What is ISO 27701?
- specifies the requirements for – and provides guidance for establishing, implementing, maintaining and continually improving – a PIMS (privacy information management system).
- is based on the requirements, control objectives and controls of ISO 27001, and includes a set of privacy-specific requirements, controls and control objectives.
Why was ISO 27701 developed?
to take measures to ensure the privacy of any personal data that they process.
How do ISO 27001 and ISO 27701 integrate with each other?
ISO 27001 sets out the requirements for an ISMS (information security management system), a risk-based approach that encompasses people, processes and technology. Independently accredited certification to ISO 27001 provides stakeholders with assurance that data is being appropriately secured.
Organisations that have implemented ISO 27001 will be able to use ISO 27701 to extend their security efforts to cover privacy management – including their processing of personal data/PII (personally identifiable information) – which can help them demonstrate that reasonable measures have been taken to comply with data protection laws such as the GDPR.
Organisations without an ISMS can implement ISO 27001 and ISO 27701 together as a single implementation project.
Who should implement ISO 27701?
ISO 27701 has been designed to be used by all data controllers and data processors. Like ISO 27001, it advocates a risk-based approach so that each conforming organisation addresses the specific risks it faces, as well as the risks to personal data and privacy.
What’s the difference between a privacy information management system and a personal information management system?
Whereas ISO 27701 sets out the requirements for a privacy information management system, BS 10012 is the British standard for a personal information management system.
There is little material difference between the two terms – both are management systems designed to secure personal information – and for the sake of day-to-day activities you can assume the acronym ‘PIMS’ to refer to either. However, there are some notable differences between the two approaches, which are considered below.
GDPR |
ISO 27701 |
| Personal data | PII |
| Data controller | PII controller |
| Data processor | PII processor |
| Data subject | PII principal |
| Data protection by design | Privacy by design |
| Data protection by default | Privacy by default |
ISO 27701 control mappings
As well as providing privacy-specific requirements, controls and control objectives for controllers and processors, ISO 27701 includes annexes that map them to:
- ISO 29100 (Information technology – Security techniques – Privacy framework);
- ISO 29151 (Information technology – Security techniques – Code of practice for personally identifiable information protection); and
- ISO 27018 (Information technology – Security techniques – Code of practice for protection of personally identifiable information (PII) in public clouds acting as PII processors)..
It also contains an annex that maps its requirements and controls to the GDPR’s requirements, so ISO 27701 can be used as a GDPR compliance guide by data controllers and processors.
For instance, data controllers’ obligations for meeting data subjects’ rights under the GDPR are covered by ISO 27701’s controls covering obligations to PII principals.
Guidance is provided for implementing each control.
Demonstrate GDPR compliance with ISO 27701 and ISO 27001
Implementing ISO 27701 and ISO 27001 will enable you to meet the privacy and information security requirements of the GDPR and other data protection regimes, and demonstrate that you have management arrangements in place for “appropriate technical and organizational measures” to protect the personal data you process and uphold data subjects’ rights, in line with the Regulation’s accountability principle (Article 5(2)).
Article 42 of the GDPR discusses data protection certification mechanisms and data protection seals and marks. No such mechanisms yet exist. However, it is possible to achieve independently accredited certification to ISO 27001 – and by extension ISO 27701 if you implement its controls – which will demonstrate to stakeholders and regulators that your organisation is following international best practice when it comes to securing personal data/PII.
