1. Purpose

This Information Transfer Policy defines requirements for the secure transfer, sharing, transmission, and exchange of organizational information.

The objective is to ensure that information is transferred only through authorized methods, to authorized recipients, with appropriate protection based on its classification, sensitivity, risk, and applicable legal, regulatory, contractual, and customer requirements.

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2. Scope

This policy applies to:

• Employees
• Contractors and consultants
• Interns and temporary personnel
• Third parties and suppliers
• Customers where applicable
• Business partners
• Auditors
• Service providers

It covers information transferred through:

• Email
• Cloud storage
• File-sharing platforms
• Collaboration tools
• Messaging platforms
• APIs
• System-to-system integrations
• Secure file transfer
• Source-code repositories
• Physical documents
• Removable media
• Mobile devices
• Remote access
• Cloud environments
• Customer portals
• Approved AI and SaaS services

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3. Policy Principles

Information transfers must follow these principles:

1. Know what information is being transferred.
2. Apply the appropriate information classification.
3. Transfer information only for an authorized business purpose.
4. Verify the recipient before sending information.
5. Use approved transfer methods.
6. Apply appropriate protection based on risk and classification.
7. Minimize the amount of information transferred.
8. Protect Confidential and Restricted information appropriately.
9. Do not transfer credentials or secrets through insecure channels.
10. Follow legal, regulatory, contractual, and customer requirements.
11. Maintain evidence where required.
12. Report accidental or unauthorized transfers immediately.

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4. Information Classification

Information must be handled according to its classification.

Classification	Transfer Requirement
Public	May be shared publicly when authorized
Internal	Transfer only to authorized recipients
Confidential	Approved recipients and secure transfer methods required
Restricted	Strict authorization, controlled recipients, and strong protection required

The organization’s Information Classification Policy defines the formal classification scheme.

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5. Information Transfer Process

The standard transfer process is:

Identify → Classify → Confirm Purpose → Verify Recipient → Authorize → Select Transfer Method → Protect → Transfer → Confirm Receipt → Record → Monitor

The level of control should be proportionate to the sensitivity and risk of the information.

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6. Before Transferring Information

Before transferring information, the sender should determine:

• What information is being transferred?
• What is its classification?
• Why is it being transferred?
• Who is receiving it?
• Is the recipient authorized?
• Is external sharing permitted?
• Is customer approval required?
• Are privacy requirements applicable?
• Are contractual restrictions applicable?
• Is encryption required?
• Is the transfer method approved?
• Is the transfer required to be recorded?

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7. Recipient Verification

The sender must verify the intended recipient before transferring sensitive information.

Verification may include:

• Confirming email address.
• Confirming organization/domain.
• Confirming identity.
• Confirming authorization.
• Confirming project involvement.
• Using approved corporate directories.
• Using an approved customer/supplier portal.

For high-risk transfers, an additional verification step should be performed.

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8. Internal Information Transfer

Information transferred internally must be shared only with personnel who have a legitimate business need.

Examples:

• HR → Payroll
• Security → Engineering
• Compliance → Management
• Finance → Authorized accounting personnel
• Customer Support → Authorized engineering personnel

Confidential information should not automatically be distributed to an entire department when only specific individuals require access.

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9. External Information Transfer

External transfers require appropriate authorization.

Examples include:

• Customer information
• Security reports
• Audit reports
• Contracts
• Employee information
• Financial information
• Technical documentation
• Source code
• Vulnerability reports

Before external transfer:

Business Need → Classification → Recipient Verification → Authorization → Secure Transfer → Evidence

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10. Email Transfer

Email may be used for information transfer when appropriate to the classification and risk.

Before sending:

• Verify recipient address.
• Check CC/BCC recipients.
• Check attachments.
• Confirm authorization.
• Confirm classification.
• Use approved corporate email.
• Apply encryption or other protection where required.

Do not send:

• Passwords
• API keys
• Private keys
• Production credentials
• Authentication tokens

through ordinary email.

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11. Confidential Information by Email

When Confidential information is transferred through email:

• Verify the recipient.
• Use an approved corporate account.
• Use encryption or password protection where required.
• Avoid unnecessary recipients.
• Avoid unnecessary copies.
• Use secure links where appropriate.
• Apply access expiry where supported.

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12. Restricted Information Transfer

Restricted information requires enhanced controls.

Examples:

• Production credentials
• Encryption keys
• Critical security architecture
• Active vulnerability details
• Security incident investigation information
• Highly sensitive customer information

Restricted information should generally be transferred using approved secure mechanisms such as:

• Restricted document repositories
• Secure portals
• Approved encrypted file transfer
• Approved secrets-management platforms
• Controlled cloud sharing

Access should be limited to specifically authorized recipients.

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13. Cloud File Sharing

Approved cloud platforms may be used for information transfer.

Before sharing a cloud link:

• Verify recipient.
• Restrict access to named users where possible.
• Avoid public links.
• Apply expiration dates where appropriate.
• Disable unnecessary download/edit permissions.
• Review sharing permissions.
• Remove access when no longer required.

Avoid:

“Anyone with the link can access”

for Confidential or Restricted information unless specifically approved and justified.

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14. Collaboration and Messaging Platforms

Approved collaboration tools may be used for business information.

Users must:

• Use approved platforms.
• Confirm channel membership.
• Avoid posting sensitive information in public/general channels.
• Follow information classification requirements.
• Avoid sharing credentials and secrets.
• Remove or restrict information when appropriate.

Restricted information should only be shared through specifically approved restricted-access channels.

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15. File Transfer

Where files contain sensitive information, use approved secure file-transfer mechanisms.

Examples include:

• Secure customer portals
• Managed file-transfer platforms
• Approved encrypted cloud storage
• Secure document-management platforms
• Approved encrypted transfer mechanisms

Where passwords are used to protect a file, the password should be communicated through a separate secure channel.

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16. API and System-to-System Transfers

Information transferred between applications or systems must use approved technical mechanisms.

Controls may include:

• TLS/encrypted communication
• API authentication
• Authorization
• Service accounts
• API gateways
• Token management
• Encryption
• Input validation
• Logging
• Monitoring
• Rate limiting
• Network restrictions

API credentials must not be embedded in source code or transmitted through insecure channels.

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17. Cloud and AWS Information Transfer

For AWS-based SaaS environments, information transfers may occur through:

• APIs
• HTTPS
• S3
• Application Load Balancers
• API Gateway
• CloudFront
• Database connections
• Secure integration services

Appropriate controls may include:

• TLS
• IAM
• Least privilege
• KMS
• Secrets Manager
• Security Groups
• Network controls
• CloudTrail
• CloudWatch
• Logging and monitoring

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18. Source Code Transfer

Source code should be transferred only through approved repositories or development platforms.

Users must not:

• Email proprietary source code unnecessarily.
• Upload source code to public repositories.
• Share repositories without authorization.
• Upload proprietary source code to unapproved AI tools.
• Store credentials in transferred source code.

External source-code sharing should be approved and appropriately controlled.

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19. Transfer of Credentials and Secrets

Credentials and secrets require special handling.

Examples:

• Passwords
• API keys
• SSH keys
• Private keys
• Cloud credentials
• Database passwords
• Authentication tokens
• Encryption keys

Use approved mechanisms such as:

• Password managers
• AWS Secrets Manager
• Azure Key Vault
• Google Secret Manager
• Approved privileged access-management platforms

Do not transmit secrets through:

• Ordinary email
• Public chat
• Public repositories
• Unapproved file-sharing services
• Public tickets
• Unapproved AI systems

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20. Customer Information

Customer information must be transferred according to:

• Customer contracts
• Data-processing requirements
• Privacy requirements
• Security requirements
• Customer-approved mechanisms

Where customers provide a specific secure portal or transfer mechanism, it should normally be used where applicable.

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21. Personal Data

Transfers involving personal data must consider:

• Purpose of transfer
• Data minimization
• Recipient authorization
• Applicable privacy requirements
• Data-processing agreements
• Cross-border transfer requirements where applicable
• Security controls
• Retention and deletion requirements

Only the information necessary for the authorized purpose should be transferred.

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22. Third-Party and Supplier Transfers

Before transferring information to a supplier or third party:

• Confirm business need.
• Identify information classification.
• Verify supplier authorization.
• Review contractual requirements.
• Review confidentiality requirements.
• Assess security requirements.
• Consider privacy requirements.
• Define retention/deletion requirements.
• Use approved transfer methods.

Third-party access should be removed when no longer required.

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23. Physical Information Transfer

Physical documents or storage media containing sensitive information must be protected during transportation.

Controls may include:

• Sealed packaging
• Authorized courier
• Tracking
• Recipient confirmation
• Tamper-evident packaging
• Secure storage
• Chain-of-custody records where required

Restricted physical information should receive additional protection based on risk.

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24. Removable Media

Use of USB drives or other removable media for information transfer should be restricted.

Where approved:

• Use organization-approved media.
• Encrypt sensitive information.
• Scan media where appropriate.
• Restrict access.
• Maintain custody where necessary.
• Securely erase information after use.

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25. Remote Working

When transferring information while working remotely:

• Use approved systems.
• Use secure network connections.
• Avoid public computers.
• Verify recipients carefully.
• Protect screens and devices.
• Avoid transferring sensitive information through personal accounts.
• Follow the Remote Working Policy.

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26. Cross-Border Information Transfer

Where information is transferred across countries or regions, the organization should consider:

• Applicable privacy laws.
• Regulatory requirements.
• Customer contracts.
• Data-processing agreements.
• Data residency requirements.
• Cross-border transfer mechanisms.
• Security requirements.
• Customer-specific restrictions.

Legal/privacy review should be obtained where the transfer presents significant regulatory or contractual implications.

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27. AI and Information Transfer

Information must not be transferred to an AI service merely because it is technically possible.

Before entering organizational information into an AI system:

Identify Data → Classify → Verify Tool Approval → Assess Use Case → Confirm Authorization → Minimize Data → Use Securely → Human Review

Confidential or Restricted information should not be entered into public or unapproved AI services.

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28. Transfer Logging and Monitoring

Transfers should be logged where appropriate based on risk.

Records may include:

• Sender
• Recipient
• Date/time
• Information type
• Classification
• Transfer method
• Business purpose
• Approval
• File/reference
• Expiry date
• Confirmation of receipt

Technical logs may include:

• API activity
• Cloud access logs
• File downloads
• Authentication events
• Administrative activity
• Security alerts

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29. Receipt Confirmation

For sensitive or critical transfers, the sender should confirm that:

• The recipient received the information.
• The intended recipient accessed it.
• The transfer was successful.
• No unauthorized recipient received it.
• Temporary access is removed when appropriate.

For highly sensitive transfers, retain confirmation as evidence.

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30. Data Loss Prevention

Where DLP capabilities are available, they may be used to identify or prevent unauthorized transfers of sensitive information.

Examples:

• Sensitive data detection
• Email DLP
• Endpoint DLP
• Cloud DLP
• SaaS monitoring
• Upload restrictions
• USB restrictions
• Data classification labels

DLP controls should support, rather than replace, user awareness and access controls.

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31. Information Transfer Agreements

Where appropriate, information-sharing arrangements should define:

• Information being exchanged
• Purpose
• Authorized recipients
• Security requirements
• Confidentiality requirements
• Transfer method
• Access controls
• Retention period
• Deletion/return requirements
• Incident notification
• Regulatory requirements
• Responsibilities of each party

Formal agreements may include:

• NDA
• Data Processing Agreement
• Information-sharing agreement
• Customer security agreement
• Supplier agreement
• Contractual security requirements

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32. Transfer Exceptions

Exceptions to this policy must:

1. Have a documented business reason.
2. Be risk assessed.
3. Identify compensating controls.
4. Have an appropriate owner.
5. Have an expiry/review date.
6. Be approved by the designated authority.

Exception ID	Requirement	Reason	Risk	Compensating Control	Owner	Expiry	Approval
EX-001	[Requirement]	[Reason]	[Risk]	[Control]	[Owner]	[Date]	[Name]

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33. Incorrect or Unauthorized Transfer

If information is sent to the wrong person or transferred through an unauthorized mechanism:

Stop → Report → Preserve Evidence → Assess → Contain → Notify → Remediate → Document

Examples include:

• Wrong email recipient
• Incorrect cloud-sharing permission
• Public file exposure
• Unauthorized download
• Customer data sent to wrong customer
• Confidential document sent to personal email
• Source code uploaded publicly
• Credentials exposed
• Sensitive information entered into an unauthorized AI tool

Users must report such incidents immediately.

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34. Information Transfer Incident Assessment

The Security/Privacy team should assess:

• What information was transferred?
• What was the classification?
• Who received it?
• Was the recipient authorized?
• How much information was involved?
• Was personal/customer data involved?
• Was encryption used?
• Can access be revoked?
• Was the information downloaded?
• Are legal/regulatory notifications required?
• Are contractual notifications required?
• Is customer notification required?

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35. Responsibilities

Role	Responsibility
Top Management	Approves policy direction and resources
Information Owner	Determines classification and transfer requirements
Document/Data Owner	Defines appropriate handling
Security/ISMS Manager	Defines security controls and monitors compliance
IT/Cloud Team	Implements technical safeguards
Privacy/Legal	Advises on privacy, legal and contractual requirements
Procurement	Ensures supplier requirements are addressed
Employees	Follow approved transfer methods
Contractors	Transfer information only as authorized
Internal Audit	Independently verifies applicable controls

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36. Evidence and Records

Evidence may include:

• Information Classification records
• Data Inventory
• Access-control records
• Sharing permissions
• Transfer logs
• Secure file-transfer records
• Cloud-sharing configuration
• API logs
• DLP alerts
• Encryption configuration
• Customer agreements
• NDAs
• Data Processing Agreements
• Supplier agreements
• Access reviews
• Incident records
• Transfer approvals
• Exception records
• Training records

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37. Quick Transfer Decision Guide

Situation	Recommended Approach
Public information	Approved public channel
Internal information	Approved corporate system
Confidential document	Authorized recipient + controlled sharing
Restricted document	Explicit approval + restricted repository/secure transfer
Password/API key	Approved secrets-management mechanism
Customer data	Approved customer/organizational secure channel
Personal data	Secure transfer + applicable privacy requirements
Source code	Approved repository
Production data	Approved controlled environment
Physical sensitive document	Secure courier/controlled transfer
AI service	Approved tool and approved use case
External supplier	Contract/security requirements + approved transfer

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38. Startup-Friendly Implementation

A startup can implement this policy without creating excessive administrative work.

Minimum operating model

1. Classify
Know whether information is Public, Internal, Confidential, or Restricted.

2. Verify
Confirm the recipient before sending.

3. Use approved tools
Use corporate email, approved cloud storage, secure portals, approved repositories, and approved collaboration tools.

4. Protect sensitive information
Use encryption, MFA, access controls, and restricted sharing where appropriate.

5. Minimize
Transfer only the information actually required.

6. Record high-risk transfers
Maintain evidence for Restricted or otherwise significant transfers.

7. Remove access
Expire links and revoke access when the business requirement ends.

8. Report mistakes
Immediately report incorrect or unauthorized transfers.

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39. Relationship With Other ISMS Documents

This policy should operate together with:

• Information Security Policy
• Information Classification Policy
• Data Handling Guidelines
• Information Handling Procedure
• Restricted Document Template
• Access Control Policy
• Access Revocation Checklist
• Acceptable Use Policy
• Employee IT Usage Policy
• Remote Working Policy
• BYOD Policy
• AI Acceptable Use Policy
• Data Inventory
• SaaS Application Register
• Supplier Security Assessment
• Data Breach Response Procedure
• Incident Response Plan
• Regulatory Compliance Register
• Risk Register

The overall relationship is:

Information → Classification → Recipient → Authorization → Transfer Method → Protection → Transfer → Monitoring → Evidence → Review

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40. ISO 27001 Connection

This policy may support applicable requirements relating to:

• Information transfer
• Information classification
• Access control
• Access rights
• Secure authentication
• Data leakage prevention
• Cloud service security
• Supplier security
• Privacy and protection of personal information
• Secure disposal
• Logging and monitoring
• Incident management

The exact applicable controls should be determined through the organization’s risk assessment and Statement of Applicability (SoA).

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41. Review and Maintenance

This policy should be reviewed:

• At the defined ISMS review frequency.
• After significant information-transfer incidents.
• When new cloud/SaaS platforms are introduced.
• When new customer requirements arise.
• When significant technology changes occur.
• When applicable legal or regulatory requirements change.
• After significant audit findings.

The policy should also be reviewed when the organization’s information-transfer methods materially change.

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42. Final Audit Trail

A mature information-transfer process should demonstrate:

Identify → Classify → Confirm Purpose → Verify Recipient → Authorize → Select Secure Method → Protect → Transfer → Confirm Receipt → Monitor → Record → Revoke/Expire → Review → Improve

Final Principle

Send the right information, to the right person, for the right reason, through the right channel, with the right protection — and retain evidence when the risk requires it.