Labelling of information

What is Labelling of information?

Labelling of information is the technical process of attaching classification tags to data assets to communicate their sensitivity. The Primary Implementation Requirement involves marking 100% of information assets, providing the Business Benefit of ensuring appropriate handling and reducing accidental data disclosure risks by up to 60%.

What is Labelling of information?

ISO 27001 Information labelling is the process of marking or classifying data to show its sensitivity and importance. It helps people handle information correctly and protect it from being seen by the wrong people. Think of it like a library where books are organised by genre. Labelling helps you know what kind of information you are dealing with, so you can treat it with the right level of care.

Examples

  • Public: This is information anyone can see, like a company’s phone number or address. It doesn’t need special protection.
  • Internal: This information is for people inside the company only. A team memo or a company budget would be labelled as internal.
  • Confidential: This is private information that can cause harm if it gets out. Employee salaries or customer details would fall into this category.
  • Secret: This is the most sensitive information, often related to security. It’s for a very small group of people.

Context

Labelling is a key part of an organisation’s information security policy. It makes sure that everyone knows the rules for handling different types of data. This helps prevent accidents and makes it harder for malicious actors to get ahold of sensitive information. Clear labels on documents and data files are a simple but effective way to improve security.

How to implement Labelling of information

Implementing the labelling of information is a critical operational requirement under ISO 27001:2022 Control 5.13. This 10-step guide, authored by Lead Auditor Stuart Barker, provides the technical roadmap for ensuring that 100% of your information assets are correctly identified and handled according to their sensitivity levels.

1. Formalise the Information Labelling Policy

Develop a clear policy that defines the procedures for labelling information in accordance with the classification scheme defined in ISO 27001 Control 5.12. This ensures a consistent approach is adopted across all business departments.

  • Align labelling categories with risk assessment outcomes.
  • Document legal and regulatory requirements for specific data marks.

2. Update the Organisational Asset Register

Map every asset in your Asset Register to its corresponding classification and required label. You cannot effectively label information if you have not identified the underlying assets that store or process it.

  • Assign ownership to each information asset.
  • Categorise assets by format, such as digital, physical, or removable media.

3. Define Visual Labelling Standards

Create standardised visual templates for physical and digital documents to ensure labels are prominent and legible. Clear marking reduces the risk of accidental data disclosure during handling or transmission.

  • Specify header and footer placements for classification tags.
  • Standardise watermark usage for “Confidential” or “Restricted” files.

4. Configure Automated Metadata Tagging

Provision technical tools to embed classification labels directly into file metadata. This enables automated systems to recognise and protect data without relying solely on manual user intervention.

  • Inject non-visual tags for machine-readability.
  • Ensure metadata persists across file conversions and copies.

5. Implement Data Loss Prevention (DLP) Rules

Integrate your labelling scheme with DLP technical controls to prevent unauthorised data egress. Rules should trigger specific actions, such as blocking or encrypting, based on the identified label.

  • Block “Secret” labelled content from being attached to external emails.
  • Mandate MFA for accessing “Confidential” labelled cloud repositories.

6. Secure Removable Media and Physical Assets

Apply durable physical labels to hardware and removable media containing sensitive information. Visible labels serve as a deterrent and provide clear instructions for secure storage and transport.

  • Label encrypted USB drives with classification markings.
  • Use tamper-evident labels for high-sensitivity hardware assets.

7. Establish Labelling Exception Criteria

Document specific instances where labelling is technically unfeasible or counter-productive to security. Identifying these gaps allows for the implementation of alternative compensatory controls.

  • Identify legacy systems that do not support metadata tagging.
  • Log exceptions in the formal Record of Evidence (ROE) for audit review.

8. Launch Staff Labelling Awareness Training

Educate employees on the importance of labelling and the specific procedures for applying marks. Human error remains the primary cause of mislabelling, so regular training is a mandatory compliance step.

  • Provide clear examples of how to label emails and physical mail.
  • Verify training completion via a central learning management system.

9. Audit Labelling Compliance via Sample Testing

Conduct regular spot checks on information assets to verify that 100% of sampled data matches the classification policy. Periodic auditing ensures the labelling process remains effective over time.

  • Review physical document storage areas for unlabelled sensitive data.
  • Audit digital repositories for correctly applied metadata tags.

10. Review and Refine the Labelling Scheme

Evaluate the effectiveness of the labelling process during your quarterly management review. Adjust the scheme based on internal audit findings or changes to the organisational risk profile.

  • Update labelling standards to reflect new regulatory requirements.
  • Integrate feedback from staff regarding labelling tool usability.

Labelling of information FAQ

What is labelling of information in ISO 27001?

Labelling of information is the technical process of attaching a visible or metadata-based classification tag to data assets to ensure appropriate handling. Under ISO 27001:2022 Control 5.13, this practice ensures that 100% of information assets are identifiable by their sensitivity level, reducing accidental data disclosure by an estimated 60%.

How do you implement an information labelling scheme?

Implementing an information labelling scheme requires a structured approach to categorise and mark data according to its risk profile. To meet ISO 27001 compliance, follow these core steps:

  • Define Classification Levels: Establish categories such as Public, Internal, Confidential, and Secret.
  • Apply Visual Markings: Ensure physical documents have headers/footers and digital files contain clear watermarks.
  • Embed Metadata: Use digital tools to inject classification tags into file properties for automated Data Loss Prevention (DLP) processing.
  • Identify Exceptions: Document specific scenarios where labelling is technically unfeasible, such as in legacy database strings.

Why is labelling critical for data protection and compliance?

Labelling is critical because it provides a visual and technical “instruction” on how data must be stored, transmitted, and deleted. Without clear labels, organisations cannot enforce 5.12 (Classification) or 5.13 (Labelling) controls, which are fundamental to passing a UKAS-accredited ISO 27001 audit and avoiding GDPR-related fines that can reach €20 million or 4% of global turnover.

What digital tools assist with automated information labelling?

Automated labelling is primarily achieved through Microsoft Purview (Information Protection) or dedicated DLP software suites. These tools use machine learning to scan 1,000s of documents per minute, automatically applying sensitivity labels based on predefined regex patterns for PII, credit card numbers, or proprietary technical data.

Relevant ISO 27001 Controls

The following controls from the ISO/IEC 27001:2022 standard are related to labelling of information:

  • ISO 27001:2022 Annex A 5.13 Labelling Of Information: This control states that organisations must have a way to label their information based on its security classification. This helps ensure that sensitive information is handled with the correct level of care.
Stuart and Fay High Table

About the author

Stuart Barker
🎓 MSc Security 🛡️ Lead Auditor 30+ Years Exp 🏢 Ex-GE Leader

Stuart Barker

ISO 27001 Ninja

Stuart Barker is a veteran practitioner with over 30 years of experience in systems security and risk management. Holding an MSc in Software and Systems Security, he combines academic rigor with extensive operational experience, including a decade leading Data Governance for General Electric (GE).

As a qualified ISO 27001 Lead Auditor, Stuart possesses distinct insight into the specific evidence standards required by certification bodies. His toolkits represent an auditor-verified methodology designed to minimise operational friction while guaranteeing compliance.

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