ISO 27701 Explained: Requirements for Privacy Governance

The challenge isn't understanding privacy principles — it's building systems that generate compliance evidence automatically, day after day.

ISO 27701 requirements provide the framework: a Privacy Information Management System (PIMS) that centralizes control over personally identifiable information, documents accountability, and transforms privacy from reactive scramble into strategic capability.

This guide covers what ISO 27701 requires, how to implement its controls operationally, and how it aligns with GDPR obligations.

What Is ISO 27701?

ISO/IEC 27701 specifies requirements for establishing, implementing, and maintaining a Privacy Information Management System. Published in August 2019 and updated significantly in October 2025, the standard provides structured privacy risk management and accountability.

Unlike policy documents gathering dust, a privacy program framework such as ISO 27701 requires operational evidence. Every data subject access request leaves a timestamped audit trail. Every deletion triggers verifiable proof across all systems. Every consent decision gets logged automatically.

The 2025 edition transformed ISO 27701 from an ISO 27001 extension into a standalone management system. Organizations can now pursue privacy certification independently, though information security foundations remain essential.

Relationship to ISO 27001

2019 Structure: Extended ISO 27001's ISMS with privacy-specific requirements. Organizations needed ISO 27001 certification first, then added 49 privacy controls.

2025 Structure: Operates independently with its own management clauses and 78 privacy-focused controls:

• 31 controls for PII Controllers (determining processing purposes)
• 18 controls for PII Processors (processing data on behalf of controllers)
• 29 information security controls for both roles

The PIMS Concept

A Privacy Information Management System differs fundamentally from policy collections.

Centralized Architecture: Every data touchpoint generates verifiable audit trails automatically.

Role-Based Assignment: Tasks carry explicit ownership with named individuals, timelines, and escalation paths.

Evidence-Driven Compliance: Proof comes from operational activities, not retroactive documentation.

Real-Time Responsiveness: Integrates new processing activities, regulatory changes, and vendor relationships continuously.

Why ISO 27701 Matters for Privacy Governance

ISO 27701 establishes clear accountability through a privacy governance structure with named individuals — not departments — responsible for each privacy function. This eliminates the "everyone's responsible so no one is accountable" problem.

The standard translates GDPR's qualitative requirements into specific, testable controls. Data minimization becomes documented retention policies and automated deletion. Transparency transforms into privacy notice templates and consent workflows. Accountability manifests as risk assessments and control testing evidence.

Measurable Benefits:

• 60-80% faster DSAR response through automated data discovery
• Procurement advantage as enterprise customers require certification
• Reduced regulatory risk through documented systematic compliance
• Operational efficiency via standardized workflows replacing manual effort

ISO 27701 Requirements Overview

Organizational Requirements

Context and Scope (Clause 4): Organizations define PIMS boundaries through comprehensive analysis of internal factors (existing security maturity, organizational structure, technology) and external factors (regulations, customer expectations, industry standards). The scope document identifies organizational units, locations, processing activities, and whether the organization acts as controller, processor, or both.

Leadership and Policy (Clause 5): Requires Privacy Policy Owner at senior management, measurable privacy objectives (e.g., "Respond to 95% of DSARs within 20 days"), documented privacy policy accessible to data subjects, and regular management communication affirming privacy as strategic priority.

Governance Structure

ISO 27701 requires named individuals — not departments — for each role:

• Privacy Policy Owner: Ultimate PIMS accountability
• Data Protection Officer: Independent oversight (where legally required)
• PII Controller Designate: Determines lawful basis, manages consent, oversees DSARs
• PII Processor Designate: Follows controller instructions, manages sub-processors
• Risk Assessment Owners: Identifies threats, selects controls
• DPIA Coordinators: Conducts impact assessments for high-risk processing
• Incident Response Leads: Investigates breaches, manages notifications
• Training Managers: Designs education programs, verifies competence

Risk Assessment & Treatment

Privacy risk assessment addresses both organizational risks and impacts on individuals:

Risk Identification: Catalog all PII processing activities. Identify threats: unauthorized access, processing errors, unlawful disclosure, accidental loss, excessive retention.

Risk Analysis: Evaluate likelihood (5-point scale) and impact on organization and individuals. Special data categories (health, racial origin, religious beliefs) carry higher individual impact.

Risk Treatment: Select controls from Annex A for high-priority risks. Document rationale linking risks to controls. Assess residual risk and document formal acceptance.

Documentation Requirements

Mandatory documents include:

• PIMS scope with organizational context
• Privacy policy accessible to stakeholders
• Record of Processing Activities (RoPA) with Article 30 fields
• Risk assessment and treatment plans
• Data Protection Impact Assessments
• Policies and procedures (DSAR, consent, breach, retention)
• Data Processing Agreements with processors
• Training records with competence verification
• DSAR logs demonstrating systematic handling
• Incident response documentation
• Internal audit reports
• Management review minutes

Data Subject Rights (DSARs)

ISO 27701 requires operational procedures for seven request categories:

Access: Authenticate requester, locate all data holdings, compile and deliver within timeline (typically 30 days).

Rectification: Verify inaccuracy, correct across all systems, notify third parties.

Erasure: Assess legal retention requirements, schedule deletion across all systems including backups, verify irreversibility, require vendor certification.

Portability: Export data in machine-readable format, deliver to requester or designated recipient.

Objection: Cease processing where objection grounds are valid, document decision, implement alternative lawful basis.

Restriction: Mark data as restricted, prohibit certain processing activities, document duration and reason.

Notification: Notify third-party recipients of corrections or erasures unless disproportionately difficult.

Common failures: treating DSARs as legal function without operational integration, inability to locate all data copies, lack of systematic timeline tracking, no identity verification evidence.

Controller vs Processor Responsibilities

Controllers determine processing purposes and means. Key obligations: document lawful basis (GDPR Article 6), obtain informed consent with logs, provide transparent privacy notices, conduct DPIAs for high-risk processing, establish all seven data subject rights procedures, implement international transfer safeguards, notify authorities of breaches within 72 hours, audit processor contracts.

Processors handle data per controller instructions. Key obligations: execute Data Processing Agreements, process only per documented instructions, bind personnel to confidentiality, notify controllers of breaches immediately, assist with data subject rights, obtain controller approval before engaging sub-processors, assist with transfer safeguards, delete or return data upon contract termination.

Many organizations act as both controller and processor for different activities, requiring explicit documentation of roles per processing activity.

Mapping ISO 27701 to GDPR

ISO 27701 supports GDPR compliance but doesn't guarantee it. Understanding alignment and gaps is critical.

Where ISO 27701 Supports GDPR

Critical Coverage Gaps

Qualitative Standards: GDPR requires "appropriate measures" based on context. ISO 27701 provides objective audit criteria. Organizations can pass ISO audits while failing GDPR's appropriateness standard through weak implementation or inconsistent enforcement.

Jurisdiction-Specific Requirements: ISO 27701 doesn't address sector-specific rules (HIPAA, GLBA), country-specific obligations (UK GDPR Schedule 1), or emerging regulations (AI Act, Digital Markets Act).

Consent Validity: ISO audits verify consent documentation exists but may not assess whether consent is truly "freely given," sufficiently "specific," or fairly designed without manipulation.

Legitimate Interest Assessments: ISO requires documenting lawful basis but provides no control for conducting legitimate interest assessments or balancing tests.

Breach Assessment: ISO requires incident procedures but not necessarily the legal threshold assessment or documented notification decision rationale.

Organizations pursuing dual compliance should supplement ISO 27701 with jurisdiction-specific legal reviews, continuous regulatory guidance monitoring, and regular gap analysis.

ISO 27701 Certification Process

Prerequisites

Before engaging a certification body:

• Define PIMS scope comprehensively
• Implement representative controls aligned with risks
• Establish DSAR procedures and test with samples
• Execute Data Processing Agreements with processors
• Conduct internal audit and document findings
• Complete management review with senior leadership
• Prepare organized documentation inventory

Audit Stages

Stage 1: Design Review (1-2 weeks) Auditors verify PIMS design and documentation compliance with clauses 4-10. Review scope, roles, risk methodology, control selection, and mandatory documents. Output: Report with findings and proceed/remediate recommendation.

Common Stage 1 findings: Unclear scope, undocumented risk methodology, generic privacy policy, future-state control claims.

Stage 2: Operational Testing (2-3 weeks) Auditors verify controls operate effectively through site visits, log reviews, staff interviews, and control testing. Output: Certification decision (Certify, Conditional, or Non-Conform).

Common Stage 2 findings: Staff lack practical knowledge despite training, DSAR procedures not systematically tracked, vendor DPAs without monitoring evidence, deletion procedures lacking backup logs.

Timeline: 6-12 months total from preparation to certification.

Costs:

• Startup (10-50 employees): €10,000-€25,000 (3-year cycle)
• Mid-Market (50-500): €20,000-€60,000
• Enterprise (500+): €50,000-€150,000+

Components include audit fees, internal preparation, surveillance audits, software platforms, training, and documentation management. Automation tools reduce costs 30-50%.

Implementation Steps

Step 1: Create Privacy Governance Structure

Appoint Privacy Policy Owner at senior management. Designate DPO if required. Assign controller/processor designates, risk owners, DPIA coordinators, incident leads, and training managers. Name specific individuals with documented responsibilities and escalation paths.

Step 2: Define Processing Activities

Conduct data discovery identifying all PII flows. Document data categories, purposes, legal basis, retention periods, recipients, locations, and responsible parties. Create Record of Processing Activities (RoPA) meeting Article 30 requirements. List all processors with executed DPAs.

Step 3: Establish Controls

Conduct privacy risk assessment per activity. Identify threats, analyze likelihood and impact. Select Annex A controls for high-priority risks. Document rationale linking risks to controls. Implement preventive controls: access management, encryption, backups, logging, data minimization.

Step 4: Operationalize DSAR & Consent

Develop procedures for all seven data subject rights. Create DSAR tracking system capturing request receipt, identity verification, data compilation, response delivery, exemptions. Document deletion procedures covering all systems including backups. Implement consent lifecycle automation capturing timestamps, enabling withdrawal.

Step 5: Deploy Monitoring

Define KPIs: DSAR response time, incident resolution, consent coverage, training completion. Launch privacy training for all staff with role-specific modules. Conduct internal audit testing controls and interviewing staff. Remediate findings. Schedule management review assessing effectiveness and approving decisions.9

Or: Automate the whole process with our Privacy Governance Platform!

Tools Supporting ISO 27701 Compliance

Privacy Governance Platforms

Sprinto: Automates 99% of compliance tasks. Pre-built ISO 27701 controls library. Integrates with 250+ systems for auto-evidence collection. Best for mid-market to enterprise.

ISMS.online: Pre-built policies, controls, risk bank. Supports 100+ standards for unified compliance. Best for multi-framework organizations.

Drata: Comprehensive evidence automation. Pre-mapped GDPR controls. Auditor portal for direct evidence sharing. Best for streamlined certification.

Consent Management Platforms

Automate consent collection, preference synchronization via API, audit logging with timestamps, multi-jurisdiction support. Satisfy ISO 27701 A.1.2.3 requirements.

DSAR Management Tools

Request intake forms, automated verification, system integration for data export, workflow automation, audit logging. Reduce response time 60-80%.

Data Mapping Tools

Scan networks/databases for sensitive data, automatic PII classification, data lineage visualization. Enable accurate RoPA and support DPIAs.

Common Implementation Mistakes

Over-Documentation Without Integration: Creating comprehensive policies without operational integration. Staff don't know procedures. Auditors identify gap between documented policy and practice.

Poorly Defined Scope: PIMS scope identical to ISMS without privacy-specific boundaries. Solution: Define scope around PII processing activities specifically.

Inadequate Risk Assessment: Focusing only on organizational impact, ignoring individual privacy impact. Solution: Assess both dimensions, especially for special data categories.

No Control Ownership: Controls documented but no named individuals accountable. Solution: Assign each control to specific person with documented authority.

DSAR Not Integrated: Procedures exist but processes are manual and slow. Solution: Map all systems, automate extraction, test with samples, measure response times.

Deletion Missing Backups: Deleting production data but overlooking backups and archives. Solution: Map all storage locations, implement logging across all systems, require processor certification.

Training Without Verification: 100% attendance but staff can't articulate procedures. Solution: Include assessments requiring passing scores, conduct interviews, design role-specific training.

ISO 27701 FAQs

Is ISO 27701 mandatory for GDPR compliance?

No. ISO 27701 is a voluntary international standard providing systematic approach to privacy management. GDPR is law requiring compliance regardless of ISO certification. However, ISO 27701 provides strong operational framework for meeting many GDPR requirements. Organizations with certified PIMS demonstrate systematic compliance rather than ad-hoc practices, potentially reducing regulatory scrutiny.

How long does ISO 27701 certification take?

Total time from pre-audit preparation to certification typically ranges 6-12 months. Timeline includes pre-audit preparation (2-4 months for PIMS design, control implementation, internal audit), auditor selection and kickoff (2-4 weeks), Stage 1 audit (1-2 weeks), Stage 1 remediation (2-8 weeks depending on findings severity), Stage 2 audit (2-3 weeks), and certification decision (1-2 weeks).

Well-prepared organizations with existing privacy programs may complete in 3-4 months. Organizations starting from zero may require 12+ months.

Do small companies benefit from ISO 27701?

Yes, particularly small companies serving enterprise customers or operating in regulated industries. Benefits include procurement advantage (enterprise customers increasingly require privacy certification), systematic approach replacing ad-hoc practices, reduced regulatory risk through documented compliance, and operational efficiency from standardized workflows.

Small companies should prioritize automation tools reducing manual effort and consider phased implementation focusing on highest-risk processing activities first.

Does ISO 27701 replace privacy laws like GDPR?

No. ISO 27701 is a management system standard, not law. It provides operational framework for implementing privacy principles but doesn't replace legal obligations. Organizations must comply with applicable privacy laws (GDPR, CCPA, LGPD) regardless of ISO certification.

ISO 27701 supports legal compliance by operationalizing requirements into auditable controls, but certification doesn't guarantee full legal compliance. Organizations should supplement ISO 27701 with jurisdiction-specific legal reviews and continuous monitoring of regulatory guidance.

Can organizations certify to ISO 27701 without ISO 27001?

Yes, as of the 2025 edition. ISO 27701 transformed from ISO 27001 extension into a standalone management system. Organizations can pursue privacy certification independently without prior ISO 27001 certification.

However, information security foundations remain essential. ISO 27701 Annex A.3 includes 29 information security controls. Organizations without existing security programs must implement these controls as part of PIMS, effectively building security capability alongside privacy governance.

What's the difference between PII controller and processor under ISO 27701?

Controllers determine the purposes and means of personal data processing, bearing primary legal accountability. Processors handle data on behalf of controllers following explicit instructions.

ISO 27701 assigns different controls to each role. Controllers must determine lawful basis, obtain consent, conduct DPIAs, manage data subject rights requests, and oversee international transfers (Annex A.1 controls). Processors must follow controller instructions exclusively, assist with data subject rights, manage sub-processors, notify controllers of breaches, and delete or return data upon contract termination (Annex A.2 controls).

Many organizations act as both controller and processor for different activities, requiring careful documentation of roles per processing activity.

Ready to operationalize your privacy governance program?

ISO 27701 provides the systematic framework privacy teams need to move from reactive compliance to proactive management. Organizations implementing PIMS report faster incident response, streamlined data subject request handling, improved customer trust, and reduced regulatory risk.

Success requires more than documentation — it demands operational discipline, clear role ownership, automated evidence collection, and continuous improvement. Organizations treating privacy as strategic capability rather than compliance checkbox build sustainable competitive advantage.

Download our ISO 27701 implementation checklist to get started with practical steps, control mapping templates, and audit preparation guidance tailored to your organization's size and industry.

Book a demo to see how Secure Privacy automates ISO 27701 compliance through integrated consent management, DSAR portals, records of processing, cookie scanning, and GDPR-aligned workflows — reducing manual effort by up to 70% while maintaining comprehensive audit trails.