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Data transfers
ASD ISMISM-0664

ASD ISM 0664 Authorisation of SECRET data exports

What it says

Data exported from SECRET and TOP SECRET systems is reviewed and authorised by a trustworthy source beforehand.

Quoted as published. Everything else on this page is written by Control Stack.

What it means

In plain English

Ensure data from high-security systems is checked and approved before export.

This control is about making sure that whenever data is taken out of highly secure systems, like those marked SECRET or TOP SECRET, it gets checked and approved by someone we trust first. This is important because if sensitive data leaks, it could cause real harm, like identity theft or a threat to national security.

Why it matters

If SECRET/TOP SECRET exports aren't reviewed and authorised, sensitive data may be released, causing compromise, national security harm and loss of trust.

How to implement

  1. The IT team should work with department heads to create a formal process for data export approval.

    This involves setting up clear steps, like filling out a data export request form and identifying who in leadership will give the final approval. Clearly outline this process in a document and share it with everyone involved.

  2. Managers need to designate trustworthy employees who have the responsibility to approve data exports.

    This involves selecting people who understand the importance of data security and have a good track record. It's also essential that these employees have the adequate security clearances needed to review sensitive data.

  3. The security team should regularly provide training on recognising sensitive data and understanding the risks associated with exporting it.

    Sessions should include real-world examples and how breaches have affected other organisations. Information should be made easy to understand so that everyone, even non-technical staff, gets the message.

  4. Human Resources (HR) should establish a system that periodically reviews the list of employees who are authorised to approve data exports.

    This includes ensuring these employees are still in good legal standing and understanding current security protocols. HR should work closely with the security team to update this list as necessary.

  5. System owners should use encryption to protect sensitive data files meant for export.

    This means converting the information into a code to prevent unauthorised access, even if the data falls into the wrong hands. Implement tools and software that handle encryption as part of the data export pipeline.

Keep it running

Maintain a current list of trustworthy reviewers and require documented pre-export review and authorisation for all data leaving SECRET/TOP SECRET systems.

Evidence and audit

  1. Check 1 of 5What an auditor asks for

    Ask for

    The data export approval documents: Request copies of forms or emails that show who approved each data export and what data was included.

    Look at

    The names of approvers and cross-reference them with a list of authorised personnel.

    Good evidence

    Will include clear authorisation records showing the approver's name, date, and approval details.

  2. Check 2 of 5What an auditor asks for

    Ask for

    To see the training records for staff involved in data export processes: Review attendance records and training materials.

    Look at

    Evidence that all relevant employees have completed up-to-date training.

    Good evidence

    Includes dated records of training sessions and signed acknowledgments by attendees.

  3. Check 3 of 5What an auditor asks for

    Look at

    How often this list is reviewed and updated.

    Good evidence

    Is a regularly updated document with dates of review and a clear change management process.

  4. Check 4 of 5What an auditor asks for

    Ask for

    A demonstration of the data encryption process: Observe the encryption being applied to sensitive data meant for export.

    Look at

    The encryption method used and if security standards are maintained.

    Good evidence

    Shows strong, current encryption practices according to industry standards.

  5. Check 5 of 5What an auditor asks for

    Look at

    How incidents are investigated and resolved.

    Good evidence

    Shows a clear, actionable incident response plan that is periodically tested and updated.

Mappings

Closest match in ISO/IEC 27001: A.8.12, Data leakage prevention measures, which partially overlaps with this control.

ISO 27001

ISO/IEC 27001: 1 mapping

  • A.8.12Data leakage prevention measuresPartially overlaps

Mappings show how controls relate across frameworks. They do not imply full equivalence or certification.