ISO 27001 Annex A 5.9: Inventory of information and other associated assets

What auditors look for

Auditors check that 5.9 is either justified as not applicable in your Statement of Applicability or implemented and working. Typical evidence includes:

• Asset inventory with owners
• Data inventory or records of processing
• Evidence the inventory is reviewed

How to implement 5.9 in practice

1. Combine automated discovery with owner confirmation
2. Include SaaS and cloud services
3. Link the inventory to classification and risk
4. Name an owner for 5.9, decide how often it runs and file evidence each time, so the control is audit-ready all year.

How 5.9 supports GDPR

This control helps demonstrate GDPR Art. 30. Map it once in your control matrix so the same evidence supports both ISO 27001 and GDPR accountability. See the GDPR compliance checklist.

Recording 5.9 in the Statement of Applicability

List 5.9 with whether it applies, the reason (usually the risks it treats or a legal or contractual requirement), its implementation status and where the evidence lives. If you exclude it, explain why none of your risks or obligations require it.

Free resources

• GDPR compliance checklist for security teams
• ISO 27001 and GDPR readiness assessment
• 10 steps to implement ISO 27001
• Remote ISO 27001 consultant

More organizational controls

• 5.5 Contact with authorities
• 5.6 Contact with special interest groups
• 5.7 Threat intelligence
• 5.8 Information security in project management
• 5.10 Acceptable use of information and other associated assets
• 5.11 Return of assets
• 5.12 Classification of information
• 5.13 Labelling of information