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ISO/IEC 27701

Security techniques - Extension to ISO/IEC 27001 and ISO/IEC 27002 for privacy information management - Requirements and guidelines

Organization: ISO/IEC Category: Privacy Management
15
Related Articles
69
Articles with Obligations
5
Key Sections
10
Coverage Areas

Overview

Extends ISO 27001 and ISO 27002 with specific requirements and guidance for establishing, implementing, maintaining and continually improving a Privacy Information Management System (PIMS). Maps directly to GDPR requirements and provides a certifiable framework for privacy compliance.

Applicability

Privacy information management systems (PIMS) for GDPR compliance

Relevance to General Data Protection Regulation (GDPR)

Primary standard for GDPR compliance - direct mapping to GDPR articles and certifiable framework

Key Coverage Areas

1
Privacy Information Management System (PIMS)
2
PII controller obligations (GDPR Articles 5-11, 12-22, 24-43)
3
PII processor obligations (GDPR Article 28)
4
Data subject rights implementation
5
Privacy by design and by default
6
Data protection impact assessments (DPIAs)
7
Records of processing activities
8
Data breach notification
9
International data transfers
10
Consent management

Standard Sections & Chapters

5

PIMS-specific requirements (extends ISO 27001 clause 5)

6

PIMS-specific guidance for PII controllers

7

PIMS-specific guidance for PII processors

A.7

PII controller controls (mapping to GDPR)

A.8

PII processor controls (mapping to GDPR)

Related General Data Protection Regulation (GDPR) Articles

Article 5: Principles relating to processing of personal data

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Sections: 5, 6, A.7

PIMS implementation of GDPR principles

Implementation Guidance:

Implement ISO 27701 PIMS with all controller controls to address lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality

Mapped Obligations:

  • Process personal data lawfully, fairly and transparently
  • Limit data collection to what is necessary (data minimization)
  • Keep personal data accurate and up-to-date
  • Implement appropriate security measures to protect data
  • Document and demonstrate compliance with all principles (accountability)

Article 12: Transparent information, communication and modalities for the exercise of the rights of the data subject

View Article →
Sections: A.7.2, A.7.3

Transparent information and communication with data subjects

Implementation Guidance:

Establish procedures for providing information and exercising data subject rights

Mapped Obligations:

  • Respond to data subject requests within one month (extendable by 2 months for complex cases)
  • Facilitate the exercise of data subject rights under Articles 15-22
  • Inform data subjects of reasons and appeal options if refusing to act on requests

Article 15: Right of access by the data subject

View Article →
Sections: A.7.3.1, A.7.3.2

Right of access by data subject

Implementation Guidance:

Implement process for data subjects to obtain confirmation of processing and access to personal data

Mapped Obligations:

  • Confirm whether personal data is being processed when requested
  • Provide access to the personal data being processed
  • Inform about data subject rights (rectification, erasure, restriction, objection)

Article 17: Right to erasure (‘right to be forgotten’)

View Article →
Sections: A.7.3.4

Right to erasure ("right to be forgotten")

Implementation Guidance:

Establish procedures for erasure requests including verification and deletion timelines

Mapped Obligations:

  • Delete personal data without undue delay when requested by the data subject
  • Delete data immediately when consent is withdrawn and no other legal basis exists

Article 24: Responsibility of the controller

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Sections: 5, 6

Controller accountability and PIMS implementation

Implementation Guidance:

Establish and maintain PIMS demonstrating appropriate technical and organizational measures

Article 25: Data protection by design and by default

View Article →
Sections: 6.2, A.7.2.2

Privacy by design and by default controls

Implementation Guidance:

Integrate privacy into system design and configure default settings for privacy protection

Mapped Obligations:

  • Build in data protection principles like data minimization from the start
  • Use techniques like pseudonymization to protect personal data
  • Restrict access to personal data - not accessible to unlimited people without user intervention

Article 28: Processor

View Article →
Sections: 7, A.8

PII processor obligations and controls

Implementation Guidance:

Processors must implement ISO 27701 processor controls and maintain appropriate records

Mapped Obligations:

  • Controllers must only use processors with sufficient guarantees for GDPR compliance
  • Processors need written authorization before engaging sub-processors
  • Processors must only process data on documented instructions from the controller
  • Processors must ensure confidentiality of personnel handling personal data
  • Processors must implement security measures per Article 32
  • Processors must assist controllers with data subject rights requests
  • Processors must delete or return all data after services end
  • Processors must allow and contribute to compliance audits
  • Sub-processors must be bound by the same data protection obligations

Article 30: Records of processing activities

View Article →
Sections: 6.3, A.7.2.1, A.8.2.1

Records of processing activities (ROPA)

Implementation Guidance:

Maintain comprehensive records of all processing activities as required by GDPR

Mapped Obligations:

  • Controllers must maintain records containing: organization details, processing purposes, data subject categories, recipient categories, international transfers, retention periods, and security measures
  • Processors must maintain records containing: processor/controller details, processing categories per controller, international transfers, and security measures

Article 32: Security of processing

View Article →
Sections: A.7.2.8, A.8.3.1

PII-specific security controls

Implementation Guidance:

Apply security controls specific to personal data processing

Mapped Obligations:

  • Implement technical and organizational security measures appropriate to the risk
  • Consider pseudonymization and encryption of personal data
  • Ensure ongoing confidentiality, integrity, availability and resilience of systems
  • Regularly test and evaluate security measures effectiveness
  • Ensure staff only process data on controller's instructions

Article 33: Notification of a personal data breach to the supervisory authority

View Article →
Sections: A.7.2.9, A.8.3.2

Breach notification to authority procedures

Implementation Guidance:

Establish 72-hour breach notification process to supervisory authorities

Mapped Obligations:

  • Controllers must notify supervisory authority within 72 hours of breach awareness
  • Processors must notify controllers without undue delay
  • Include breach nature, affected data subjects, contact details, consequences, and mitigation measures
  • Maintain documentation for supervisory authority verification

Article 34: Communication of a personal data breach to the data subject

View Article →
Sections: A.7.2.10

Breach notification to data subjects

Implementation Guidance:

Establish procedures for timely communication to affected individuals when high risk exists

Mapped Obligations:

  • Use clear and plain language in breach notifications

Article 35: Data protection impact assessment

View Article →
Sections: 6.4

DPIA integration in PIMS

Implementation Guidance:

Integrate DPIA process into privacy information management system

Mapped Obligations:

  • Conduct a Data Protection Impact Assessment (DPIA) before high-risk processing activities
  • Perform DPIA for automated decision-making, large-scale processing of sensitive data, or systematic monitoring of public areas
  • Follow supervisory authority lists of processing requiring or not requiring DPIAs
  • Seek views of data subjects or their representatives where appropriate
  • Review and update the DPIA when risks change

Article 37: Designation of the data protection officer

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Sections: 5.2.1

DPO designation and responsibilities

Implementation Guidance:

Designate DPO with appropriate expertise and independence

Mapped Obligations:

  • Designate a DPO if your core activities involve regular and systematic monitoring of data subjects on a large scale
  • Communicate DPO contact details to the supervisory authority

Article 44: General principle for transfers

View Article →
Sections: A.7.5

International data transfer controls

Implementation Guidance:

Implement controls for international transfers including adequacy decisions, standard contractual clauses, and transfer impact assessments

Mapped Obligations:

  • Apply transfer rules to any onward transfers (when data moves from one third country to another)
  • Both controllers and processors must comply with transfer requirements

Article 83: General conditions for imposing administrative fines

View Article →
Sections: 5, 6, 7, A.7, A.8

Comprehensive PIMS to demonstrate compliance and avoid fines

Implementation Guidance:

Implement and maintain ISO 27701 PIMS to demonstrate proactive compliance efforts

Quick Information

Organization
ISO/IEC
Category
Privacy Management
Certification
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