ISO 27001:2022 Annex A 8.33 Test Information

ISO 27001 Test Information

In this guide, I will show you exactly how to implement ISO 27001 Annex A 8.33 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.

Key Takeaways: ISO 27001 Annex A 8.33 Test Information

ISO 27001 Annex A 8.33 is a control dedicated to stopping one of the most common causes of data breaches: the insecure “Test” environment. It requires that data used for testing software or systems is carefully selected, protected, and managed, ensuring that developers do not have unrestricted access to live, sensitive customer information (PII).

Core requirements for compliance include:

• The “No Live Data” Rule: The default stance of the standard is that you should not use operational (live) PII for testing. You should use Synthetic Data (fake data generated by a tool) or Anonymized Data whenever possible.
• Data Masking: If you must use live data (e.g., to debug a complex issue that can’t be replicated with fake data), you must “mask” or obfuscate sensitive fields. For example, replacing real names with “John Doe” or scrambling credit card numbers while keeping the format valid.
• Access Control: Test environments often have weaker security than production (e.g., shared passwords, no MFA). This control mandates that if sensitive data is present, the test environment must have production-level security controls.
• Secure Deletion: Once testing is complete, the data must be deleted immediately. You cannot leave a copy of the customer database sitting on a developer’s laptop “just in case.”

Audit Focus: Auditors will specifically ask: “Where do you get your test data from?”

• The Trap: If you say, “We just take a backup of production and restore it to the staging server,” you will likely fail unless you can prove that the staging server is just as secure as production (which is rarely true).
• The Fix: Auditors want to see a Data Transfer Log (authorizing the copy) and evidence of Sanitization (scripts that run after the copy to scramble emails/passwords).

Safe vs. Risky Testing Data:

Data Type	Definition	Risk Level	ISO 27001 Verdict	ISO 27001:2022 Control
Synthetic Data	Completely fake data created by a script.	None	Best Practice (Preferred).	A.8.33 (Test Data)
Anonymized Data	Real data stripped of all identifiers (irreversible).	Low	Acceptable.	A.8.11 (Data Masking)
Pseudonymized Data	Real data with identifiers replaced by codes (reversible).	Medium	Acceptable (with strict controls).	A.8.11 (Data Masking)
Raw Production Data	A direct copy of live customer records.	High	Avoid (Requires documented risk acceptance).	A.8.33 (Test Data)

What is ISO 27001 Test Information?

ISO 27001 Annex A 8.33 Test Information is an ISO 27001 control that requires you to use appropriate data when testing and to manage and protect it.

In ISO 27001 this is known as ISO27001:2022 Annex A 8.33 Test Information. It is one of the 93 ISO 27001 Annex A controls. 

Simply put, this control is all about keeping test data safe. Think about it: when you’re testing new software or systems, you often need data that looks like your real, confidential information (like customer names, addresses, or internal documents).

This control tells you that you must use dummy data or make sure the real data you use for testing is protected just as well as your live, operational data. You need to prevent the unauthorised disclosure, modification, or loss of data that’s used for testing purposes.

What is ISO 27001 Annex A 8.33?

The latest version of the ISO 27001 standard is ISO/IEC 27001:2022 (published in October 2022).

In the ISO/IEC 27001:2022 Standard the control is titled “Test Information”.

The ISO 27001 standard defines ISO 27001 Annex A 8.33 as:

Test information should be appropriately selected, protected and managed.

ISO27001:2022 Annex A 8.33 Test Information

ISO 27001 Annex A 8.33 Purpose

The purpose of ISO 27001 Annex A 8.33 is to ensure the relevance of testing and protection of operational information used for testing.

Is ISO 27001 Annex A 8.33 Mandatory?

ISO 27001 Annex A control 8.33 (Test Information in the 2022 standard) is not automatically mandatory in the same way the clauses in the main body of the standard (clauses 4 through 10) are.

The mandatory part of the standard requires you to consider ISO 27001 Annex A 8.33 and all other Annex A controls, but you have the flexibility to exclude it if it is not applicable to your organisation’s specific risks and context.

Why you need ISO 27001 Annex A 8.33

You need to care for a few important reasons:

1. Stop Data Leaks: If your test environment is less secure than your live system, a hacker can easily get to your real data that you’ve copied over for testing.
2. Maintain Customer Trust: If you leak customer data, even from a testing server, your customers will lose faith in you.
3. Avoid Fines: Depending on where you operate, laws like GDPR (General Data Protection Regulation) apply to test data just as much as live data. A leak can lead to huge fines.
4. Keep it Real: If you use fake or masked data, your test results are more reliable, as you aren’t worried about accidentally modifying or destroying real customer records.

When you need ISO 27001 Annex A 8.33

You should address this control before you start any new development or testing project that requires using or simulating real data.

• During System Development: As soon as you plan to move data from a live environment to a testing environment.
• When You Set Up a Test Environment: You should define the security rules for the test environment right from the start.
• As Part of Your ISO 27001 Certification Process: You need documented procedures and proof of compliance before your audit.

How to write ISO 27001 Annex A 8.33

You don’t need a super-long, complicated document. Your procedure should answer these main questions:

1. What data is allowed in the test environment? (Only masked data? Completely fake data?)
2. How do we get the data? (Do we use an approved masking tool? Is the transfer encrypted?)
3. Who can access the test data and test environment? (Only approved developers? Do they use unique passwords?)
4. How is the test data deleted or destroyed when testing is finished? (Do we have a secure deletion process?)

ISO 27001 Annex A 8.33 Explainer Video

In this strategic implementation briefing, Lead Auditor Stuart Barker and team do a deep dive into ISO 27001:2022 Annex A 8.33 Test Information.

ISO 27001 Annex A 8.33 Podcast

In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001:2022 Annex A 8.33 Test Information. The podcast explores what it is, why it is important and the path to compliance.

How does ISO 27001 Annex A 8.33 apply to Small Businesses, Tech Startups, and AI Companies?

This information security control is useful for businesses of all sizes, including small businesses, tech startups, and AI companies. Examples of using this control include:

Business Type	Application of Annex A 8.33	Practical Example & Visual
Small Businesses	You may not have complex testing environments, but if you take a copy of your customer database to test a new sales system, that copy must be protected.	Testing a new website checkout process using a copy of 100 recent customer orders. Use a tool to randomise customer names and addresses in the test copy before it’s used by the developer. Only approved IT staff can access the test server.
Tech Startups	You are constantly building and testing! You’re likely dealing with proprietary code and potentially sensitive user data, so keeping your test environments secure is a must to protect your intellectual property and early user trust.	Developers need to test a new feature that uses real user settings and preferences. They create a synthetic dataset that perfectly simulates the structure of real data but contains no actual user-identifying information. The test environment is protected by a separate firewall.
AI Companies	You rely heavily on training data and testing data to build and fine-tune your models. This data is often highly sensitive, sometimes containing personal details or proprietary information used to train your AI. This control is vital to ensure that data doesn’t leak during the development and testing of your algorithms.	A Machine Learning engineer needs to test a new AI model’s ability to process medical records. The engineer uses a de-identified and tokenised version of the medical records (each real patient ID is replaced by a temporary, meaningless code). This test data is stored only on an encrypted development server.

ISO 27001 Annex A 8.33 Implementation Guide

When it comes to testing information, in other words the information that you use in testing, the best advice for implementation is to not use production data, confidential data, personal data. Think of it this way, don’t use any data or information in test that could get you in hot water.

If you have to then you have to but here I would recommend using things such as data masking or specialist tools that turn data into test data.

What we need to do is select data and information that will ensure reliability of test results including the confidentiality, integrity and availability of the production and operational information.

Consider here the requirements of ISO 27001 Annex A 8.31 Separation of Development, Test and Production Environments.

General considerations would include

• Access Control – having access control in place that mirrors the production environment
• Authorisation – having a process of authorising the transfer of data between environments
• Logging – having logs of the transfer of information between environments
• Deletion – deleting testing data immediately after use
• Test data is for testing only.

Depending on the test data that you have chosen then remember here that all of the annex a controls will apply to it as it does in production. Not using ‘real data’ is the best way to meet this control and mitigate risk.

If you have to use ‘real data’ then the advice would be to have a risk register item, manage through the risk management process, even if that is accepting the risk.

How to implement ISO 27001 Annex A 8.33 Step-by-Step

In this step by step implementation checklist to ISO 27001 Test Information I show you, based on real world experience and best practice, the best way to implement ISO 27001 Annex A 8.33.

1. Test Data Management

Challenge

Employing production data within testing environments elevates the potential for data breaches or unauthorised access.

Solution

• Implement rigorous data sanitisation and data masking techniques.
• Utilise synthetic data whenever possible.
• Encrypt all production data utilised for testing purposes.
• Establish robust access controls to safeguard test data.

2. Data Anonymisation and Data Masking

Challenge

Anonymising or masking data effectively is complex and requires constant attention to prevent re-identification risks.

Solution

• Utilise sophisticated tools to effectively anonymise or mask sensitive data.
• Regularly assess the effectiveness of masking techniques and ensure compliance with laws and relevant regulations.
• Continuously monitor systems for potential vulnerabilities and weaknesses that could lead to re-identification.

3. Access Control

Challenge

Managing access rights in large organisations, especially when collaborating with external partners, can create significant security vulnerabilities.

Solution

• Implement Role-Based Access Control (RBAC): Utilise RBAC to efficiently manage and control access permissions based on an individual’s role and responsibilities within the organisation.
• Regularly review access rights: Conduct periodic reviews of access rights to ensure they remain appropriate and aligned with current business needs.
• Monitor access logs: Continuously monitor access logs to detect and promptly respond to any unauthorised access attempts.

4. Environment Separation

Challenge

Maintaining distinct development, testing, and production environments can be challenging, particularly within agile development methodologies.

Solution

• Establish and enforce strict environment separation policies: Implement Separation of Development, Test and Production Environments.
• Leverage automation: Utilise automated tools to prevent accidental or unauthorised movement of code or data between environments.
• Conduct regular audits: Regularly review and assess the effectiveness of environment separation controls.

5. Compliance and Security Requirements

Challenge

Maintaining compliance in test environments while adapting to constantly evolving regulations presents a significant challenge.

Solution

• Utilise compliance management tools: Employ specialised tools to track and monitor regulatory changes and ensure compliance adherence.
• Integrate compliance into the ISMS: Incorporate compliance requirements directly into the Information Security Management System (ISMS) framework.
• Provide continuous training: Regularly train security teams on the latest regulatory requirements and best practices for maintaining compliance in test environments.

6. Documentation and Audit

Challenge

Maintaining comprehensive and audit-ready documentation can be time-consuming and resource-intensive.

Solution

• Automate documentation processes: Utilise automated tools to streamline documentation tasks, such as generating reports and tracking changes.
• Conduct regular reviews: Regularly review and update documentation to ensure accuracy, completeness, and compliance with relevant standards (e.g., ISO 27001).

How to audit ISO 27001 Annex A 8.33

To conduct an internal audit of ISO 27001 Annex A 8.33 Test Information use the following audit checklist which sets out what to audit and how to audit it.

1. Test Data Management

• Review and test data sanitisation and masking techniques.
• Check the use of synthetic data.
• Evidence that encryption of all production data utilised for testing purposes is in place.
• Walkthrough the access controls that are in place to safeguard test data.

2. Data Anonymisation and Data Masking

• Document the tools to effectively anonymise or mask sensitive data.
• Assess the effectiveness of masking techniques and ensure compliance with relevant regulations.
• Walkthrough systems for potential vulnerabilities and weaknesses that could lead to re-identification.

3. Access Control

• Ensure Role-Based Access Control (RBAC) is used to manage and control access permissions based on an individual’s role and responsibilities within the organisation.
• Review access rights: Conduct a review of access rights to ensure they remain appropriate and aligned with documented business needs.
• Check access logs

4. Environment Separation

• Review the environment separation policies and check for clear rules and procedures for managing and accessing each environment.
• Assess automation and the use of automated tools to prevent accidental or unauthorised movement of code or data between environments.
• Check there have been regular audits that review and assess the effectiveness of environment separation controls.

5. Compliance and Security Requirements

• Review compliance management tools and how they track and monitor regulatory changes and ensure compliance adherence.
• Ensure that compliance is integrated into the ISMS
• Asses continuous training and that regular training is in place for security teams on the latest regulatory requirements and best practices for maintaining compliance in test environments.

6. Documentation and Audit

• Ensure that reviews and internal audits are in place and evidenced
• Assess the documentation framework, inputs and outputs.

Fast-Track Compliance with the ISO 27001 Toolkit

For ISO 27001 Annex A 8.33 (Test information), the primary requirement is not to buy a complex “Test Data Management” engine, but to establish a robust governance framework that defines how you select, protect, and destroy test data.

While SaaS platforms often try to sell you expensive, over-engineered modules to “manage” this control, the High Table ISO 27001 Toolkit provides the logical, time-saving solution by focusing on the policies and procedures that actually satisfy the auditor.

Here is why the Toolkit is the smarter choice for complying with Annex A 8.33:

Compliance Factor	SaaS Platform Risk	High Table Toolkit Advantage
Ownership	SaaS platforms act as gatekeepers. If you cancel the subscription, you risk losing access to your compliance evidence, logs, and approvals.	You keep your data forever. You receive the Test Data Policy and Data Masking Guidelines in fully editable Word/Excel formats, ensuring permanent ownership of your evidence.
Simplicity	Often involves expensive, over-engineered modules that require team training to navigate complex interfaces for simple tasks.	Governance without the bloat. Provides pre-written rules and clear communication. No new software to learn—just adopt the policy and sign the document.
Cost	Come with high price tags, often charging recurring monthly fees per user, per integration, or requiring “premium tiers” for data protection tools.	One-off fee. You pay once for the entire documentation suite (Secure Development Policy & Test Procedures) with no recurring costs or licensing fees.
Freedom	Vendor lock-in forces you to handle test data their way, which may not fit specific workflows (e.g., AI synthetic data vs. banking masked data).	No vendor lock-in. Fully flexible templates allow you to define the process that works for your specific technology stack and business model.

Summary: For Annex A 8.33, the auditor wants to see that you have strict rules preventing the misuse of production data. The High Table ISO 27001 Toolkit gives you those rules immediately. It is the most direct, cost-effective way to demonstrate control without getting locked into an expensive monthly subscription.

Information security standards that need ISO 27001 Annex A 8.33

This control 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)

List of relevant ISO 27001:2022 controls

The ISO 27001:2022 standard has specific controls that relate to test data:

• ISO 27001:2022 Annex A 8.11 Data Masking
• ISO 27001:2022 Annex A 8.34 Protection of Information Systems During Audit Testing
• ISO 27001:2022 Annex A 8.29 Security Testing in Development and Acceptance
• ISO 27001:2022 Annex A 8.32 Change Management

ISO 27002:2022 Control 8.33

ISO 27002 Control 8.33 provides implementation guidance for ISO 27001 Test Information.

ISO 27001 Annex A 8.33 Attributes Table

Control type	Information security properties	Cybersecurity concepts	Operational capabilities	Security domains
Preventive	Confidentiality	Protect	Information Protection	Protection
	Integrity

ISO 27001 Annex A 8.33 Strategic Briefing Slides