ISO/IEC 27701: Building a Privacy Information Management System That Satisfies GDPR and Beyond
ISO/IEC 27701:2019 is the international standard for Privacy Information Management Systems (PIMS). It extends ISO/IEC 27001 and ISO/IEC 27002 with additional requirements and guidance specifically for privacy — making it the first certifiable international standard for privacy management and the most credible framework for demonstrating GDPR accountability.
What Is ISO 27701 and Why Does It Matter
ISO 27701 extends the ISMS requirements of ISO 27001 with privacy-specific controls drawn from globally recognised privacy principles. It covers requirements for both PII Controllers (organisations that determine the purposes and means of processing personal data) and PII Processors (organisations that process data on behalf of controllers).
Key reasons ISO 27701 matters:
- It provides a certifiable framework for demonstrating GDPR Article 5 accountability principle compliance
- It maps directly to GDPR, CCPA, NDPR, and other major privacy regulations
- It creates a common language for privacy obligations across the entire supply chain
- It allows organisations to demonstrate privacy commitment to regulators, customers, and partners through an internationally recognised certificate
- For data processors, it provides the most credible response to the GDPR requirement for processors to provide "sufficient guarantees" about their data protection practices
ISO 27701 Structure: What It Adds to ISO 27001
ISO 27701 adds four sections to the ISO 27001 framework:
Clause 5 — PIMS-specific requirements for ISO 27001: Additional requirements for the privacy-extended ISMS, including understanding the organisation's privacy role (controller or processor), privacy-specific risk assessment considerations, and privacy objectives.
Clause 6 — PIMS-specific guidance for ISO 27002: Privacy guidance for each of the ISO 27002 control categories, extending the information security controls with privacy considerations.
Clause 7 — Additional ISO 27002 guidance for PII controllers: Controls specific to organisations acting as PII controllers, covering consent management, privacy notices, data subject rights, data transfers, and privacy by design.
Clause 8 — Additional ISO 27002 guidance for PII processors: Controls for processors covering agreements with controllers, purposes and means limitations, sub-processor management, and processing records.
The Privacy Controls at the Heart of ISO 27701
ISO 27701 introduces privacy-specific controls across key domains:
Consent and transparency: Implementing mechanisms for obtaining, recording, and respecting consent. Providing clear, accessible privacy notices that meet regulatory requirements. Managing changes to purposes and providing updated notices.
Data subject rights: Establishing operational processes for handling access requests, erasure requests, objection and restriction of processing, and data portability — within regulatory timeframes and with documented responses.
Data minimisation and purpose limitation: Controls ensuring that only data necessary for the specified purpose is collected, that data is not used for incompatible purposes, and that retention schedules enforce deletion when data is no longer needed.
Privacy by design: Integrating privacy requirements into system design and development processes, conducting Privacy Impact Assessments for high-risk processing activities, and building data protection into products and services from inception.
Third-party and supply chain privacy: Implementing controls over sub-processors, verifying that suppliers maintain adequate privacy protections, and documenting contractual privacy requirements throughout the supply chain.
ISO 27701 and GDPR: The Accountability Bridge
GDPR Article 5(2) requires data controllers to be able to demonstrate compliance with the data protection principles — the accountability principle. ISO 27701 is the most credible mechanism for satisfying this requirement because:
The standard maps directly to GDPR requirements across all six lawful bases for processing, all eight data subject rights, GDPR Articles 25 (data protection by design and default), 28 (processor requirements), 30 (records of processing activities), 32 (security of processing), and 35 (data protection impact assessments).
An ISO 27701 certificate provides evidence to supervisory authorities that the organisation has implemented a systematic, audited privacy management system — far stronger evidence of accountability than a privacy policy alone.
When combined with ISO 27001 certification, ISO 27701 creates a comprehensive, certified framework for both information security and privacy that satisfies the demands of the most rigorous enterprise and regulatory audiences.
The ISO 27701 Certification Path
Prerequisite: ISO 27701 cannot be certified independently — it extends ISO 27001. Organisations must either already hold ISO 27001 certification or pursue both certifications together.
Gap Assessment: A privacy-specific gap assessment identifying where current privacy practices fall short of ISO 27701 requirements for both controller and processor roles.
PIMS Implementation: Building the privacy management system — privacy policy, records of processing activities (ROPA), consent mechanisms, data subject rights procedures, privacy impact assessment process, sub-processor management, and privacy training.
Integration with ISMS: Extending the existing ISO 27001 ISMS to incorporate privacy risks, privacy controls, and privacy-specific management review agenda items.
Certification Audit: ISO 27701 is audited concurrently with or after ISO 27001. The certification body assesses the PIMS using the same Stage 1 / Stage 2 process as ISO 27001.
Ongoing Surveillance: Annual surveillance audits and three-year recertification cover both the ISMS and PIMS together.
Why Organisations Choose Savadub
Deep GRC Expertise
Our team holds practitioner-level expertise across every major compliance framework — not just theoretical knowledge, but hands-on implementation experience across multiple industries and organisation sizes.
Engineers, Not Just Consultants
We implement controls, not just recommend them. Our GRC engineers configure the systems, write the integrations, and build the monitoring pipelines that make compliance operational.
Global and African Regulatory Coverage
We understand both the global frameworks and the African regulatory environment — NDPR, NDPA, CBN directives, NITDA guidelines, and regional data protection laws — making us uniquely positioned for organisations operating across Africa and internationally.
Internal and External Audit Capability
We provide both embedded internal audit functions and independent third-party audit support, including CPA-accredited audit coordination for SOC examinations.
End-to-End Engagement
From initial gap assessment through certification, continuous monitoring, and ongoing compliance management — we are your long-term GRC partner, not a one-time consultant.
Industries We Serve
Financial Services · Healthcare · Technology & SaaS · Manufacturing · Logistics & Trade · Government & Public Sector · Energy & Critical Infrastructure · Education & EdTech · Media & Broadcasting · Retail & E-Commerce · Professional Services · Food & Beverage
Deliverables You Receive
Working with Savadub, every engagement delivers a concrete set of outputs:
- Gap Assessment Report — prioritised findings with effort estimates and risk ratings
- Compliance Roadmap — milestone-based plan from current state to certification or attestation
- Risk Register — organisational risk register with treatment plans
- Policy Pack — all required policies authored, reviewed, and approved
- Technical Control Implementation Evidence — configurations, screenshots, and audit trails
- Internal Audit Report — independent assessment of control effectiveness
- Audit Evidence Repository — organised, auditor-ready evidence collection
- Executive Summary Presentation — board and leadership-ready compliance status
- Remediation Tracker — structured tracking of open findings and closure evidence
- Continuous Monitoring Setup — ongoing CCM pipeline for post-certification compliance
Get Started with Savadub
Savadub's GRC practice combines deep compliance expertise with technical engineering capability. We don't just advise — we build, implement, and operate your compliance program from the ground up.
Book a free GRC consultation with our team. We will review your current posture, identify your most critical gaps, and give you a clear, costed roadmap to compliance.
Contact us:
- Email: grc@savadub.com
- Phone: +234 816 734 2201
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