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CISO Times

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The CISO Decision Brief

How do we…

How do we decide how to prevent data leakage and set the rules for sending information out, under ISO 27001?

8 decision pointsThe pack behind this answer: ISO 27001 Implementation & Certification Readiness

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The short answer

Recommendation
Classify first, then list the channels information can leave by and set a rule for each by level. Use the settings of the tools you already have, warn before you block, make sure someone handles the alerts, and buy a dedicated product only where the gaps justify it. Test every channel.
Reasoning
Public guides and the pack agree that the leakage control does not require a product, but it does require rules that work. Auditors look for sharing restrictions, alert rules and evidence that alerts were handled. The common failures are a tool left in monitor mode for ever, rules so noisy that alerts are ignored, email rules that ignore sharing links and messaging apps, and external sharing left open by default.
Considerations
  • The standard's text is paywalled. The controls are described from the pack's Library and public guides, which are secondary.
  • Some data loss prevention vendors argue a product is effectively required. That is a sales position. Check with your certification body what it expects.
  • Monitoring content touches privacy and employment law. Agree what you inspect with whoever advises on data protection.
  • Transfer rules for AI services follow the approved tool list in your classification policy.

The decision, step by step

Select any step for the reasoning behind it and where the pack covers it.

  • Start
  • Step
  • Decision
  • Outcome
  • Loop back

Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.

Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.

Read as text

The same flow written out: each step, its reasoning and where the pack covers it. 22 steps.
  1. Start

    We must stop information leaving without authority and set rules

    Two controls meet here. One protects information while it moves by email, file transfer, courier or conversation. The other detects and blocks it leaving without authority. The decision is which channels you control, how hard, and whether built-in settings are enough or a dedicated tool is justified.

    In the pack

  2. Decision

    Does a classification scheme exist that staff use?

    The pack's rules are set by level, so an enforceable rule needs levels to work from. Without them every rule says 'sensitive' and nothing can be enforced. If staff do not use levels, answer no.

    In the pack

  3. Outcome

    Classify first, then return

    A tool cannot tell what is sensitive until you tell it. Build the scheme and the handling rules, and then come back to the channels.

    In the pack

  4. Step

    List the channels information can leave by

    Email, links to cloud sharing, messaging apps, removable media, uploads to personal and AI services, printing, and courier or conversation. The Library names email rules that ignore file-sharing links and messaging apps as a mistake. Include channels you do not want, to decide what to block.

    In the pack

  5. Step

    Set a rule for each channel by level: tools, senders and recipients

    The pack's handling matrix has a row for sharing outside and one for transferring, per level. Confidential information goes only to an approved recipient, for a recorded purpose, by an approved channel, with the address checked. Write the rule per channel, not as one general sentence.

    In the pack

  6. Decision

    Can tools you already have limit external sharing and warn on content?

    Email, office and cloud storage platforms usually have sharing limits, labels and basic content rules. The Library says to start with the tools you have. External sharing left open by default is its named mistake. If you have not looked at the settings, answer no.

    In the pack

  7. Step

    Look at the sharing, labelling and content settings of each platform

    List what each email, office and storage platform can do now: external sharing limits, labels, warnings, upload restrictions. Turn on what the licence allows. Only then judge what is left for a product to do.

    In the pack

  8. Decision

    Would blocking stop legitimate work?

    A rule that blocks routine work is bypassed, and a tool left in monitor mode for ever is the Library's named mistake. If you do not know what normal sharing looks like, answer yes and start by warning.

    In the pack

  9. Step

    Warn and log first, with a date to move to blocking

    Run the rule in warn or monitor mode for a short, fixed period, review what it catches, adjust it and then switch it to block. Record the date. Sharing with a regular partner can use an approved route that the rule allows.

    In the pack

  10. Step

    Block the transfer and give a safe way to do the task

    Block what the rule prohibits and tell staff the approved alternative, such as the managed sharing site, so the task can still be done. Set a way to ask for an exception.

    In the pack

  11. Decision

    Does a named person handle the alerts within a stated time?

    Rules so noisy that alerts are ignored are the Library's named mistake. Before turning on more rules, check someone reads the ones you have. If alerts go to a shared mailbox, answer no.

    In the pack

  12. Step

    Name who reviews alerts, how fast, and what counts as an incident

    Give the alerts an owner and a response time. Set a short list of what must go to the incident route, such as a bulk export or a Confidential file sent to a personal address.

    In the pack

  13. Decision

    Does the risk justify a dedicated data loss prevention product?

    Then consider regulated data in volume, a customer or regulator expecting it, built-in tools that cannot cover a major channel, and your capacity to run it. Public sources say the control does not require a product, though some vendors claim otherwise. If the gaps in your list are small, answer no. If yes, trial a tool on your highest-risk channel, measure false alerts and cost the people to tune it.

    In the pack

  14. Step

    Record the rules and settings as the treatment, accepted by the owner

    Write down what the built-in controls do and do not cover, and have the risk owner accept the remainder. This is a valid treatment, as long as it is a recorded decision. Say which built-in limits you turned on and which channels remain open.

    In the pack

  15. Decision

    Do you regularly exchange Confidential information with a partner?

    The Library asks for transfer terms in agreements with parties you exchange information with regularly: what may be sent, how, who may receive it and what happens at the end. If you have such partners and no terms, answer yes.

    In the pack

  16. Step

    Put transfer terms in the agreement

    State the channel, the encryption, who may receive, the retention and how the partner reports loss. Use the clause library as a start.

    In the pack

  17. Decision

    Can staff paste Internal or Confidential data into AI tools?

    AI tools and personal storage are channels. The pack's classification policy lets Internal and Confidential information into only the AI tools the organisation has approved for that level, under a contract that bars training on its data. If you have no list of approved tools, answer yes.

    In the pack

  18. Step

    Name the approved tools by level and block the rest

    Publish the list and the levels allowed, enforce it at the web or sign-in layer where you can, and ask staff to report accidental pastes. The AI tools question covers the terms.

    In the pack

  19. Step

    Send a test item through each channel

    Use a harmless file marked at the highest level and try each channel, including a personal address. Show whether it is blocked, warned, logged or alerted. The Library lists the rules and how alerts were handled as evidence.

    In the pack

  20. Decision

    Did every channel behave as the rule says?

    Any channel that let the item through silently is a gap. If you did not test, answer no.

    In the pack

  21. Step

    Adjust the rule or the setting, then test again

    Fix the setting that failed, record the change and test the same channel again. Repeat until the test behaves as the rule says.

    In the pack

  22. Outcome

    Leakage and transfer rules set, tested and owned

    Keep the channel list, the rules, the settings, the alert handling record and the test result. Do not say you have data loss prevention because a product is installed in monitor mode, or that information cannot leave because one channel is blocked.

    In the pack

Practical checklist

  1. Confirm a classification scheme exists that staff use.
  2. List the channels information can leave by, including links, messaging, media and AI tools.
  3. Set a rule for each channel by level, and use the settings of the tools you already have.
  4. Run new rules in warn mode for a fixed period, then block, and name who handles the alerts.
  5. Decide on a dedicated tool by the gaps left, or record the built-in controls as the treatment.
  6. Put transfer terms in agreements with regular partners, and test every channel.

Evidence to have ready

  • The channel list and the rule for each by classification level.
  • Platform sharing and upload restrictions, and any rule and alert settings.
  • The alert handling record, showing who looked and when.
  • Transfer terms in agreements, and the test result.

Assumptions

  • A classification scheme exists, or you are building one, so rules can refer to levels.
  • You can see the sharing and upload settings of your email, office and storage platforms.
  • Someone can be named to handle alerts, and someone advises on data protection.

Not covered here