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Information Labelling and Handling Procedure Template (ISO/IEC 27001)

Label texts and formats, handling matrix from create to destroy per class, e-mail and file label settings, auto-labelling, paper and media, TLP mapping

SGSI e ISO/IEC 27001CompletaISO/IEC 27001:2022 + Amd 1:2024 A.5.12 to A.5.14, A.5.10, A.7.10, A.8.12 (cited only); ISO/IEC 27002:2022; NIST SP 800-88 Rev. 2; FIRST TLP 2.0informationlabellinghandlingprocedure

Cómo usar: Use it once your classification policy is approved, to tell people and tools how to label and handle information at each level. Fill the label texts, the handling matrix and the e-mail and file label settings first. The main pitfall is vague matrix cells or label spellings that differ between tools, so nothing can be enforced.

Vista previa

Information Labelling and Handling Procedure: [Organization name]

Procedure that makes the classification of information visible and tells every person what to do with information at each level when they create, store, use, share, print, transfer, keep and destroy it. It supports ISO/IEC 27001:2022 + Amd 1:2024 Annex A controls A.5.12 (classification), A.5.13 (labelling) and A.5.14 (transfer), together with A.5.10 (acceptable use), A.7.10 (storage media) and A.8.12 (data leakage prevention), with guidance from ISO/IEC 27002:2022. The classification levels themselves are defined in the data classification policy; this procedure applies them. Replace every [bracketed] value and every row marked Example.

Document control

FieldValue
Document IDDOC-ISMS-042
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Owner[@isms-manager]
Approvers/reviewers[@ciso], [@dpo], [@head-of-it], [@records-manager]
Last updatedYYYY-MM-DD
Classification[Internal]
Standard and editionISO/IEC 27001:2022 + Amd 1:2024, Annex A A.5.12 to A.5.14, A.5.10, A.7.10, A.8.12; guidance ISO/IEC 27002:2022
Next scheduled reviewYYYY-MM-DD (at least annually, and when the classification policy changes)
Classification scheme reference[Data classification policy, version and date]
Labelling tools[Productivity suite sensitivity labels / DLP tool / document management system]
Related documentsDOC-ISMS-001, DOC-ISMS-012, DOC-ISMS-040, DOC-ISMS-043, DOC-ISMS-056, DOC-ISMS-057, DOC-ISMS-062

Approvals

RoleNameDecisionDate
Procedure owner[@isms-manager][Prepared]YYYY-MM-DD
Data protection officer or privacy lead[@dpo][Reviewed]YYYY-MM-DD
Head of IT[@head-of-it][Reviewed: tool settings match]YYYY-MM-DD
CISO or top management delegate[@ciso][Approved]YYYY-MM-DD

Revision history

VersionDateAuthorChange
1.0 (Example)YYYY-MM-DD[@isms-manager]First approved procedure, aligned with classification policy v2.0
1.1 (Example)YYYY-MM-DD[@isms-manager]Default label for new documents changed to Internal; automatic Restricted label for health identifiers added

Contents

  1. Purpose and scope
  2. Roles and responsibilities
  3. Classification levels and label texts
  4. Labelling methods by format
  5. Handling matrix across the information lifecycle
  6. E-mail and file labelling
  7. Automated labelling and enforcement
  8. Physical media and printed information
  9. Unlabelled, mislabelled and relabelled information
  10. Information received from third parties
  11. Handling breaches and incidents
  12. Training and awareness
  13. Size tiers
  14. Records and evidence
  15. References

1. Purpose and scope

This procedure makes sure that information held or processed by [Organization name] carries a label that shows its classification, and that people and systems handle it according to that label throughout its life. It applies the levels defined in the data classification policy (data/data-classification-policy) and does not redefine them.

The procedure applies to all information in the ISMS scope (DOC-ISMS-002) in any form:

  • electronic documents, spreadsheets, presentations and PDFs;
  • e-mail, chat messages, meeting recordings and transcripts;
  • files in shared drives, cloud storage and collaboration sites;
  • structured data in databases, data warehouses and SaaS applications;
  • source code, configuration and logs that contain sensitive values;
  • printed documents, removable media and portable devices;
  • information shared verbally in meetings and calls.

It applies to employees, contractors and third parties who handle information on behalf of [Organization name]. Information owners are recorded in the asset inventory (compliance/asset-inventory, DOC-ISMS-012).

2. Roles and responsibilities

RoleResponsibilities
Information ownerConfirms the correct level for information sets in their area, approves downgrades, decides on external sharing of Confidential and Restricted information
Creator (any staff member)Applies a label when creating or receiving information, checks inherited labels, follows the handling matrix
RecipientKeeps the label, handles to the label, reports information that seems mislabelled
ISMS manager (procedure owner)Maintains the procedure, label texts and handling matrix; reports metrics
IT or platform teamConfigures labels, defaults, encryption and automatic labelling in tools; keeps settings aligned with this procedure
Security teamOperates DLP and discovery scans, triages label policy alerts, investigates handling breaches
Privacy lead or DPODefines personal data detectors and confirms handling rules for personal data
Records manager or office managerRuns secure printing, storage of paper records, media destruction contracts

3. Classification levels and label texts

LevelCodeVisible label textMachine-readable valueDefault for
PublicC0PUBLICclassification=C0Approved published content only
InternalC1INTERNALclassification=C1New documents and messages without another label
ConfidentialC2CONFIDENTIALclassification=C2Customer, employee, commercial and financial data
RestrictedC3RESTRICTEDclassification=C3Special-category personal data, payment card data, bulk personal data extracts, secrets and security-critical data, board-only material

Optional sub-labels (also called flags or caveats) add handling information without adding levels:

Sub-labelMeaningEffect
PDContains personal dataMinimum Confidential (C2); privacy rules apply; DLP personal data rules active
PD-SCContains special-category personal dataOnly allowed at Restricted (C3)
PD-CRContains criminal offence personal dataOnly allowed at Restricted (C3)
PD-CHILDContains personal data of childrenOnly allowed at Restricted (C3)
PAYContains full payment card numbers or sensitive authentication dataOnly allowed at Restricted (C3); card data environment rules apply
LEGAL-HOLDUnder legal holdDeletion blocked until the hold is released
[CUSTOMER-NAME]-ONLYCustomer-restricted data under contractShared only with staff assigned to that customer
EXT-[LABEL]Original label from a third party (section 10)Handled at the mapped internal level

The personal data and payment flags (PD, PD-SC, PD-CR, PD-CHILD, PAY, and PSEUDO or ANON where used) are defined in the data classification policy; use its spelling and minimum levels exactly.

4. Labelling methods by format

FormatVisible markingMachine-readable markingApplied by
Office documents and PDFsHeader or footer with the label text on every page; Restricted adds a watermarkSensitivity label in file metadataCreator, with default and automatic labelling
E-mailLabel shown in the message banner; Restricted adds the subject prefix [RESTRICTED]Sensitivity label in message headersSender, with default label Internal
Chat and collaboration channelsChannel or team label in the channel descriptionContainer sensitivity labelChannel owner at creation
Collaboration sites and shared foldersSite bannerContainer label setting default label for filesSite owner, approved by information owner for C3
Meeting recordings and transcriptsLabel in the meeting invitation and recording titleInherited from the meeting labelMeeting organiser
Databases, warehouses and data setsLabel in the data catalogue entryTable and column tagsData owner, with discovery scans
SaaS application recordsField or record classification where supported, otherwise system-level label in the asset inventoryApplication settingSystem owner
Source code repositoriesRepository description states the highest levelRepository topic or tagRepository owner
Exports and extractsLabel in the file name, for example customers_2026-10_C2.csvFile metadata where the format allowsPerson creating the export
Printed documentsLabel printed in header or footer on every pageNot applicableInherited from the electronic file
Removable media and devicesPhysical label with level and asset numberEncryption status recorded in the asset inventoryAsset holder
Verbal briefingsSpeaker states the level at the start, for example "this briefing is Confidential"Not applicableSpeaker

Public information may stay unlabelled once it has been approved for release. All other information is labelled.

5. Handling matrix across the information lifecycle

5.1 Create, store and use

StepPublic (C0)Internal (C1)Confidential (C2)Restricted (C3)
CreateMark as Public only after approval by the content ownerDefault label applied automaticallyCreator applies label at creation; template documents carry the labelCreated only in approved Restricted locations; label applied before saving
Store electronicallyAny approved systemApproved company systemsApproved systems with encryption at rest and access loggingApproved Restricted locations only, with encryption and access limited to named people or roles
Store on endpointAllowedAllowed on managed devicesManaged, encrypted devices only; no local sync of whole sitesNot stored locally unless an exception is approved; access through the approved application
AccessAnyoneStaff and authorised contractorsRole-based, need to know (isms/access-control-policy)Named individuals or narrow roles, owner approval, access reviewed quarterly
Use in AI toolsAllowedApproved enterprise AI tools onlyApproved tools cleared for C2 with no training on inputs (ai-data/ai-usage-policy)Prohibited unless the tool is approved for C3
Discuss verballyAnywhereNot in public placesIn private rooms or calls with known participantsNamed participants only, no recording unless the information owner approves
Display on screenNo restrictionLock screen when away (isms/clear-desk-clear-screen-policy)Privacy screen in public placesDo not open in public places

5.2 Share and transfer

StepPublic (C0)Internal (C1)Confidential (C2)Restricted (C3)
Share internallyFreeFree within the organisationNeed to know, through approved tools; share links limited to named peopleNamed people only, approved by the information owner; no "anyone in the organisation" links
Share externallyFreeUnder an NDA or contractContract with confidentiality terms, and a data processing agreement when PD applies; information owner approves each new recipient organisation and any bulk data transferAs Confidential plus information owner approval per recipient, encrypted channel, minimised content
E-mail externallyAllowedAllowed to contracted partiesAllowed with label-driven encryption, enforced TLS to the partner domain, or an approved secure file shareOnly through the approved secure transfer channel; plain e-mail attachments prohibited
Transfer methodAnyApproved channels in the transfer policyEncrypted channels listed in isms/information-transfer-policyEncrypted channels with recipient verification and transfer log
Removable mediaAllowedEncrypted media onlyEncrypted, company-issued media, approved by line managerProhibited unless an exception is approved
PublishAfter approvalNeverNeverNever

5.3 Print, keep and destroy

StepPublic (C0)Internal (C1)Confidential (C2)Restricted (C3)
PrintAllowedAllowed on company printersSecure print release; collect at onceAvoid; if needed, secure print release and a numbered copy log
Store paperNo restrictionNot left on desks overnightLocked drawer or cabinetLocked cabinet in a controlled area, key or code held by named people
Take off-siteAllowedAllowedOnly when needed, kept with the personOnly with information owner approval, in a closed folder or locked case
Post or courierAny serviceStandard mailTracked service, sealed envelope, no label on the outer envelopeTracked service with signature, double envelope, inner envelope marked
RetainRecords scheduleRecords scheduleRetention rule with trigger and period (data/data-retention-deletion-standard)Shortest period that meets the purpose, documented basis
Destroy electronicNormal deleteNormal deleteDelete plus removal from shares and trash; storage sanitised at end of lifeAs Confidential plus verified sanitisation per NIST SP 800-88 Rev. 2 and a disposal record
Destroy paperRecycleRecycle or confidential binConfidential waste bin, cross-cut shreddingCross-cut shredding on site or witnessed destruction with a certificate
Destroy media and devicesReuse allowedWipe before reuseSanitise before reuse or disposalSanitise or destroy, recorded in isms/equipment-disposal-reuse-record

6. E-mail and file labelling

Settings in the productivity suite and file storage:

Setting IDSettingValue
LBL-SET-001Default label for new documents and e-mailsInternal (C1)
LBL-SET-002Label mandatory before saving or sending[Yes for documents and e-mail]
LBL-SET-003Lowering a labelAllowed with a written justification, logged; lowering from Restricted needs information owner approval
LBL-SET-004Confidential (C2) label effectFooter marking; external sharing limited to authenticated recipients; download allowed on managed devices
LBL-SET-005Restricted (C3) label effectHeader, footer and watermark; encryption with access limited to named groups; no forwarding or printing for external recipients; offline access limited to [7 days]
LBL-SET-006Container labelsSites and teams labelled at creation; files inherit the container label as default
LBL-SET-007Label inheritance in e-mailReplies and forwards keep the highest label in the thread; attachments raise the message label to their highest level
LBL-SET-008Public labelOnly users in the publishing group can apply Public

Rules for staff:

  • Check the label each time you create, receive or forward information.
  • When you combine information from several sources, use the highest level among them.
  • Do not remove markings from a document, print or export.
  • When in doubt, choose the higher level and ask the information owner.
  • Write the label justification in plain words when you lower a label, for example "personal data removed, aggregated figures only".

7. Automated labelling and enforcement

7.1 Automatic and recommended labels

Rule IDDetectorActionScope
LBL-AUTO-001 (Example)Payment card numbers (validated pattern)Apply Restricted (C3) and PAY automaticallyE-mail, files, chat
LBL-AUTO-002 (Example)Health or patient identifiers from the customer data modelApply Restricted (C3) and PD-SCFiles and databases at Quillmere Health Systems
LBL-AUTO-003 (Example)National identity or passport number patterns for the countries servedApply Restricted (C3)Files, e-mail
LBL-AUTO-004 (Example)10 or more e-mail addresses with names in one fileRecommend Confidential (C2) and PDFiles
LBL-AUTO-005 (Example)Secrets: private keys, access tokens, connection stringsApply Restricted (C3), alert the security teamRepositories, files, chat
[LBL-AUTO-NNN][detector][action][scope]

7.2 Enforcement links

  • DLP rules use the machine-readable labels to block or warn on transfers that break the matrix in section 5.2 (isms/data-masking-dlp-standard, DOC-ISMS-062).
  • Discovery scans of storage and data platforms report unlabelled or under-labelled content [monthly] to information owners.
  • Label changes, downgrades and policy overrides are logged and reviewed by the security team [weekly].

7.3 Labelling at creation

Every path ends with a label that travels with the information. The justification step is the only way to lower a label, and its log is the evidence reviewed in section 7.2.

8. Physical media and printed information

  • Removable media (USB drives, external disks, memory cards) is blocked by default on managed endpoints. Where allowed, only company-issued, encrypted media is used and it carries a physical label with the level and asset number.
  • Restricted media is held in a locked container in a controlled area and recorded in the asset inventory with its holder.
  • Printers use secure release (badge or PIN) for Confidential and Restricted printing. Uncollected jobs are purged after [24 hours].
  • Locked confidential waste bins are placed near printers and emptied by an approved destruction service that issues a certificate for each collection.
  • Paper and media leaving a site are logged (date, content level, carrier, recipient) when they are Restricted.
  • Devices and media at end of life are sanitised or destroyed and recorded in the equipment disposal and reuse record (isms/equipment-disposal-reuse-record, DOC-ISMS-057), with the method chosen according to NIST SP 800-88 Rev. 2.

9. Unlabelled, mislabelled and relabelled information

SituationRule
Unlabelled electronic informationTreated as Internal (C1) until labelled, unless a detector finds personal data, which raises it to Confidential (C2)
Information that seems under-labelledRecipient raises the label or tells the information owner; the owner confirms within [5 working days]
Information that seems over-labelledRecipient asks the information owner; the label stays until the owner decides
Planned downgrade (for example publication)Information owner approves; the reason and date are logged; Public release follows the publication approval process
Time-based downgradeLabel may carry a review date, for example a results announcement that becomes Public at release
Legacy archivesScanned and labelled in a planned project; until then access is limited to the archive owner group

10. Information received from third parties

External label or schemeInternal levelNotes
Customer "Confidential" or "Strictly Confidential"Confidential (C2) or Restricted (C3) as stated in the contractContract terms override the default mapping
TLP:CLEAR (TLP 2.0, FIRST)Public (C0)May be shared freely, subject to copyright
TLP:GREENInternal (C1)Within the community, not published
TLP:AMBERConfidential (C2)Need to know within the organisation and its clients as the source allows
TLP:AMBER+STRICTConfidential (C2), organisation onlyNo sharing with clients
TLP:REDRestricted (C3), named recipients onlyNo further sharing
Government or regulator markingsAs agreed with the authorityRecord handling instructions in the authority contacts list (isms/authority-special-interest-contacts)

The original label is kept as an EXT- sub-label. When the third party's rule is stricter than the mapped internal rule, the stricter rule applies.

11. Handling breaches and incidents

  • Report any handling breach immediately through the security event reporting procedure (isms/security-event-reporting-procedure, DOC-ISMS-023). Examples: Confidential or Restricted information sent to the wrong recipient, uploaded to an unapproved service, printed and lost, or left unattended.
  • The security team assesses whether the event is an incident under the incident response plan (compliance/incident-response-plan, DOC-ISMS-020) and whether personal data breach rules apply (compliance/personal-data-breach-assessment).
  • Recall, deletion requests or link revocation are attempted at once where the tool allows.
  • Deliberate or repeated breaches are handled through the disciplinary process (isms/security-disciplinary-process, DOC-ISMS-052); honest mistakes reported promptly are treated as learning opportunities.

12. Training and awareness

  • All staff complete labelling training at onboarding and at each annual awareness cycle (security/security-awareness-program), with examples from their own work: a customer list, a board pack, a support ticket export.
  • Information owners and site owners receive extra guidance on approval of downgrades and external sharing.
  • A one-page summary of section 5 is published on the intranet and linked from the label selection dialog where the tool allows.
  • Completion is recorded in the competence and training matrix (isms/isms-competence-training-matrix, DOC-ISMS-026).

13. Size tiers

TopicSmall: Quillmere Analytics Ltd (46 staff)Medium: Quillmere Health Systems (320 staff)Large or multi-site: Quillmere Group (2,400 staff, 6 sites)
LabelsFour labels in the productivity suite, default Internal, manual labelling with recommended labels for customer data exportsMandatory labelling for documents and e-mail, automatic Restricted label for health identifiers (LBL-AUTO-002)Group label set in all tenants, translated label descriptions for 4 countries, same codes everywhere
Data platformsCustomer data store tagged at system level in the asset inventoryColumn tags in the data catalogue for clinical scheduling dataCatalogue tags across IT data platforms; OT historian data labelled at system level per plant
Paper and mediaLittle paper; one locked bin at the office; USB blockedLocked bins at both offices; media register at the colocation suiteSite records managers at each of the 6 sites; destruction contracts per country
Third-party labelsCustomer contract terms mapped in the customer registerTLP mapping used for sector threat sharingTLP plus authority markings at the data centre and plants
OwnershipISMS manager (0.5 FTE) maintains the procedure and reviews downgrade logs monthly3-person security team runs discovery scans and DLP triageSecurity office runs a labelling service; site coordinators handle local paper and media

14. Records and evidence

RecordProvesOwnerLocationRetention
Approved procedure and revision historyLabelling rules defined (A.5.13)ISMS managerDocumented information register (DOC-ISMS-028)Current plus [3] previous versions
Label configuration exportTool settings match section 6ITProductivity suite admin exportEach change plus [3 years]
Label usage and downgrade logsLabels applied; downgrades justifiedSecurity teamAudit log platformAt least [1 year]
Discovery scan reports and remediationUnlabelled content found and fixedSecurity team, information ownersDLP or discovery tool[3 years]
DLP alert triage recordsHandling rules enforced (A.8.12)Security teamDLP tool, ticketing[3 years]
Certificates of destruction and disposal recordsSecure destruction (A.7.10, A.7.14)Records or office managerDOC-ISMS-057[6 years] or per records schedule
Restricted media and print logsRestricted physical handlingHolders, records managerRegister[3 years]
Training completionStaff know the rules (A.6.3)HR or ISMS managerDOC-ISMS-026[3 years]
Handling breach reportsBreaches reported and handledSecurity teamIncident register (DOC-ISMS-021)Per incident register retention

15. References

ReferenceEditionUse
ISO/IEC 27001:2022 + Amd 1:20242022, Amd 1 published 2024-02-23Annex A A.5.10, A.5.12 to A.5.14, A.7.10, A.7.14, A.8.12 (cited by number)
ISO/IEC 27002:20222022Guidance for classification, labelling and transfer controls
NIST SP 800-88 Rev. 2, Guidelines for Media SanitizationFinal, September 2025Choice of sanitisation method in sections 5.3 and 8
FIRST Traffic Light Protocol (TLP) version 2.0Authoritative from August 2022External label mapping in section 10
ISO/IEC 27001 official pagehttps://www.iso.org/standard/82875.htmlPurchase the standard
ISO/IEC 27002 official pagehttps://www.iso.org/standard/75652.htmlControl guidance

Related templates: data/data-classification-policy, isms/information-transfer-policy (DOC-ISMS-043), isms/data-masking-dlp-standard (DOC-ISMS-062), isms/clear-desk-clear-screen-policy (DOC-ISMS-056), isms/equipment-disposal-reuse-record (DOC-ISMS-057), compliance/asset-inventory (DOC-ISMS-012), compliance/acceptable-use-policy (DOC-ISMS-040), data/data-retention-deletion-standard, isms/control-evidence-matrix (DOC-ISMS-033).

Standard and licence note

Structure aligned with ISO/IEC 27001:2022 + Amd 1:2024, Annex A controls A.5.12 to A.5.14 with A.5.10, A.7.10 and A.8.12, and with the guidance in ISO/IEC 27002:2022. The procedure text, label texts, rule IDs, examples and guidance are original wording; ISO/IEC text is not reproduced, and the short control labels are descriptions written for this library, not official titles. ISO and IEC standards are copyrighted: obtain the official standards from ISO (https://www.iso.org/standard/82875.html) or your national standards body. TLP label names are used as published by FIRST; sanitisation references point to NIST SP 800-88 Rev. 2. Check the current editions of all referenced standards before use. Template licence: MIT.

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