Building a Compliant ISO 27001 Information Transfer Policy

On 9 September 2025, China’s regulator found Dior’s Shanghai branch had unlawfully transferred customer data to France without required approvals, contracts, or encryption.

As organizations adopt Generative AI and expand globally, information flows faster and farther than ever. Each unmanaged transfer now carries real compliance risk.

An ISO 27001 Information Transfer Policy, anchored by Annex A.13.2, sets clear rules for sharing, protecting, and tracking data ensuring every exchange is secure, legal, and auditable.

This blog breaks down what the policy coves, why it matters, how to build one, and how automation makes audit easier with practical tips and real-world examples throughout.

TL;DR

ISO 27001’s Information Transfer Policy turns secure data sharing from a vague expectation into a clear, actionable routine.

Annex A.13.2 requires you to set clear rules for all types of data transfers: internal, external, and cross-border, and to keep records that prove those rules are followed.

Effective information transfer is less about paperwork and more about real, everyday habits: using approved channels, encrypting sensitive files, and keeping transfers traceable.

What is ISO 27001 information transfer policy?

An ISO 27001 Information Transfer Policy is a documented framework that defines how an organization shares, transmits, or exchanges information internally and externally in a secure, controlled, and compliant manner. 

It forms a critical component of the Information Security Management System (ISMS) and ensures that every data transfer, whether digital or physical, follows defined procedures to protect confidentiality, integrity, and availability.

The policy operationalizes Annex A.13.2 of ISO 27001, which mandates organizations to establish and enforce security measures for data in transit. It specifies approved transfer methods, authentication requirements, encryption standards, and responsibilities for monitoring and logging all transfers.

If you implement this policy, your HR department will share files containing personal data using an encrypted SFTP channel with multi-factor authentication, ensuring that only authorized parties can access and track the data exchange.

Why does secure information transfer matter in ISMS?

The value of an information transfer policy is in the discipline it enforces. 

In modern organizations, data exchange happens between people, apps, APIs, and automated workflows. Every hop adds both convenience and risk.

Secure information transfer matters because it:

1. Ensures that data transfer does not disrupt business processes and operations
2. Sets clear rules to prevent sensitive data from being shared through unverified channels or unauthorized integrations
3. Provides auditable proof of how data in transit is protected 
4. Builds security habits into daily operations when teams understand transfer protocols
5. Creates a complete evidence trail that accelerates audit closure and reduces findings through logged, encrypted, and approved transfers

Rather than acting as an isolated control, secure data transfer becomes a thread that ties together technical safeguards, human processes, and governance oversight. This makes compliance a continuous practice. 

Overview of ISO 27001 Annex A.13.2. requirements

Annex A.13.2 of ISO 27001 sets out how organizations should safeguard information as it moves, whether that’s between internal systems, across teams, or out to third parties.

At its core, this annex expects organizations to:

• Establish clear policies and procedures for all information transfers, defining which types of data require additional protection and who is responsible for enforcing these controls.
• Apply safeguards to every transfer channel, including email, APIs, file-sharing platforms, and messaging tools. Each method should have the right level of security, such as encryption, access controls, and activity logs.
• Set expectations with external partners and vendors. This requires that when data leaves your organization, agreements or requirements are in place to ensure it’s still handled securely on the other end.
• Ensure accountability and traceability. Every data transfer must be traceable, with evidence that controls are working as intended. Regular reviews and audits help spot gaps and strengthen processes.

Annex A.13.2 embeds security into the daily flow of information, making safe transfers the default.

Key components of an information transfer policy

A well-structured Information Transfer Policy provides a repeatable framework for handling, transmitting, and auditing sensitive information across systems and teams.

These are the components that make a policy both practical and compliant:

Component	What it Means	Pro Tip
Purpose & Scope	Explains why the policy exists and which types of data, teams, or transfers it applies to.	Connect transfer types to risk categories for clarity.
Roles & Responsibilities	Outlines who is involved in data transfers—who approves, who sends, who monitors—and their duties.	Keep a simple chart of responsibilities for quick reference.
Approved Methods	Lists the secure channels and tools that are officially allowed for moving data within or outside the org.	Make unapproved tools off-limits in your IT policy.
Authentication & Access	Describes how the organization checks identities and controls who can access or send data.	Always enable multi-factor authentication where possible.
Encryption & Protection	Details the required protections—like encryption standards—for data while it’s moving and at rest.	Note your encryption standards in a shared doc for audits.
Logging & Audit Trails	Specifies how transfers are recorded and tracked, creating an evidence trail for reviews or audits.	Review logs regularly, not just before audits.
Third-Party & Cross-Border	Explains how the organization manages data sent to vendors or overseas, and the requirements for external transfers.	Ensure contracts with vendors address security expectations.
Monitoring & Review	Defines how and when the policy and its effectiveness are checked, and who is responsible for updates.	Link reviews to your regular ISMS meetings.
Exceptions & Incident Handling	Lays out the process for handling policy breaches or mistakes, and for logging and resolving incidents.	Log all exceptions to show ongoing improvement.

7 Examples of information transfer methods

Information moves through countless channels, some visible, others embedded deep within automated systems. Understanding these methods helps teams apply the right level of protection where it matters most. 

• Email and messaging platforms:
  Still the most common way business data travels, email and chat tools handle everything from invoices to confidential project notes.
  
  Security here depends on using encryption (like TLS), domain protection protocols such as SPF, DKIM, and DMARC, and enforcing policies against sending sensitive data in plain text or through personal accounts.
  
• File-sharing and collaboration tools:
  Platforms like OneDrive, Google Drive, or Slack make teamwork seamless, but also expand the attack surface, especially in remote work. You should use access restrictions, link expiry settings, and watermarking for documents classified as confidential.
  
  Where possible, integrate these tools with identity providers to apply centralized access controls.
  
• Managed File Transfer (MFT) systems:
  When large or regulated data sets need to be transferred, MFT solutions offer a structured alternative with automated encryption, activity logging, and delivery confirmation.
  
  A typical use case is securely exchanging financial data or customer reports with partners.
  
• Removable media and offline transfers:
  Although rare in cloud-first environments, removable drives still appear in air-gapped setups or when transferring backups. Every use must be logged, encrypted, and limited to approved personnel.
  
  Even a single untracked USB drive can compromise months of compliance work.

How to implement a secure information transfer procedure?

Building a secure information transfer procedure creates a repeatable routine your teams can trust. 

A good procedure brings structure to how information moves and proves that security is embedded in your day-to-day operations:

1. Map your information flows

Start by identifying what kinds of data your organization sends or receives, where it goes, and who handles it. 

Use data flow diagrams to visualize movement between systems, vendors, and regions. 

2. Define approved transfer channels

Decide which tools and methods are allowed for each data type. 

For example, SFTP for customer files, encrypted email for contracts, and secure APIs for system-to-system exchanges. And, restrict the rest.

3. Apply authentication and encryption consistently

Use identity-based access (SSO or MFA) and strong encryption (AES-256, TLS-1.3). 

Automate wherever possible to reduce dependency on manual checks, which will make it easier for your organization to monitor every single flow of information.

4. Monitor and log every transfer

Implement monitoring systems that record who sent what and how, and store the logs in your SIEM or ISMS dashboard to simplify audits.

5. Test, train, and improve

Regularly review failed transfers or exceptions and train your employees on what a secure transfer looks like and why it matters. 

Done right, these steps turn compliance controls into everyday safeguards, helping teams move fast without risking data integrity.

3 common risks in data transfer and how to mitigate them

Even with the right policies, information transfers come with their own set of pitfalls. Some are technical, others are all too human.

1. Accidental exposure: 
   The most common risk is someone sending the wrong file, or using the wrong channel. One click and sensitive data lands in the wrong inbox or Slack channel.
   
   Mitigation: Use clear labeling, limit who can access certain files, and set up data loss prevention (DLP) tools to flag mistakes before they happen.
   
2. Shadow IT and unsanctioned tools: 
   Well-meaning employees use their own tools, public cloud links, or unauthorized apps to “get work done faster,” bypassing controls.
   
   Mitigation: Make it easy for people to request access to secure, approved tools, and regularly audit usage. Restrict the use of unapproved tools and train teams to spot and avoid risky shortcuts. Enforce MFA and encryption on all approved channels.
   
3. Intercepted or tampered data: 
   Data in transit can be intercepted if not properly encrypted.
   
   Mitigation: Always encrypt sensitive data in transit (TLS 1.3, SFTP). Log and review all transfer activity so nothing slips through the cracks.

No system is perfect, but with practical controls and ongoing awareness, you can keep everyday transfers safe and compliant.

ISO 27001 controls for data transfer (A.13.2.1, A.13.2.2, A.13.2.3)

The heart of secure information transfer in ISO 27001 controls is found in Annex A.13.2, which breaks the topic into three actionable controls:

A.13.2.1: Information transfer policies and procedures

This control requires organizations to define and document how information is to be transferred formally. It includes approved channels, responsibilities, formats, and safeguards that apply to internal and external data exchanges. 

For example:

A company specifies that sensitive project files must only be transferred via a secure Managed File Transfer (MFT) service with encryption at rest and in transit, never through personal email or unapproved messaging apps.

A.13.2.2: Agreements on information transfer

Whenever data is transferred between organizations, these controls mandate creating binding agreements that outline the security expectations, encryption methods, and liability for each party.

These agreements are crucial for cross-border or vendor-based data flows. 

For example:

A SaaS vendor handling customer data signs a Data Processing Agreement (DPA) that defines how data will be encrypted during transmission, who can access it, and how incidents will be reported and resolved. 

A.13.2.3: Electronic messaging

This control focuses on securing electronic messaging channels, including email, instant messaging, and system-to-system notifications. It will require organizations to protect messages from unauthorized access, spoofing, or alteration, and to ensure authenticity and non-repudiation where needed. 

For example:

Implementing domain-based message authentication (DMARC), encryption (TLS), and digital signatures for all outbound corporate emails to prevent tampering and impersonation.

When applied together, these controls establish a closed-loop system for secure data exchange from defining internal transfer standards to enforcing them across vendors and automated systems. They also form the foundation of a defensible audit trail proving that data sharing is not just permitted but continuously governed. 

Enable information transfer compliance with Sprinto

One of the toughest parts of ISO 27001 compliance is gathering real proof that your team follows it every day. 

That’s where Sprinto steps in. Sprinto integrates with your existing systems to automatically collect the evidence auditors care about. 

For every information transfer, it can:

• Map and monitor transfer activities: Sprinto connects to your file-sharing, email, and API platforms to track when, how, and by whom sensitive data is moved.
• Log access and approvals: The platform records who initiates transfers, which approvals were given, and whether the right channels and encryption were used.
• Automate control testing: Sprinto runs regular checks to confirm that only approved transfer methods are in use and that policy violations are flagged instantly.
• Centralize audit trails: All transfer records and exception logs are stored in a single dashboard, making it easy to respond to auditor requests or internal reviews.

With these automated workflows, compliance teams spend less time searching for screenshots or sifting through emails and more time enhancing actual security outcomes.

Ready to make information transfer compliance seamless? Speak to our experts.

Frequently asked questions