ISO/IEC 27701:2025·Annex A A.3.20·high·Component: Security considerations

What this control requires

Manage storage media life cycle in accordance with classification & handling requirements. Implementation: Track media, use encryption where possible, apply secure disposal. Justification: Controls prevent leakage via removable/physical media.
— ISO/IEC 27701:2025, Annex A A.3.20

In plain English

Manage storage media life cycle in accordance with classification & handling requirements. In practice, this means you can prove you implement storage media-level controls on a defined cadence.

Why it matters

ISO 27701 is the international way to evidence the GDPR principle of accountability: certified PIMS controls translate directly into the records, contracts and rights-handling that supervisory authorities want, and into the privacy-engineering evidence SOC 2 + Privacy auditors and enterprise procurement teams ask for.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

PIMS auditors expect ISO 27001 to be implemented first and then the 27701-additional controls tested. For PII controllers they look at lawful-basis and rights-handling evidence; for PII processors they look at customer-instructions, sub-processor controls and return/transfer/disposal evidence.

Within Security considerations, the assessor will trace your implementation back to the catalogue reference (Annex A A.3.20) and look for objective evidence on the latest two assessment cycles.

How to implement

Physical Security

Inheritance. For cloud-only operations, inherit physical controls from the provider's SOC 2 / ISO 27001 report and document the inheritance in the SoA.

Asset Inventory

AWS. AWS Config Aggregator across every account + region gives a real-time inventory; ship the daily snapshot to S3 and surface drift in Security Hub.

Azure. Azure Resource Graph plus Defender for Cloud's inventory blade enumerates every subscription; export to Log Analytics for retention and Workbooks for reporting.

GCP. Cloud Asset Inventory exports a daily feed of every resource and IAM binding; query via BigQuery and alert on appearance/disappearance.

Endpoints. Pipe MDM telemetry (Intune / Jamf / Workspace ONE) into your CMDB so laptops and phones are inventoried with the same rigour as cloud resources.

Operational checklist

  • Implement. Document the trigger, the owner and the cadence.
  • Encrypt. Document the trigger, the owner and the cadence.
  • Scope: storage media.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Focus: Storage media.

Common pitfalls

  • Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.

Related controls in ISO/IEC 27701:2025

References

Topics: data protectionphysical securityasset inventory