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ISO/IEC 27701:2025 — What’s New, Why It Matters, and How to Get Certified

  • Danny Abramovich
  • 3 hours ago
  • 4 min read

What is ISO/IEC 27701?

ISO/IEC 27701 defines the requirements and guidance for a Privacy Information Management System (PIMS)—a management system focused on protecting personally identifiable information (PII) and proving accountability to regulators, partners, and customers. It sits within the ISO/IEC 27000 family and complements security with privacy governance, risk, and controls for both PII controllers and processors.


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What changed in ISO/IEC 27701:2025?


Status & timing. Edition 2 (labelled ISO/IEC 27701:2025) is in ISO’s “under publication” stage as of October 2025—i.e., final production steps before release, replacing the 2019 edition. Expect official availability imminently.


1) Stand-alone standard (no longer an “extension”).

The 2019 edition was an extension to ISO/IEC 27001/27002; the 2025 edition has been redrafted as a stand-alone management system standard. Organizations will not be required to certify to ISO/IEC 27001 before certifying their PIMS—though strong information-security controls are still expected through privacy risk treatment.


2) Modernized structure (Clauses 4–10 requirements).

The new edition adopts ISO’s high-level structure used by other MSS (e.g., ISO 9001, 27001, 42001), making integration easier. Crucially, Clauses 4–10 now contain mandatory PIMS requirements (no exclusions), whereas much of 2019’s content was guidance.


3) Risk management ties privacy and security together.

The standard requires explicit privacy risk assessment and treatment and documentation of the information-security program supporting privacy objectives. It references ISO/IEC 27001/27002 as normative aids while keeping PIMS independent.


4) Annexes reshaped controls & guidance.

  • Annex A lists possible privacy controls for controllers (A.1), processors (A.2), and information-security controls applicable to both (A.3). (SGS summarizes counts and organization.)

  • Annex B (normative) provides implementation guidance for the selected controls.

    The note clarifies that Annex A is not exhaustive—you may add controls as needed.


5) Title and terminology updated.

The title now reads: Information security, cybersecurity and privacy protection — Privacy information management systems — Requirements and guidance, reflecting its independence from ISO/IEC 27001/27002 and broader applicability. Terms and definitions have been refreshed to align with modern ISO MSS language.


6) Certification framework alignment coming via ISO/IEC 27706.

A new companion standard, ISO/IEC 27706, sets requirements for bodies auditing and certifying PIMS—this is also moving through ISO’s “under publication” steps in Oct 2025, signalling the ecosystem for accredited certification is being formalized.


Note on transition rules: formal transition timelines and certification rules for the new edition were not yet released during the FDIS period; historically, these are released shortly after publication by accreditation bodies.


Benefits of the 2025 update (why upgrade from 2019)


  • Direct PIMS certification path. No prerequisite ISO/IEC 27001 certificate lowers the entry barrier—useful for privacy-focused organizations or those with separate security certifications.

  • Easier integration across standards. The high-level structure aligns with other MSS (ISO 9001/27001/42001), reducing duplicated documentation, audits, and governance overhead.

  • Clearer controller/processor controls. The reorganized Annexes and normative guidance sharpen expectations for both roles, improving contract diligence and vendor oversight.

  • Stronger market assurance. A recognized, up-to-date PIMS helps demonstrate accountability for global privacy regimes (e.g., GDPR, CCPA, LGPD) and builds trust with customers and regulators.

  • Future-proofed privacy program. The refocus on risk-based controls, cloud/service supply chains, and modern operations helps organizations keep pace with evolving tech and cross-border data flows.


How to achieve certification with ISO/IEC 27701:2025


  1. Decide your certification route.

    • Stand-alone PIMS: Suitable if privacy is your primary driver and you don’t yet hold 27001.

    • Integrated PIMS+ISMS: If you already have 27001 or plan to, integrate to share scope, risk, audits, and controls. (The new structure makes this easier.)


  2. Define scope and roles.

    Pin down PII processing contexts, jurisdictions, and whether you act as controller, processor, or both; align applicable Annex A controls accordingly.


  3. Build the PIMS (Clauses 4–10).

    • Context, leadership, policy, roles & responsibilities

    • Planning: privacy objectives, privacy risk assessment (6.1.2) and risk treatment (6.1.3), including the documented information-security program supporting privacy outcomes

    • Support & operation: competence, awareness, communication, DPIAs/PIAs as relevant, records, vendor/privacy clauses

    • Performance evaluation: monitoring, internal audit, management review

    • Improvement: nonconformities and continual improvement


  4. Select and implement controls.

    Use Annex A to select relevant privacy and information-security controls (A.1, A.2, A.3) and implement using Annex B guidance; document rationale (e.g., a PIMS “statement of applicability”).


  5. Evidence & metrics.

    Establish records, KPIs, and audit trails for consent, lawful bases, retention, rights requests, data sharing, cross-border transfers, breach handling, vendor management, and training. (ISO emphasizes evidence-based privacy management.)


  6. Internal audit & readiness.

    Run a full PIMS internal audit, correct gaps, and prepare for the certification audit. Certification bodies will apply the requirements of ISO/IEC 27706 as they come into force.


  7. Transition planning (if you’re on 2019).

    Monitor your CB/AB announcements for the official transition window and milestones. (During FDIS, rules weren’t yet published; historically, these follow publication.)


Key challenges to anticipate


  • Scoping without a pre-existing ISMS. PIMS is now stand-alone; organizations without 27001 must still prove a robust information-security program that supports privacy risk treatment.

  • Controller vs. processor complexity. Mixed roles across business units and third parties require careful control selection and evidence.

  • Cloud and cross-border data flows. Mapping data paths, transfer mechanisms, vendor chains, and shared responsibilities remains non-trivial.

  • Ecosystem alignment and timing. Certification/transition rules and auditor requirements (ISO/IEC 27706) are entering production; organizations should track CB/AB updates and plan migrations.

  • Sustained compliance across regimes. Harmonizing GDPR, CCPA/CPRA, LGPD, etc., with your Annex A control set and processes requires ongoing regulatory watch and updates.


How TITANS SECURITY can help


Program strategy & scoping. 

We define a right-sized PIMS—stand-alone or integrated with 27001—mapped to your products, data flows, and jurisdictions.


Privacy risk & control design. 

We run privacy risk assessments, draft risk treatment plans, and build the supporting information-security program required by 6.1.2/6.1.3—plus select and tailor Annex A controls (controllers/processors/security).


Documentation & evidence. 

From policies and RoPA/DPIA templates to vendor DPAs, cross-border transfer records, SoA-style control rationale, training, and KPIs.


Implementation & readiness. 

We operationalize processes (rights requests, breach response, vendor oversight), perform internal audits, and coach teams for certification.


Transition services (2019 → 2025). 

Gap analysis, migration roadmap, evidence refresh, and liaison with your certification body as 27706-based audit requirements roll out.

 
 
 
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