February 2, 2026

ISO 27701 Privacy Guide

Written by
Rebecca Williams
GRC Consultant

Data privacy has become one of the core indicators of trust for a business, and one of the key differentiators. Customers, partners and regulators alike all expect that companies maintain secure systems, and that personal data is handled with care. ISO 27701’s purpose is to ensure that security. 

Building on ISO 27001, this standard extends information-security principles into privacy management, giving enterprises a structured way to demonstrate compliance with data-protection laws like the GDPR.

What is ISO 27701?

ISO 27701 is an international privacy framework that extends ISO 27001 (Information Security Management System) and ISO 27002 (security controls). It introduces a Privacy Information Management System (PIMS), a structured approach to managing personally identifiable information (PII).

The framework defines privacy responsibilities for two primary roles:

PII Controllers (Controllers): determine how and why personal data is processed.

PII Processors (Processors): process personal data on behalf of controllers.

By aligning security and privacy controls, ISO 27701 helps organizations manage both confidentiality and lawful data processing within one governance model.

Link to GDPR

ISO 27701 was developed in close alignment with the EU General Data Protection Regulation (GDPR). While it isn’t a legal substitute, it aligns with many of the same principles.

ISO 27701 ↔ GDPR Mapping

Lawfulness, Fairness, Transparency
Maintain RoPA, publish privacy notices, manage consent and withdrawal.

Evidence Examples

  • Records of Processing Activities (RoPA)
  • Consent logs and withdrawal records
  • Published privacy notices and change history
Purpose Limitation
Define and document specific processing purposes; review any changes.

Evidence Examples

  • Purpose statements in RoPA entries
  • Change-control records for new purposes
  • Data-flow diagrams showing lawful processing scope
Data Minimization
Collect only essential PII; design privacy-by-default forms and fields.

Evidence Examples

  • Field-level justification matrix
  • Form design approvals
  • Data reviews removing unnecessary attributes
Integrity & Confidentiality
Extend ISO 27001 security controls to PII—encryption, access, monitoring.

Evidence Examples

  • Access control reviews
  • Encryption settings and key management logs
  • Incident response documentation
Accountability
Assign privacy roles; perform management review and internal audit.

Evidence Examples

  • RACI charts defining controller / processor roles
  • Internal audit findings
  • Continuous improvement and KPI reports

Key privacy requirements

ISO 27701 adds privacy-specific obligations to the ISO 27001 control set, with core requirements including:

Data Processing Transparency: Maintain records of processing activities and share clear notices with data subjects.

Risk-Based Privacy Assessment: Conduct privacy impact assessments to identify and mitigate PII-related risks.

Data Subject Rights Management: Implement processes for access, correction, erasure, and portability requests.

Third-Party Governance: Extend privacy requirements to vendors and partners through contractual clauses.

Privacy by Design and Default: Integrate privacy considerations into product development and system architecture.

Ongoing Monitoring and Improvement: Track compliance metrics and update controls as laws and technologies evolve.

Steps to certification

Achieving ISO 27701 certification typically requires six phases:

ISO 27701 — Privacy Control Checklist

0% complete (0 of 12)

Core PIMS (extends ISO 27001)

Controller Responsibilities

Processor Responsibilities

Certification is valid for three years with annual surveillance audits required to ensure ongoing conformance. 

FAQs

Do we need ISO 27001 before ISO 27701? Yes. ISO 27701 extends ISO 27001 and requires an existing ISMS.

Does ISO 27701 ensure GDPR compliance? It doesn’t guarantee legal compliance, but it provides a verifiable structure for demonstrating alignment.

How long does implementation take? For organizations with ISO 27001 in place, 2 to 4 months is typical; new programs may take longer.

Can a processor be certified without a controller? Yes, processors can obtain certification independently for their own PIMS.

How does ISO 27701 compare to NIST Privacy Framework? NIST focuses on risk management; ISO 27701 provides a globally certifiable system for privacy governance.

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