ISO/IEC 27701:2019 Implementation Guide for Privacy Information Management
Comprehensive guidance for information security professionals implementing ISO/IEC 27701:2019 Privacy Information Management System (PIMS) extensions to existing ISO/IEC 27001 frameworks.
Understanding ISO/IEC 27701 Fundamentals
ISO/IEC 27701:2019 extends the well-established ISO/IEC 27001 and 27002 standards by incorporating comprehensive privacy principles specifically designed for Personally Identifiable Information (PII). This international standard provides a structured framework for organizations to systematically manage privacy risks through a Privacy Information Management System (PIMS).
The standard applies universally to organizations of all sizes and sectors, whether they operate as PII controllers (determining purposes of data processing) or PII processors (processing data on behalf of controllers), or both simultaneously.
Key Stakeholders in PIMS Implementation
Data Subjects
Individuals whose PII is being processed and who have specific rights regarding their data. Their expectations for privacy protection must be understood and addressed.
Organization
The entity implementing the PIMS, which must define its role as controller, processor, or both, and establish appropriate governance structures.
Regulators
Government bodies that enforce privacy laws and may conduct audits or investigations. Organizations must maintain compliance with their requirements.
Business Partners
Third parties with whom data is shared or who process data on behalf of the organization. These relationships require formal agreements defining privacy responsibilities.
Distinguishing Controller vs. Processor Roles
PII Controller
The entity that determines the purposes and means of processing personally identifiable information. Controllers bear primary responsibility for:
  • Establishing legal basis for processing
  • Providing notice to data subjects
  • Securing consent when required
  • Ensuring data subject rights are respected
  • Managing the entire data lifecycle
PII Processor
The entity that processes PII on behalf of and under the instructions of a controller. Processors must:
  • Process data only as instructed
  • Implement appropriate security measures
  • Assist controllers with data subject requests
  • Report breaches promptly to controllers
  • Return or delete data after processing completion
Integrating PIMS with Existing ISMS
Gap Analysis
Assess current ISO/IEC 27001 ISMS implementation against 27701 privacy requirements to identify areas needing enhancement.
Scope Definition
Define the precise scope of PIMS, identifying all processes, systems, and organizational units handling PII.
Policy Integration
Revise information security policies to incorporate privacy-specific considerations and controls.
Risk Assessment Expansion
Extend existing risk assessment methodologies to address privacy-specific threats and vulnerabilities.
Control Implementation
Deploy additional privacy controls as identified in clauses 5-8 of ISO/IEC 27701.
Context of the Organization (Clause 5.2)
Under ISO/IEC 27701, organizations must thoroughly analyze their operational context with specific focus on privacy dimensions. This requires identifying all internal and external factors that influence how PII is managed throughout its lifecycle.
Organizations must document stakeholder expectations regarding privacy, with particular attention to regulatory requirements, industry standards, contractual obligations, and data subject concerns. This analysis forms the foundation for determining the scope of the PIMS.
External Context Factors
Applicable privacy regulations (GDPR, CCPA, etc.), industry standards, technological landscape, and competitive pressures.
Internal Context Factors
Organizational structure, existing policies, technological capabilities, resource constraints, and organizational culture.
Leadership Commitment to PIMS (Clause 5.3)
Policy Alignment
Top management must ensure privacy policies align with organizational strategic direction and business objectives.
Role Assignment
Executive leadership must establish clear roles and responsibilities for privacy management, including consideration of a Data Protection Officer.
Resource Allocation
Adequate resources (human, technical, financial) must be committed to PIMS implementation and continuous improvement.
Culture Development
Leadership must promote a privacy-aware organizational culture through communication, incentives and leading by example.
Privacy Risk Assessment Process (Clause 5.4)
Privacy risk assessment extends beyond traditional information security risk methodologies to address privacy-specific concerns. Organizations must systematically identify and evaluate risks to PII principals (data subjects) that could result from their processing activities.
This process must consider both the likelihood and potential consequences of privacy breaches, unauthorized access, or non-compliance with regulatory requirements. Risk treatment decisions must be documented and justified, with clear traceability to specific controls.
Risk Identification
Catalog processing activities and associated privacy risks, considering collection, use, storage, sharing, and deletion phases.
Risk Analysis
Evaluate likelihood and impact of identified risks, including reputational damage, regulatory penalties, and harm to data subjects.
Risk Evaluation
Prioritize risks based on established criteria and determine which require treatment versus acceptance.
4
4
Risk Treatment
Implement controls to mitigate, transfer, avoid, or accept identified risks based on organizational risk appetite.
Measurable PIMS Objectives (Clause 5.4)
100%
Documentation Compliance
All PII processing activities must be completely documented in Records of Processing Activities (ROPA) by end of quarter.
<24h
Breach Response Time
Maximum time from breach detection to initial containment and notification to relevant stakeholders.
95%
Staff Training Completion
Percentage of employees who must complete privacy awareness training annually, with role-specific modules for key personnel.
<5d
DSR Response Time
Maximum days to respond to data subject access requests, ensuring compliance with regulatory timeframes.
Supporting Resources and Competence (Clause 5.5)
Required Resources
  • Qualified privacy personnel with relevant certifications (CIPP, CIPM)
  • Budget allocation for technical privacy controls
  • Tools for privacy impact assessments and data mapping
  • Automated systems for managing consent and preferences
  • Legal expertise for regulatory interpretation
Competence Development
  • Role-specific privacy training programs
  • Privacy certification paths for key personnel
  • Cross-functional privacy workshops
  • Regular knowledge sharing sessions
  • Participation in industry privacy forums
Privacy Awareness and Communication (Clause 5.5)
Internal Awareness
Organizations must develop comprehensive privacy awareness programs that communicate the importance of privacy protection, individual responsibilities, and consequences of non-compliance. Regular refresher training should address emerging threats and regulatory changes.
External Communication
Transparent privacy notices must clearly articulate what PII is collected, how it's used, with whom it's shared, and how long it's retained. Communication channels for data subjects to exercise their rights must be established and maintained.
Documented PIMS Information (Clause 5.5)
Privacy Policy
The foundational document outlining organizational commitment to privacy protection, including overall principles and accountability framework.
Records of Processing Activities
Comprehensive inventory of all processing activities, including purpose, categories of data, recipients, retention periods, and security measures.
Data Processing Agreements
Formal contracts defining privacy responsibilities between controllers and processors, including security requirements and breach notification procedures.
PIA and DPIA Reports
Documented privacy impact assessments and data protection impact assessments for high-risk processing activities.
Operational Procedures
Step-by-step instructions for privacy-related activities such as handling data subject requests, breach response, and consent management.
Operational Planning and Control (Clause 5.6)
The operational aspects of a PIMS require careful planning and systematic execution. Organizations must establish processes that ensure privacy is maintained throughout all stages of PII processing. This includes implementing technical and organizational measures that satisfy requirements identified during risk assessment.
Organizations must maintain documented evidence of operational control, including records of processing activities, completed impact assessments, and validation of privacy-enhancing technologies. These controls must be regularly tested to ensure continued effectiveness.
Operational Risk Monitoring
Continuous monitoring of privacy risks through automated tools and manual reviews to detect emerging threats or control weaknesses.
Change Management
Privacy impact assessments must be conducted before implementing significant changes to systems or processes handling PII.
Performance Evaluation Methods (Clause 5.7)
1
Continuous Monitoring
Daily and weekly automated checks of privacy controls, including access logs, consent records, and data transfer mechanisms.
2
Quarterly Reviews
Regular assessment of privacy metrics, incident reports, and completion of planned privacy enhancements against established objectives.
3
Internal Audits
Systematic evaluation of PIMS against ISO/IEC 27701 requirements, conducted by trained internal auditors semi-annually.
4
Management Review
Annual executive assessment of PIMS effectiveness, resource adequacy, and strategic alignment, resulting in documented improvement plans.
5
External Certification Audit
Independent third-party verification of PIMS compliance with ISO/IEC 27701 requirements every three years.
Privacy-Enhanced Security Controls (Clause 6)
This chart illustrates the relative complexity and privacy impact of key security control areas that must be enhanced for ISO/IEC 27701 compliance. While incident response has the highest privacy impact, supplier management presents the greatest implementation challenge due to the need for contractual modifications and ongoing monitoring of third parties.
Privacy Policy Framework (Clause 6.2)
Essential Privacy Policy Components
  • Clear identification of the organization as controller/processor
  • Categories of PII collected and processed
  • Specific purposes for each processing activity
  • Legal basis for each processing activity
  • Retention periods and deletion procedures
  • Third-party sharing arrangements and safeguards
  • Data subject rights and exercise mechanisms
  • Cross-border transfer mechanisms
Effective privacy policies must be regularly reviewed, approved by senior management, and communicated to all relevant stakeholders. They should be written in clear, accessible language while maintaining legal accuracy.
Privacy Roles and Responsibilities (Clause 6.3)
Data Protection Officer
Oversees privacy program, monitors compliance, provides expert advice, and serves as contact point for supervisory authorities. Must have independent position with direct reporting to highest management level.
Privacy Governance Committee
Cross-functional team responsible for privacy strategy, policy approval, and resource allocation. Typically includes representatives from legal, IT, security, HR, and business units.
Privacy Champions
Designated individuals within business units who promote privacy awareness, facilitate impact assessments, and act as first point of contact for privacy concerns within their teams.
Privacy Engineers
Technical specialists who implement privacy-enhancing technologies, conduct privacy design reviews, and ensure privacy requirements are translated into technical specifications.
Human Resource Security for Privacy (Clause 6.4)
Pre-Employment
  • Background checks for roles with PII access
  • Privacy responsibilities in job descriptions
  • Privacy awareness assessment during hiring
  • Confidentiality agreements before access grant
During Employment
  • Role-based privacy training programs
  • Annual privacy awareness refreshers
  • Privacy compliance in performance reviews
  • Disciplinary procedures for violations
Termination/Change
  • Immediate access revocation procedures
  • Return of all PII-containing assets
  • Extended confidentiality obligations
  • Knowledge transfer protocols
PII Asset Management (Clause 6.5)
1
2
3
4
5
1
Identify
Catalog all PII assets
2
Classify
Categorize by sensitivity level
3
Document
Record processing purposes and flows
4
Protect
Implement appropriate controls
5
Monitor
Track access, usage and transfers
Effective PII asset management requires a comprehensive inventory of all data assets containing personally identifiable information. Organizations must implement a data classification scheme that identifies sensitivity levels and handling requirements based on privacy risk. The Records of Processing Activities (ROPA) must be maintained as a living document, updated whenever processing activities change.
PII Access Control Implementation (Clause 6.6)
ISO/IEC 27701 requires enhanced access controls specifically for PII. Organizations must implement strict need-to-know and least privilege principles, ensuring access is limited to only what is necessary for legitimate job functions.
Access to PII must be accompanied by appropriate logging and monitoring to detect unauthorized access attempts or suspicious patterns. Regular access reviews must verify that permissions remain appropriate as roles change within the organization.
Technical Controls
Multi-factor authentication for PII access, role-based access control, and privileged access management for administrative functions.
Procedural Controls
Formal access request workflow with management approval, quarterly access certification, and immediate revocation processes.
Cryptographic Protections for PII (Clause 6.7)
Encryption in Transit
All PII transmitted across networks must use TLS 1.2+ with strong cipher suites. VPN connections must be required for remote access to systems containing PII. Email containing PII must be encrypted using organization-approved solutions.
Encryption at Rest
Databases containing PII must implement transparent data encryption. File systems with PII must be encrypted using AES-256. Portable devices must use full-disk encryption with secure boot mechanisms.
Key Management
Encryption keys must be managed using hardware security modules where possible. Key rotation schedules must be defined and enforced. Separate keys must be used for different data sets and environments.
Incident Management for Privacy Breaches (Clause 6.13)
1
Detection
Automated tools and manual processes to identify potential privacy breaches, with clear incident classification criteria to distinguish between security and privacy incidents.
2
Containment
Immediate actions to limit breach impact, including isolation of affected systems, temporary access restrictions, and preservation of evidence for forensic analysis.
3
Assessment
Evaluation of breach scope, affected data subjects, potential harm, and regulatory notification requirements using a documented risk assessment methodology.
4
Notification
Timely communication to authorities (within 72 hours for GDPR), affected individuals, and other stakeholders according to regulatory requirements and organizational policy.
5
Remediation
Implementation of corrective actions to address root causes, prevent recurrence, and restore normal operations with enhanced controls.
Controller-Specific Requirements (Clause 7)
Legal Basis Requirements
Controllers must establish and document a valid legal basis for all processing activities. This might include:
  • Explicit, specific consent with revocation mechanism
  • Necessary for contract performance
  • Compliance with legal obligations
  • Protection of vital interests
  • Public interest or official authority
  • Legitimate interests assessment and balancing test
Transparency Obligations
Controllers must provide clear information to data subjects regarding:
  • Identity and contact details of controller
  • Purposes and legal basis for processing
  • Data retention periods
  • Recipients or categories of recipients
  • International transfer mechanisms
  • Data subject rights and how to exercise them
  • Automated decision-making logic and consequences
Data Subject Rights Management (Clause 7.3)
Right of Access
Process for verifying identity and providing copy of personal data in machine-readable format, including processing purposes, categories, recipients, and retention periods.
Right to Rectification
Mechanism for correcting inaccurate personal data and completing incomplete data, with propagation of changes to all systems and third parties.
Right to Erasure
Procedure for secure deletion of data when requested, no longer needed, or unlawfully processed, with verification and documentation of deletion.
Right to Restriction
Technical controls to temporarily limit processing while verifying accuracy, assessing legitimate interests, or processing objections.
Processor-Specific Requirements (Clause 8)
Key Processor Obligations
ISO/IEC 27701 establishes specific requirements for organizations acting as PII processors. These include:
  • Processing PII only according to documented controller instructions
  • Implementing appropriate technical and organizational measures
  • Assisting controllers with data subject rights fulfillment
  • Supporting controllers in conducting impact assessments
  • Notifying controllers promptly of any PII breaches
  • Returning or securely deleting PII after service completion
  • Making available all information necessary to demonstrate compliance
  • Obtaining written authorization before engaging sub-processors
Processors must maintain detailed records of all processing activities carried out on behalf of controllers, including categories of processing, transfers to third countries, and general description of technical and organizational security measures.
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