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What is ISO 27701 (PIMS): Benefits, Primary Focus & Steps

What is ISO 27701 (PIMS): Benefits, Primary Focus & Steps

TL;DR

ISO/IEC 27701:2025 is a Privacy Information Management System (PIMS) standard for managing PII and privacy risk.
The 2025 version replaces ISO/IEC 27701:2019 and is now a standalone management system standard.
ISO 27001 is no longer a strict prerequisite, though ISO 27701 can still be integrated with an existing ISMS.
ISO 27701 supports GDPR and other privacy-law readiness, but certification does not automatically prove legal compliance.

Data privacy is now a board-level trust issue for organizations that collect, process, or store personal information. Customers, regulators, and enterprise buyers expect clear evidence that privacy risks are being managed, not just policy promises.

ISO/IEC 27701 helps organizations build that evidence through a Privacy Information Management System (PIMS). The standard gives organizations a structured way to define privacy roles, assess privacy risks, manage Personally Identifiable Information (PII), monitor controls, and maintain audit-ready records.

The 2025 revision changed the standard in an important way. ISO/IEC 27701:2025 is now an independent management system standard, rather than only an extension to ISO/IEC 27001 and ISO/IEC 27002. Organizations can still integrate it with ISO 27001, and many will, but ISO 27001 is no longer the only route into ISO 27701.

ISO 27701 also supports privacy obligations under laws such as GDPR, CCPA, LGPD, and POPIA by giving teams a practical system for managing consent, data subject rights, breach response, vendor oversight, and privacy evidence. It does not replace legal compliance work, but it helps make privacy compliance operational and auditable. 

What is ISO 27701 and how does it work?

ISO/IEC 27701:2025 is an international standard for establishing, implementing, maintaining, and continually improving a Privacy Information Management System (PIMS). A PIMS helps organizations manage privacy risks related to Personally Identifiable Information (PII), including how personal data is collected, used, stored, shared, retained, and deleted.

The earlier 2019 version of ISO 27701 was designed as an extension to ISO 27001 and ISO 27002. The 2025 version changes that structure. ISO 27701 can now be implemented as a standalone privacy management system standard, while still remaining compatible with ISO 27001 for organizations that want to manage security and privacy controls together.

In practice, ISO 27701 works by helping organizations:

  • define the scope of their privacy management system
  • assign privacy responsibilities across teams
  • identify whether they act as a PII controller, PII processor, or both
  • assess and treat privacy risks
  • document privacy policies, processes, and controls
  • manage data subject requests, consent, retention, and breach response
  • monitor performance and improve the PIMS over time

For companies already using ISO 27001, ISO 27701 can build on existing governance, risk assessment, internal audit, management review, and evidence collection processes. For companies without ISO 27001, the 2025 version makes ISO 27701 more accessible as a dedicated privacy management standard.

Dr. Andreas Wolf, Chair of the ISO/IEC technical committee behind the standard, mentioned in 2019:

“ISO/IEC 27701 defines processes and provides guidance for protecting PII on an ongoing, ever-evolving basis.”

What changed in ISO 27701:2025?

ISO/IEC 27701:2025 replaces ISO/IEC 27701:2019. The biggest change is that ISO 27701 is now a standalone Privacy Information Management System standard. The 2019 version depended on ISO 27001 and ISO 27002; the 2025 version can be implemented and audited independently.

Key changes include:

  • Standalone PIMS structure: Organizations can implement ISO 27701 without first certifying to ISO 27001.
  • Continued ISO 27001 compatibility: Companies with an existing ISMS can still integrate ISO 27701 with ISO 27001 to avoid duplicate governance, audit, and evidence processes.
  • Updated privacy management requirements: The revised standard gives privacy teams a clearer structure for managing PII, privacy risk, accountability, monitoring, and continual improvement.
  • Modernized implementation guidance: The 2025 version reflects newer privacy governance expectations and aligns better with current ISO management system structures.
  • Transition requirements for existing certificate holders: Organizations certified to ISO/IEC 27701:2019 should confirm transition timelines with their certification body.

This change matters because ISO 27701 is no longer only an add-on for organizations that already have ISO 27001. It can now serve as a dedicated privacy management system for organizations that need formal privacy governance, even if their immediate priority is not full information security certification.

Who needs ISO 27701 certification and why?

ISO 27701 is relevant for organizations that collect, process, store, or share PII. This includes companies that act as data controllers, data processors, or both.

The standard is especially useful for:

  • SaaS and cloud service providers handling customer data
  • healthcare, fintech, and regulated businesses processing sensitive information
  • companies operating across multiple privacy jurisdictions
  • organizations subject to GDPR, CCPA, LGPD, POPIA, or similar privacy laws
  • vendors that need to prove privacy maturity during enterprise sales or tenders
  • companies that already have ISO 27001 and want to extend their program into privacy management

ISO 27701 certification gives customers, auditors, and business partners evidence that privacy is managed through a formal system. It shows that privacy responsibilities, risk assessments, policies, controls, monitoring, and improvement activities are documented and auditable.

It is not a substitute for legal advice or regulator-specific compliance work. Instead, it gives organizations the management system needed to operate privacy controls consistently.

How ISO 27701 supports GDPR compliance

ISO 27701 helps organizations turn GDPR requirements into operational privacy controls. GDPR defines what organizations must do when they collect, process, store, or share personal data. ISO 27701 provides the management system structure for proving that those privacy practices are documented, assigned, monitored, and improved over time.

For organizations that handle EU personal data, ISO 27701 can support GDPR readiness in areas such as:

  • defining whether the organization acts as a data controller, data processor, or both
  • documenting lawful processing, consent, retention, and data minimization practices
  • managing data subject rights, including access, correction, deletion, portability, and consent withdrawal
  • running privacy risk assessments and DPIAs where required
  • maintaining breach response procedures and evidence for regulatory reporting timelines
  • reviewing vendors, sub-processors, and Data Processing Agreements
  • keeping audit trails for privacy policies, controls, training, reviews, and corrective actions

ISO 27701 certification does not automatically make an organization GDPR compliant. GDPR is a legal regulation, while ISO 27701 is a certifiable privacy management standard. The value of ISO 27701 is that it gives privacy teams a structured, auditable way to demonstrate accountability and show how GDPR obligations are being managed in practice.

What are the key components of ISO 27701?

ISO 27701 provides a structured approach to privacy information management. Here’s a breakdown of its components:

1. Privacy Information Management System (PIMS)

This framework builds on ISO 27001 by adding a structured approach to managing personal data, bringing security and privacy controls together in one system.

2. Roles & responsibilities

Clear expectations are set for PII controllers and processors, outlining their legal, contractual, and operational duties when handling personal data.

3. Risk management & Privacy Impact Assessments (PIA)

Organizations need a structured process to identify, assess, and reduce privacy risks. This also ensures compliance with regulations like GDPR’s Data Protection Impact Assessment (DPIA).

4. Privacy controls

A mix of technical and organizational measures helps manage data collection, classification, encryption, access, retention, and secure disposal—reducing the risk of unauthorized access or misuse.

5. Data subject rights management

Well-defined processes make it easier to handle requests for data access, correction, deletion (right to be forgotten), portability, and consent withdrawal, with audit trails to track everything.

6. Continuous monitoring & improvement

Regular audits, automated monitoring, and compliance reviews help organizations find and fix gaps in their privacy practices before they become bigger issues.

7. Third-party & supply chain management

Data Processing Agreements (DPAs) and third-party audits ensure that vendors meet privacy requirements and stick to their contractual obligations.

8. Incident response & breach management

A structured response plan helps organizations detect, investigate, and respond to privacy breaches. This includes real-time anomaly detection, forensic analysis, and meeting regulatory reporting deadlines like GDPR’s 72-hour rule.

9. Employee training & awareness

Regular training, hands-on exercises, and assessments ensure employees understand their privacy responsibilities and can apply best practices in real-world situations.

Can the ISO 27701 standard help strengthen your information privacy management?

Yes, the ISO 27701 standards strengthen your information privacy management system. Here’s how it benefits you:

1. Defines clear privacy roles and responsibilities

ISO 27701 established who handles what in your organization. It holds respective people accountable for data collection, processing, assessing, erasure, etc. It also outlines the responsibilities of both data processors and controllers. 

2. Improves data privacy risk management

The standard contains guidelines for identifying the risks associated with handling PII and controls to mitigate breaches and non-compliance.

3. Covers the complete data privacy lifecycle

ISO 27701 governs private data from start to finish, optimizing the processes from collection to disposal. 

4. Governs continuous data monitoring

ISO 27701 requires you to conduct regular assessments and audits to ensure ongoing compliance with evolving privacy regulations and threats.

How to Get ISO 27701 Compliant

The process of becoming ISO 27701 compliant can go two ways: 

  1. You’re already ISO 27001 compliant. 
  2. Or, you’re starting from scratch.

Let’s cover the more straightforward scenario first.

Getting ISO 27701 when you’re already ISO 27001 compliant

Complying with ISO 27701 standards becomes fairly easy if you already have the ISO 27001 certification. 

ISO 27701 has 184 controls in total. It builds on ISO 27001 by introducing 135 modified controls that enhance existing security measures. In addition, it includes 49 new controls specifically designed to address the management and protection of PII. ISO 27701’s privacy-focused controls make it a dedicated privacy framework. For organizations navigating the EU-U.S. Data Privacy Framework specifically, our step-by-step guide covers self-certification, policy updates, and ongoing compliance.

So, here are the steps to comply with ISO 27701 while already having ISO 27001 certification:

1. Conduct an ISO 27701 gap analysis

A gap analysis maps your existing ISO 27001 controls against ISO 27701 requirements. Compliance management and GRC (Governance, risk, and compliance) tools usually provide automated gap analysis reports highlighting missing privacy controls. 

2. Implement all missing controls

After the gap analysis, you need to set up the controls that have yet to be implemented. You can use pre-built templates, workflows, policies, and other measures mapped to the remaining ISO 27701 control requirements in your compliance management software.

3. Conduct a readiness assessment

A readiness assessment ensures you’ve implemented ISO 27701 controls correctly and are prepared for the audit. Running it alongside an internal audit helps validate control effectiveness. A GRC tool enables real-time compliance tracking, flagging gaps and automating evidence collection to meet audit requirements.

For example, in Sprinto, you can skip a few steps and directly access the compliance health report to see if you have any more compliance requirements. 

4. Get an external auditor 

Once your system is aligned, export compliance reports directly from your platform and provide auditors with structured evidence. Many tools offer audit-ready documentation and access controls to streamline the review process.

Faster audits with a dedicated audit dashboard | See Sprinto in action

Once your auditor gives the go-ahead, you’ll receive the ISO 27701 certification soon. Otherwise, if there are non-conformities (major issues), you’ll go through another cycle of corrective actions and measures. 

Complying with ISO 27701 from scratch

If you’re not ISO 27001 certified, your ISO 27701 certification may take some time. For starters, you have to begin implementing all the requirements of ISO 27001 before moving on to the ISO 27701 controls.

Here’s a step-by-step approach to getting ISO 27701:

1. Establish your ISMS (Information Security Management System)

An ISMS helps organizations protect sensitive information and manage security risks systematically. It forms the baseline for ISO 27001.  

As a first step, you need to define the scope of your ISMS to determine what parts of your ISMS you want to protect—for example, business processes, locations, and data types. Next, you must conduct a risk assessment to identify and mitigate potential threats that could sabotage your information assets. 

2. Seek professional guidance: Consultants or Tools for ISO 27001 + ISO 27701

Consultants and tools can be included in the first step or after you’ve defined the scope of your ISMS. ISO 27001 consultants bring specialized expertise to your compliance journey. They can assist with risk assessments, policy development, and training.

On the other hand, there are GRC tools that help automate workflows, reduce manual workload, and make the compliance process more efficient and accurate. 

What should you choose: Consultants or GRC tools? 

Consultants provide personalized advice. However, the consultant route can be quite time-consuming and costly since they are mostly contract arrangements. 

GRC tools, such as Sprinto, integrate with your existing systems to map controls, automatically collect evidence, and monitor continuously. Sprinto also includes access to onboard ISO lead auditors within its pricing model, so you don’t have to worry about personalized guidance. 

3. Define ISO 27001 + ISO 27701 policies

Whether you choose to implement ISO 27001/27701 with a consultant or a tool, you need to define all policies regarding your applicable controls. 

When using an automation tool, you’ll find ready-to-use templates for the above policies that you can customize as per your business’s requirements. 

“Under ISO/IEC 27701, having internal privacy policy and privacy trainings as a commitment from the business and its staff members is a must-have,” Akshay added.

4. Integrate PIMS components as per ISO 27701

The controls specific to the Privacy Information Management System for ISO 27701 address the management and protection of Personally Identifiable Information (PII). Your systems should align with the requirements under relevant privacy laws, such as GDPR, CCPA, PIPEDA, etc. 

Another important aspect of ISO 27701 is documenting all procedures for collecting, processing, and storing PII. This step is necessary if you’re doing the compliance process for both frameworks hand-in-hand to save time and effort.

5. Conduct an ISO 27001 & ISO 27701 training program

Since you’re implementing two frameworks at once, cut your employees some slack and formalize the training program so that it’s easily accessible and understandable. All staff should understand their responsibilities for maintaining privacy and information security. 

Sprinto allows you to conduct a framework-specific training program on the platform itself. It’s as simple as your employees getting a training notification in their mail and completing the training modules on time. You will be notified in real time of your employees’ training status. 

6. Prepare for certification

Before you actually involve an external auditor, you need to run an internal audit of your ISO 27001 and ISO 27701 compliance process. The good news is that both audits can be conducted simultaneously. 

The internal audit checks your ISMS scope, the roles and responsibilities under ISMS, and the organizational context (such as stakeholders, internal and external issues, etc.). Note that all these also extend to your PIMS.

7. Engage an ISO-certified auditor

ISO-accredited bodies usually perform certification audits. They evaluate your ISMS and PIMS against ISO standards, including reviewing your documented policies, procedures, and controls against the Statements of Applicability.

Post-audit, if there are any identified non-conformities, you have to address them promptly to achieve or maintain certification. If there’s any major non-conformity, it requires your immediate corrective action and may delay certification until resolved.

“When preparing the Statement of Applicability (SoA) for internal and external audits, you can cover clauses from ISO 27001 and ISO 27701. Combining them into a single SoA document is often more efficient, given the overlap and derivation of many requirements.” – Akshay.

Map common controls & manage multiple compliances together

What is the cost of complying with ISO 27701?

As per ISMS online, complying with ISO 27701 can range from around $3,500 USD to $18,000 USD. However, it largely depends on the size of your organization and other factors such as the scope of your ISMS, the number of controls applicable, and your current security posture.  

For example, if you already comply with ISO 27001, your price will be reduced to around $2000-$5000, provided you work with GRC software like Sprinto. 

If you’re starting from scratch, you can opt to comply with ISO 27701 hand-in-hand with ISO 27001 to reduce some cost and effort, too. 

ISO 27701 vs. ISO 27001: What’s the difference?

ISO 27001 and ISO 27701 are related, but they solve different problems. ISO 27001 focuses on information security management. ISO 27701 focuses on privacy information management and the responsible handling of PII.

FactorsISO 27701ISO 27001
Primary focusPrivacy management and PII processingInformation security management
Management systemPrivacy Information Management System (PIMS)Information Security Management System (ISMS)
Current version contextISO/IEC 27701:2025 is a standalone management system standardISO/IEC 27001:2022 is a standalone ISMS standard
Certification dependencyNo longer strictly dependent on ISO 27001 under the 2025 versionCan be certified independently
Best fitOrganizations managing privacy obligations, PII risks, data subject rights, and privacy evidenceOrganizations managing confidentiality, integrity, availability, and security risk
RelationshipCan be implemented alone or integrated with ISO 27001Can provide a strong security foundation for ISO 27701

Many organizations still implement both standards together because privacy and security controls often overlap. For example, access control, incident response, supplier risk, internal audits, and management reviews can support both an ISMS and a PIMS. The difference is that ISO 27701 adds privacy-specific governance for PII and privacy obligations.

Overview of ISO/IEC 27701 controls

The current edition, ISO/IEC 27701:2025, was published on October 14, 2025, and fully replaces the 2019 version. The biggest shift: in the 2025 version, the PIMS stands alone, so organizations no longer need an ISMS or ISO 27001 certification to implement it, though it stays fully aligned with ISO/IEC 27001:2022 and ISO/IEC 27002:2022.

Its controls fall into three groups:

  • PII controller controls (Annex A): 31 controls for organizations that decide why and how personal data is processed. They cover the conditions for collecting and processing PII, obligations to data subjects (access, correction, erasure), privacy by design and by default, and the rules for sharing or transferring data.
  • PII processor controls (Annex B): 18 controls for organizations that process data on a controller’s behalf. The focus is processing only under documented instructions, supporting the controller’s obligations, and managing sub-processors and cross-border transfers.
  • Information security controls: 29 controls applicable to both roles, carried over and restructured to align with ISO/IEC 27002:2022.

Because the standard maps its controls to GDPR and other privacy regulations, implementing them gives you an auditable, certifiable way to demonstrate privacy compliance rather than just assert it.

Manage your ISO 27701 compliance with Sprinto

ISO 27701 asks a lot of you: dozens of controller and processor controls, continuous monitoring of every privacy control, current policies, and audit-ready evidence for all of it kept in sync with your underlying ISO 27001 and 27002:2022 controls. Doing that by hand, across a privacy program that never stops changing, is exactly where most teams fall behind.

Sprinto’s Autonomous Trust Platform is built to carry that load. Instead of flagging gaps and waiting for someone to act, it detects drift, collects evidence continuously, and keeps your privacy program current with minimal manual effort.

With Sprinto, you can:

  • Map your privacy controls once and reuse evidence across ISO 27701, ISO 27001, GDPR, and other frameworks, instead of running each in a silo
  • Automatically collect audit-ready evidence from your integrated systems
  • Manage policies, distribution, and acknowledgments from one place using pre-built templates
  • Monitor controls in real time and catch drift before it becomes an audit finding
  • Stay audit-ready year-round, not just before an assessment

Ready to make privacy compliance continuous instead of a scramble? Just schedule a Sprinto demo.

FAQ

What is the primary focus of ISO 27701?

ISO/IEC 27701’s primary focus is establishing, implementing, maintaining, and continually improving a Privacy Information Management System (PIMS). It extends ISO/IEC 27001 by incorporating privacy-specific requirements and guidance. It enables organizations to manage and protect Personally Identifiable Information (PII) effectively.

Can I get ISO 27701 certification without ISO 27001?

Under ISO/IEC 27701:2025, ISO 27701 is now a standalone Privacy Information Management System standard. ISO 27001 is no longer a strict prerequisite. However, organizations can still integrate ISO 27701 with ISO 27001 to manage privacy and information security across connected systems.

Does ISO 27701 require a formal audit?

Yes, obtaining ISO/IEC 27701 certification necessitates a formal audit conducted by an accredited certification body. This audit assesses the organization’s compliance with the standard’s requirements, ensuring the PIMS is effectively implemented and maintained.

Is ISO 27701 mandatory for complying with GDPR?

No. ISO 27701 is not mandatory for GDPR compliance. It can support GDPR readiness by giving organizations a structured, auditable way to manage privacy roles, data subject rights, risk assessments, breach response, vendor oversight, and evidence. Legal compliance still depends on how the organization interprets and applies GDPR requirements.

What changes in ISO 27701:2025?

ISO/IEC 27701:2025 replaces the 2019 version and makes ISO 27701 a standalone management system standard. The old version worked as an extension to ISO 27001 and ISO 27002. The revised version can be implemented independently, while still integrating well with ISO 27001 for organizations that already have an ISMS.

Do existing ISO 27701:2019 certificates need to transition?

Yes, organizations certified to ISO/IEC 27701:2019 should plan for transition to the 2025 version. The exact process and timing should be confirmed with the organization’s certification body.

Pansy
Author

Pansy

Pansy is an ISC2 Certified in Cybersecurity content marketer with a background in Computer Science engineering. Lately, she has been exploring the world of marketing through the lens of GRC (Governance, risk & compliance) with Sprinto. When she’s not working, she’s either deeply engrossed in political fiction or honing her culinary skills. You may also find her sunbathing on a beach or hiking through a dense forest.
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