auditable Information Security Management System (ISMS). As a Lead Auditor, I look for a structured “single source of truth” where every document has a clear lifecycle, from creation to secure disposal. Follow these ten steps to ensure your documentation remains accurate, accessible, and compliant with the rigorous requirements of Clause 7.5 of the standard.
1. Formalise Document Governance
- Draft the overarching Document and Record Policy to define the rules for creation, review, and approval.
- Communicate these standards to all staff to ensure a unified approach to information handling.
- Result: A baseline governance framework that dictates how every other ISMS document is managed.
3. Identify Required Documentation
- Identify the mandatory documents required by ISO 27001, such as the Statement of Applicability and the ISMS Scope.
- Create a master document list to track all internal policies, procedures, and external records.
- Result: Full visibility of the documentation landscape required for successful certification.
3. Standardise Document Formatting
- Establish a standard template that includes mandatory metadata, specifically version numbers, authors, and classification levels.
- Utilise consistent headers and footers to ensure document identification is clear on every page.
- Result: Improved legibility and professional consistency across the entire information security estate.
4. Implement Version Control
- Provision a numerical versioning system to distinguish between draft, approved, and archived versions.
- Document change histories within each file to provide an audit trail of modifications over time.
- Result: Prevention of the accidental use of obsolete or unauthorised document versions.
5. Configure Secure Storage and Repositories
- Provision secure cloud repositories or internal shared drives with a logical folder structure.
- Ensure the storage environment allows for rapid retrieval while protecting against data corruption or loss.
- Result: Centralised and protected storage that supports business continuity and efficient auditing.
6. Assign Document Ownership
- Designate an individual owner for every document or record category.
- Task owners with the responsibility for periodic reviews to ensure content remains relevant to current risks.
- Result: Clear accountability for the maintenance and accuracy of the organisation’s intellectual property.
7. Establish Approval Workflows
- Formalise a workflow where senior management or the CISO must review and sign off on adequacy before publication.
- Record the date of approval and the identity of the approver within the document metadata.
- Result: Assurance that all active policies have been vetted for technical and operational suitability.
8. Enforce Access Permissions and IAM Roles
- Apply Identity and Access Management (IAM) roles to restrict document access based on the principle of least privilege.
- Configure “Read Only” permissions for general staff while restricting “Edit” rights to document owners.
- Result: Protection of sensitive ISMS documentation from unauthorised modification or deletion.
9. Define Retention Schedules
- Determine how long records must be kept based on legal, regulatory, and business requirements.
- Document these timeframes in a formal retention schedule within the policy.
- Result: Compliance with data protection laws and reduced storage costs through managed data lifecycles.
10. Provision Secure Disposal Procedures
- Establish procedures for the secure destruction of obsolete records, such as physical shredding or digital wiping.
- Maintain a Record of Destruction to provide evidence of secure disposal to auditors.
- Result: Elimination of residual security risks associated with unmanaged or sensitive legacy data.
How to audit ISO 27001 Document and Record Policy
Auditing the ISO 27001 Document and Record Policy requires a rigorous examination of the information lifecycle to ensure integrity and availability. As a Lead Auditor, I focus on the “single source of truth” principle, verifying that your Information Security Management System (ISMS) documentation is not only present but also formally controlled and protected. Use these 10 steps to audit your document control processes effectively, ensuring compliance with Clause 7.5 and broader regulatory requirements.
1. Verify Formal Policy Approval and Governance
- Inspect the Document and Record Policy to ensure it has been authorised by senior management within the last 12 months.
- Confirm the policy defines clear responsibilities for document creation, review, and approval.
- Result: Validates leadership commitment and establishes a legitimate foundation for all ISMS governance.
2. Audit the Master Document Index
- Review the centralised register or index that tracks all controlled ISMS documents.
- Check that mandatory documents, such as the Statement of Applicability and Risk Treatment Plan, are correctly identified.
- Result: Ensures the organisation has a complete view of its documentation landscape.
3. Validate Version Control and Naming Conventions
- Sample 5 to 10 policies to check for consistent version numbering and effective dates in headers or footers.
- Verify that naming conventions match the standards defined in the primary policy.
- Result: Prevents the accidental use of obsolete information and maintains document integrity.
4. Audit Access Permissions and IAM Roles
- Examine the document repository permissions to ensure they align with Identity and Access Management (IAM) roles.
- Verify that “Edit” access is restricted to authorised document owners only, while general staff have “Read Only” access.
- Result: Protects sensitive ISMS documentation from unauthorised or accidental modification.
5. Inspect Evidence of Document Reviews
- Audit the meeting minutes or digital approval logs for the most recent policy iterations.
- Ensure that technical adequacy was confirmed by a competent authority before the document was released.
- Result: Confirms that governance documents are technically sound and operationally relevant.
6. Review Record Retention and Disposal Logs
- Examine the retention schedule to ensure it complies with local laws, such as the UK Data Protection Act.
- Audit disposal logs or certificates of destruction for records that have reached their end of life.
- Result: Verifies legal compliance and ensures sensitive data is not retained longer than necessary.
7. Audit External Document Controls
- Identify documents of external origin, such as ISO standards or supplier service level agreements.
- Verify that these documents are identified and their distribution is controlled within the ISMS.
- Result: Ensures that external dependencies are managed with the same rigour as internal policies.
8. Validate Backup and Availability Protocols
- Inspect backup logs for the document repository to ensure data is protected against loss or corruption.
- Test the retrieval of a specific record to confirm that information is available to authorised users when required.
- Result: Guarantees business continuity and proves the resilience of the record management system.
9. Audit Staff Awareness of Document Handling
- Interview a sample of staff to confirm they know where to find the latest approved policies.
- Check training records to ensure employees understand document classification and handling requirements.
- Result: Reduces the risk of human error and ensures the “live” application of the policy.
10. Perform a Physical Document Integrity Check
- If physical records exist, inspect storage areas for appropriate environmental controls and security locks.
- Cross reference a physical document against the digital register to ensure the hard copy is the latest version.
- Result: Ensures that physical assets are managed to the same standard as digital information.
ISO 27001 Document and Record Policy Template
The ISO 27001:2022 Documents and Records Policy Template is designed to fast track your implementation and give you an exclusive, industry best practice policy template that is pre written and ready to go. It is included in the ISO 27001 toolkit.
How the ISO 27001 toolkit can help
An ISO 27001 toolkit is a great shortcut. It often includes pre-written policies, procedures, and forms that you can use right away. It saves you the hassle of writing everything from scratch and helps you make sure you don’t miss any important details.
Applicability of an ISO 27001 Document and Record Policy to Small Businesses, Tech Startups, and AI Companies
| Business Sector | Policy Focus | Implementation Example |
|---|---|---|
| Small Businesses | Formalising the handling of client contracts and financial records. | Storing client contracts in password-protected folders with mandatory manager approval for new security policies. |
| Tech Startups | Managing code documentation, project plans, and sensitive customer data. | Maintaining code documentation in specific online repositories with peer-review requirements for all changes. |
| AI Companies | Documenting AI models, training data sets, and ensuring responsible data handling. | Implementing strict rules for training data anonymisation and maintaining auditable logs for algorithm changes. |
Information security standards that need an ISO 27001 Document and Record Policy
This policy is a key part of ISO 27001, which is an international standard for managing information security. Other standards that need it include:
- GDPR (General Data Protection Regulation)
- CCPA (California Consumer Privacy Act)
- DORA (Digital Operational Resilience Act)
- NIS2 (Network and Information Security (NIS) Directive)
- SOC 2 (Service Organisation Control 2)
- NIST (National Institute of Standards and Technology)
- HIPAA (Health Insurance Portability and Accountability Act)
ISO 27001 Document and Record Policy Applicable Laws and Related Standards
| Standard / Regulation | Reference Clause | Mapping Context and Requirement |
|---|---|---|
| GDPR / UK Data (Use and Access) Act 2025 | Article 30 / Accountability Principle | Mandates the maintenance of a Record of Processing Activities (ROPA). The Document Policy ensures these records are accurate, approved, and securely retained to prove compliance. |
| NIS2 / UK Cyber Security and Resilience Bill | Article 21 (Risk Management) | Requires entities to document cyber risk management measures. This policy governs the lifecycle of those security documents, ensuring they remain current during mandatory reporting. |
| DORA (Digital Operational Resilience Act) | Article 6 (ICT Framework) | Financial entities must document their ICT Risk Management Framework. This policy ensures version control and availability of resilience testing records for regulators. |
| NIST CSF 2.0 | GV.PO-01 (Policy Management) | Policies for cybersecurity must be established, communicated, and enforced. This control provides the mechanism for policy creation, distribution, and periodic review. |
| SOC2 (Trust Services Criteria) | CC1.1, CC2.2 | Requires the organisation to document its internal control environment. The record policy provides the audit trail necessary for independent auditors to verify control effectiveness. |
| EU AI Act / AI Standards | Article 11 (Technical Documentation) | Providers of high-risk AI systems must maintain exhaustive technical documentation and logs of model training and testing for at least 10 years. |
| HIPAA Security Rule | 45 CFR § 164.316 | Specifically requires the maintenance of policies and procedures in written (digital) form for six years from the date of creation or last effective date. |
| CCPA / CPRA (California) | Section 1798.105 | Requires records of consumer requests and the organisation’s response. Document control ensures these records are retrievable and protected against unauthorised deletion. |
| CIRCIA (USA) | Reporting Records | Mandates that records pertaining to cyber incidents reported to CISA must be maintained to facilitate technical analysis and sector-wide resilience. |
| EU Product Liability Directive (PLD) | Evidence Disclosure | Software providers must maintain technical records to disprove negligence in the event of a cybersecurity flaw causing damage to consumers. |
| ECCF (European Cybersecurity Framework) | Certification Records | The record policy ensures that all evidence used to obtain EU-wide security labels is preserved and available for post-market surveillance. |
Related ISO 27001 Controls and Further Reading
- ISO 27001:2022 Clause 7.5.1 Documented Information
- ISO 27001:2022 Clause 7.5.2 Creating and Updating Documented Information
- ISO 27001:2022 Clause 7.5.3 Control of Documented Information
ISO 27001 Document and Record Policy FAQ
What’s the main goal of this policy?
The main goal of the ISO 27001 Document and Record Policy is to keep your information security management system (ISMS) organised, safe, and up-to-date. It ensures that 100% of your documents provide a reliable audit trail, proving to certification bodies that you are managing information security with precision.
Is this policy only for paper documents?
No, this policy is for both physical and digital files. Whether your data is stored in a cloud environment, on a shared local drive, or in a physical filing cabinet, the rules for version control, approval, and secure storage remain identical across the entire organisation.
Who is responsible for the policy?
The person in charge of your ISMS (usually the CISO or ISMS Manager) is responsible for writing and maintaining the policy, but everyone must follow it. From IT staff to part-time interns, every team member who creates or stores a record is an active participant in ISMS compliance.
How often should we update our policy?
You should review your Document and Record Policy at least once a year. Regular reviews ensure the policy stays aligned with technical changes in your infrastructure and remains effective against evolving security risks, maintaining a 12-month freshness cycle for all ISMS governance.
Is this policy a one-time project?
No, it’s a living document that you should continually use and update. ISO 27001 is based on the “Plan-Do-Check-Act” (PDCA) cycle, meaning your document management must be an ongoing operational process rather than a static, one-off administrative task.
Does this policy cover emails?
Yes, emails are considered records, so they should be managed according to the policy. Since 90% of business communication occurs via email, these threads often contain critical evidence of security decisions, approvals, and incident reports that must be archived and protected correctly.
What’s a record?
A record is a document that provides proof of an activity or event. While a “policy” tells you what to do, a “record” (such as a log, signed form, or audit report) proves that you actually did it. Records are the primary evidence used by auditors to verify compliance.
How long should we keep our documents?
The policy should specify a retention period based on legal and business requirements. Typically, ISO 27001 records are kept for 3 to 7 years to satisfy statutes of limitations, GDPR mandates, and the requirements of the UK Data (Use and Access) Act 2025.
Do we need a separate policy for each document type?
No, this single policy can cover all your documents and records. By maintaining one centralised Document and Record Policy, you reduce administrative overhead and ensure that a consistent standard for version control and approval is applied across the whole business.
What if a team member leaves the company?
The policy should explain how to manage their documents and records when they leave. This includes transferring ownership of digital files, recovering physical documents, and ensuring that no “single point of failure” exists where only the departing individual has access to critical ISMS records.
How does this help with compliance?
It provides clear evidence that you are managing your information correctly, which is crucial for audits. Without a Document and Record Policy, an organisation cannot prove its “Accountability” under the UK Data Act or demonstrate the “Check” phase of ISO 27001 certification.
Is this policy mandatory for ISO 27001?
Yes, a documented process for managing information is required under Clause 7.5. ISO 27001 specifically mandates that “documented information” required by the ISMS must be controlled to ensure it is available, suitable for use, and adequately protected.
What’s the first step to creating our policy?
Find a good template and decide who will be in charge of it. Starting with a pre-written framework from an ISO 27001 Toolkit allows you to focus on tailoring the rules to your specific business processes rather than building a complex governance structure from scratch.
About the author
