October 20, 2025

Practical Guide to ISO 27018

Written by
Rebecca Williams
GRC Consultant

As organizations move sensitive workloads to the cloud, protecting personal data has become more complex (and more critical). ISO 27018 is the international privacy standard designed specifically for public cloud environments.

It helps both cloud service providers (CSPs) and enterprise customers demonstrate that personally identifiable information (PII) is processed safely, transparently, and lawfully.

What is ISO 27018?

ISO/IEC 27018:2019 is a code of practice that establishes controls for protecting personal data (PII) in public clouds acting as PII processors. It builds on the ISO 27002 security control framework, adding privacy-specific guidance for the cloud context.

ISO 27018 defines principles for:

Consent and Purpose Limitation: PII is used only for agreed purposes.

Transparency: Users know what data is collected and why.

Data Subject Rights: Mechanisms exist for access, correction, and deletion.

Security Safeguards: Encryption, segregation, and access controls for PII.

Accountability: CSPs provide clear evidence of compliance to customers.

In short: ISO 27018 bridges the gap between cloud security and privacy obligations, helping organizations prove they treat customer data responsibly.

Privacy protections for Cloud Services

ISO 27018 addresses a core challenge of cloud computing: delegated processing.

When a business outsources its data to a cloud provider, it still retains legal responsibility for that data under regulations like the GDPR, HIPAA, or CCPA. ISO 27018 helps close the accountability gap by requiring CSPs to implement strong privacy controls that mirror regulatory expectations. The standard strengthens trust through:

  • Contractual clarity on PII ownership and processing limits.
  • Explicit restrictions on marketing or profiling using customer data.
  • Mandatory breach notification procedures.
  • Clear data deletion and return processes at contract end.
  • Customer visibility into sub-processor use and location of data storage.

Together, these requirements enable enterprises to show auditors and clients that their cloud vendors operate under robust, auditable privacy controls.

Key requirements

Requirement Area
Purpose
Implementation Example
Lawful Processing & Consent
Use PII only for explicit, documented purposes.
Contractual purpose clauses; consent tracking and logs.
Data Subject Rights
Enable access, correction, deletion, and export.
Self-service DSAR portal/API with SLAs and audit trails.
Transparency & Disclosure
Make processing locations and sub-processors visible.
Published processing register; data-location reporting.
Security & Encryption
Protect PII in transit and at rest; access control.
Per-tenant keys; TLS 1.3; least-privilege IAM; key rotation.
Retention & Deletion
Remove PII when no longer needed or at contract end.
Automated deletion workflows; verified erasure certificates.
Incident Response & Breach Notice
Detect, contain, and promptly notify controllers.
24-hour notification playbooks; forensic logging for PII events.
Sub-processor Management
Extend privacy controls across the vendor chain.
DPA flow-down clauses; due diligence; continuous monitoring.

ISO 27018 vs ISO 27701

Many cloud providers pursue ISO 27018 + ISO 27701 to cover both processor and controller obligations; a strong signal of trust to customers and regulators.

Dimension
ISO 27018
ISO 27701
Focus
Privacy controls for public cloud PII processors.
Organisation-wide PIMS for controllers and processors.
Applies To
Cloud providers processing customer PII.
Any org handling PII (on-prem or cloud).
Base Standard
Extends ISO 27002 (security controls) for privacy in cloud.
Extends ISO 27001/27002 to create a PIMS.
Certification
Usually audited as an annex with ISO 27001.
Standalone certification (PIMS) via accredited CBs.
Best Use
CSPs proving GDPR-style processor obligations.
Enterprises integrating privacy into governance at scale.

Steps to certification

  1. Confirm ISO 27001 foundation: ISO 27018 extends your existing ISMS.
  1. Identify PII data flows: Map where personal data is stored and processed.
  1. Perform a gap assessment: Compare current practices against 27018 controls.
  1. Implement privacy controls: Consent tracking, deletion workflows, data registers.

  2. Update contracts and SLAs: Reflect privacy commitments and responsibilities.
  1. Train and test: Educate staff on PII handling; run breach simulations.
  1. Internal audit and external review: Validate compliance and prepare for certification audit.

Complyance helps cloud-driven enterprises automate privacy audits, map ISO 27018 to ISO 27701 and GDPR, and maintain evidence in real time. Book a Demo to see how your team can simplify cloud privacy compliance.

ISO 27018 Implementation Checklist

0% complete • Open items: 6

Baseline with ISO 27001

Confirm ISMS scope; 27018 is an annex built on 27001/27002.

Map PII data flows

Identify locations, transfers, and sub-processors handling PII.

Processor obligations (Art. 28)

Align contracts/DPAs on purpose limits, transparency, and rights.

Implement privacy controls

Consent tracking, DSAR workflows, encryption, minimisation.

Manage sub-processors

Due diligence, flow-down clauses, and continuous monitoring.

Test & audit

Breach drills; internal audit; prepare for certification review.

FAQs

Is ISO 27018 mandatory for cloud providers? No, but it’s a globally recognized benchmark for privacy assurance and a competitive advantage in procurement and vendor reviews.

Can ISO 27018 be certified independently? It’s usually audited as an extension to ISO 27001, but some CBs offer stand-alone attestation.

How does ISO 27018 relate to GDPR? It provides a framework for GDPR Article 28 (Processor Obligations) and other privacy laws worldwide.

What’s the difference between ISO 27018 and CSA STAR? CSA STAR focuses on cloud security maturity; ISO 27018 focuses on data privacy controls within cloud environments.

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