Protect personal privacy information using a systematic approach

In the process of digital transformation, Personal privacy information protection Privacy has become a pressing issue for businesses. The lack of systematic privacy governance not only poses risks of data breaches and misuse, but also leads to compliance penalties, damage to brand trust, and uncertainty regarding cross-border data compliance. A structured approach is to establish a Privacy Information Management System (PIMS) based on ISO/IEC 27701 – which builds upon ISO/IEC 27001/27002 (Control P11/27002) and addresses the differentiated requirements for processors, helping to align with regulations such as GDPR and PIPL and seamlessly integrate with existing ISMSs.

Continuously improve privacy protection maturity, reduce the risk of violations and leaks, meet supervision and contract requirements, and enhance customer and ecosystem trust.

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What is ISO 27701?

ISO/IEC 27701 is built upon ISO/IEC 27001 and 27002. Privacy Information Management System (PIMS) international standard. It focuses on the identification, evaluation, and management of personally identifiable information (PII) processing. The associated risks elevate "compliance and trust" to a key strategic element for businesses, helping organizations align with privacy regulations such as GDPR and PIPL.

Information is ubiquitous and permeates every business process. Some information is general, but much more is sensitive and involves individuals. To make this distinction within an organization, one must first... Identify and classify PII Information is categorized based on its sensitivity, processing purpose, retention period, and sharing scope, and the organization's role in different scenarios is clearly defined. PII: Controller or Processor? In ISO/IEC 27701, the measures and processes of PIMS are designed and implemented based on this.

PIMS has established a management and control framework for protecting personal information: from Privacy policy and roles and responsibilities (e.g., DPO) , Data Flow Analysis and PIA/DPIA , Consent and Legal Basis , Response to data subject rights (access, correction, deletion, portability) , Minimize and retain/remove strategies ,arrive Third-party and cross-border transmission management , Incident Response and Notification as well as Audit and Continuous Improvement Within this framework, organizations not only focus on the confidentiality, integrity, and availability of information, but also emphasize Transparency and accountability .

At the certification level, ISO/IEC 27701 serves as an alternative to ISO/IEC 27001/27002. expansion Implementation is typically integrated with ISMS audits and verifications. Obtaining ISO 27701 certification sends a strong signal to the market and partners: your organization has passed... Independent external assessment Its privacy governance capabilities, entrusted processing capabilities, and compliance have been effectively confirmed.

As an extension of 27001/27002, ISO/IEC 27701 does not change the existing information security management requirements, but rather... Supplementing privacy-oriented terms and controls By embedding "Privacy by Design & by Default" into daily operations, organizations can continuously improve their privacy maturity and business trust.

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Who is ISO 27701 certification applicable to?

ISO/IEC 27701 (PIMS) is applicable to all types of organizations worldwide, providing a framework for planning, implementing, and monitoring the protection of personal information and privacy. The standard covers private, public, and non-profit organizations and is applicable to... Personal information controller and Processor As an extension of ISO/IEC 27001/27002, 27701 supplements ISMS with mechanisms for PII identification and classification, data minimization and retention/deletion, legality and consent management, data subject rights, third-party and cross-border governance, privacy incident response, auditing and continuous improvement, helping organizations establish auditable and verifiable privacy management system metrics.

In the EU and Germany, the GDPR and the Federal Data Protection Act (BDSG) require organizations to fulfill provable responsibility for the processing of personal data, including recording processing activities, conducting PIA/DPIA, implementing technical and organizational measures (TOMs), managing entrusted processors, and promptly reporting incidents. An integrated management system based on ISO/IEC 27001 and 27701 can systematically explain "how to ensure the protection of personal information" and serve as strong evidence in customer or partner audits, bidding due diligence, and third-party assessments. It is important to emphasize that ISO/IEC 27701 does not replace legal compliance or regulatory certification, but it provides a structured approach and verifiable evidence to meet regulations such as the GDPR and PIPL, thereby improving the maturity and market trust of companies in privacy governance in highly sensitive sectors such as healthcare, finance, utilities, communications, and the internet.

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What makes the ISO/IEC 27701 standard useful for my company?

Establishing a Privacy Information Management System (PIMS) in accordance with ISO/IEC 27701 is a strategic decision. The standard emphasizes adaptation to local conditions, requiring consideration of business scenarios, the types of personal information processed, organizational roles (controller/processor), applicable regulations (such as GDPR, PIPL), and scale and structure to plan and monitor privacy governance. The new version of ISO/IEC 27701:2025 adopts a high-level structure consistent with other management systems (auditable via Clauses 4–10) for integration with existing systems. It is important to note that 27701:2025 is an independent standard, not an extension of 27001/27002; whether to implement and certify it alongside 27001 is up to the organization, and the two can still be seamlessly integrated.

In ISO/IEC 27701:2025, Annex A lists privacy and information security controls, divided into three categories: A.1 (applicable to controllers), A.2 (applicable to processors), and A.3 (information security controls shared by controllers and processors). The new version includes 31 controls (controllers), 18 controls (processors), and 29 shared controls. Organizations must select applicable controls and form a Statement of Applicability (SoA) based on a privacy risk assessment (6.1.2) and processing (6.1.3), and may supplement with additional privacy controls as necessary.

Aligning the process with 27701 will bring a series of verifiable benefits:

  1. Continuously improve the maturity of privacy protection (privacy design and pre-set, provability/accountability implementation);
  2. Reduce the risk of violations and leaks (systematically manage PIA/DPIA, incident reporting, and cross-border transmission).
  3. Meet regulatory and contractual requirements (establish clear mappings and chains of evidence with frameworks such as GDPR and PIPL).
  4. Enhance employee awareness and role clarity (controller/handler responsibilities, duties and communication mechanisms);
  5. Enhance customer and ecosystem trust (through publicly available third-party audit/certification results). The implementation and corresponding relationships for these points are outlined in Articles 27701 and its appendices (including the correspondence between GDPR and the privacy framework).

To achieve these benefits, internal audits and management reviews are key "endogenous levers," and need to be combined with metrics (such as response to rights requests, data retention and deletion, third-party management, incident handling, etc.) to form an "assessment-improvement" closed loop. In accordance with the terms and annexes of ISO/IEC 27701, privacy governance can be embedded in the entire chain of processes, including development, operation, suppliers, and cross-border operations, encompassing privacy controls and connecting with necessary information security plans and control domains.

 

Relationship with other management systems

ISO 27701:2025 is designed to facilitate integration with management systems such as ISO 9001, 14001, and 27001. Whether simultaneous certification is required depends on business and market needs. Companies already implementing an ISMS can maintain their risk management and control baseline, reducing implementation costs. Organizations not yet implementing 27001 can directly establish a PIMS based on Clauses 4–10 of 27701:2025 and seek certification. Specific certification and transition arrangements are subject to the announcements of certification and accreditation bodies.

ISO 27701 provides an auditable, measurable, and demonstrable privacy governance architecture. The 2025 version further emphasizes independence and compatible integration, enabling organizations to more flexibly integrate privacy protection with business objectives, compliance requirements, and information security initiatives.

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Who can be certified according to ISO/IEC 27701?

Since its release in 2025, ISO/IEC 27701 has been upgraded to an independent Privacy Information Management System (PIMS) standard, which can be established and certified independently or integrated with ISO/IEC 27001.

When conducting third-party certification, the certification body must be accredited and meet two core requirements:

  • ISO/IEC 17021-1 General requirements for the competence and impartiality of management system certification bodies;
  • ISO/IEC 27706:2025 (Replaces TS 27006-2): Additional capability and methodological requirements for PIMS, including the audit team’s knowledge of privacy and regulations, evidence collection and sampling, certificate information, etc.

At the level of national accreditation bodies (such as UKAS and ANAB), PIMS accreditation also examines details such as personnel competence, audit arrangements, confidentiality and independence controls to ensure the credibility and comparability of certification results.

 

Why choose DQS?

  1. Global Recognition and Coverage DQS Group holds 100+ national/international accreditations covering information security and privacy, which can be audited and certified by entities with the corresponding accreditation scope.
  2. ISMS × PIMS capabilities We are familiar with the integration path of 27701 and 27001 and can make actionable improvement recommendations in compliance, risk and governance (without conflict of interest).
  3. Smooth migration to 27701:2025 For organizations that have already obtained 27701:2019, DQS can support a smooth migration to the 2025 version of the independent PIMS during the transition period, according to the arrangements of the IAF/local accreditation bodies.
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How is ISO/IEC 27701 certification conducted?

Once the requirements of ISO/IEC 27701 are planned and largely implemented within the organization, certification can be initiated. DQS will provide a multi-stage, transparent, and controllable process. If your company has already implemented an ISO/IEC 27001 ISMS, we will conduct the audit in an integrated manner to shorten the cycle and reduce disruptions.

The first step is to communicate with you about your organization's business, the scope and role of PIMS (controller/processor), regulatory concerns (such as GDPR/PIPL), and certification objectives, and provide a detailed quote and project plan accordingly.

Following the audit, DQS's independent certification decision committee will conduct a technical assessment and compliance verification of the evidence. If the standards are met, we will issue an ISO/IEC 27701 certificate (usually consistent with or related to the ISO/IEC 27001 certificate and scope) to demonstrate your organization's capabilities and maturity in privacy governance and entrusted processing.

Following certification, a surveillance audit should be conducted at least annually, focusing on ongoing compliance and improvement in key areas such as PIA/DPIA implementation, data subject requests and indicator management, data retention and deletion, third-party and cross-border management updates, incident handling and debriefing, and measurement and management reviews. Surveillance audits help organizations maintain and improve the operational performance of PIMS.

Certificates usually Valid for three years A recertification audit will be conducted before the expiration date to comprehensively review the system's continued suitability, adequacy, and effectiveness. Upon compliance, a new certificate will be issued, and the system will proceed to the next surveillance audit cycle.

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What is the cost of ISO 27701 certification?

Following Annex B's methodology, we categorized the factors into two main dimensions: first, we assessed the risks, and then we used a matrix to calculate the audit man-days and cost ranges.

1) Risks of PII Handling (Annex B — Table B.2)

1. Classification of PII

Does it involve highly sensitive/special category PII? Is DPIA/similar process required?

2. PII Transfer

Whether the transfer crosses jurisdictions/regions, and whether there is sufficient transfer and contractual control.

3. Processing complexity

Does it involve multi-platform/multi-region/multi-process automation? Does it involve profiling, algorithmic decision-making, and data exploration?

The above three items are rated as High / Medium / Low respectively, and are collectively classified as "Handling Risk".

 

(ii) PII Operational Risks (Annex B — Table B.3)

1. Number of people processing/accessing PII

The percentage of personnel covered in relation to the scope of certification.

2. PII Main Data Volume (Number of Records)

Data size and number of datasets.

3. Number of control measures implemented (A.1/A.2/A.3)

Appendix A: Coverage and maturity of relevant controls.

All three items are rated as High / Medium / Low, and the overall rating is "Operational Risk".

 

(iii) From Risk to Audit Man-Days and Costs (Annex B — Table B.4)

Substitute "Handling Risk × Operational Risk" into the matrix in Table B.4 to obtain the percentage adjustment range for audit man-days (e.g., adjusting upwards/downwards within a certain range).

Apply this range to the baseline man-days (considering organization size, number of sites/countries, whether it is integrated with 27001 auditing, etc.) to form a man-days estimate;

The cost range is determined by multiplying the standard daily rate by the number of person-days, and key assumptions and exclusions are recorded.

 

(iv) The preliminary information we need (for quickly identifying the range)

Certification scope and business scenarios; types and scale of PII involved; whether it is cross-border; list of main systems/platforms; ratio of self-developed to third-party systems; site/country; controller/processor role; ISO/IEC 27001 certification status and whether integration audit is being considered.

 

(v) Tip: Integration with 27001 makes auditing more efficient.

Reusing existing management structures and evidence reduces the need for repeated interviews and evidence collection, which can typically shorten the cycle and reduce overall costs.

 

(vi) Example Scenarios

  1. Small SaaS in a single cloud zone (low processing, low operational risk): Small adjustments are made to the baseline man-days to form a smaller range.
  2. Multi-business line online retail (medium-level handling of medium and medium-level operational risks): median of man-days is slightly above average, combining on-site and remote operations.
  3. For regulated industries in multiple countries and locations (high processing and high operational risks): man-days have increased significantly, requiring a more complete chain of evidence and contextual verification.

The above range will be based on the information you provide. We will provide a customized range of man-days and costs, as well as an implementation plan for review.

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What can you expect from us?

  • Over 35 years of experience in management system and process certification
  • Auditors and experts with extensive industry experience and strong technical knowledge
  • Insights that add value to your company
  • Possesses internationally recognized certification
  • Expertise and certification in all relevant standards
  • Our experts provide personalized, seamless support at the regional, national, and international levels.
  • Flexible contract terms and personalized pricing with no hidden fees

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