ISO 27701:2019 for Data Controllers and Processors – A Practical Guide to Privacy Compliance

Effective privacy management is more important than ever at a time when personal data influences everything from marketing plans to corporate operations. The ISO 27701:2019 standard is the gold standard for building a Privacy Information Management System (PIMS) and offers a robust extension that integrates privacy into the framework for enterprises already using ISO 27001.

Building trust, lowering risk, and complying with laws like the CCPA, GDPR, and others all depend on your ability to comprehend how ISO 27701 relates to your position as a data controller, processor, or both.

Let's examine ISO 27701's requirements, its effects on data controllers and processors, and the advantages of applying it for your company.

What is ISO 27701:2019?

An expansion of the widely used ISO 27001 information security standard is ISO 27701. It offers recommendations for creating a privacy-first culture in your company and particularly tackles the handling of personally identifiable information (PII).

ISO 27701 focuses on managing privacy, whereas ISO 27001 focuses on information protection. It expands your ISMS to include data protection responsibilities, defines roles, and adds privacy-specific controls.

Who Are Data Controllers and Processors?

You must first comprehend the difference between data controllers and data processors—terms that are frequently used in GDPR and reflected in ISO 27701—in order to comprehend the practical consequences of ISO 27701:

The person or organization that decides how and why to treat personal data is known as the data controller. Their amount of responsibility for privacy obligations is the highest.

The organization that handles personal data on behalf of the controller is known as the data processor. Modern data protection regulations hold processors accountable even though they follow instructions.

Many companies, depending on the department or service, serve as both controllers and processors. Each role's tasks are clearly divided by ISO 27701, which also assigns particular controls.

Why ISO 27701 Matters for Controllers and Processors

Global privacy regulations are constantly changing, and noncompliance carries severe penalties. A uniform and globally accepted framework is offered by ISO 27701 that:

Complies with the CCPA, GDPR, and other laws

aids in proving openness and accountability

increases preparedness for audits

lowers the possibility of data breaches and harm to one's reputation

aids in the management of third parties in intricate supply networks

ISO 27701 provides structured guidelines for data controllers on how to handle user rights, consent, privacy impact assessments, and other matters.

It assists in demonstrating due diligence for data processors, particularly when working with several clients and jurisdictions.

ISO 27701 Requirements for Data Controllers

If your company is a data controller, you are in charge of making sure that processing is done legally and that PII is protected throughout its lifecycle. In accordance with ISO 27701, you must:

Determine and record the legitimate processing grounds.

Acquire and efficiently handle consent

Use privacy notifications to preserve openness.

Respect the rights of data subjects, including those to access, correct, and delete.

Perform PIAs, or privacy impact assessments.

Track cross-border data transfers

Establish policies for disposal and retention.

These procedures are guaranteed to be quantifiable, reproducible, and continuously improved by the standard.

ISO 27701 Requirements for Data Processors

It is required of you as a data processor to have procedures in place to protect the PII you handle for controllers. According to ISO 27701, processors must:

Follow the controller's directions to the letter.

Put in place strong encryption and access controls.

Continue using incident response protocols.

Maintain accurate records of all processing operations.

Help controllers fulfill requests from data subjects

Do due diligence on suppliers.

Create and evaluate procedures for notifying breaches.

Due to clients' growing demands that providers comply with ISO 27701, these requirements are particularly useful when bidding for contracts.

Benefits of Implementing ISO 27701 for Both Roles

ISO 27701 provides a strong privacy basis for your company, regardless of whether you are a controller, processor, or both. Important advantages include:

Simplified adherence to global privacy regulations

Lower risk to one's reputation and legal standing

Simplified internal and external audit documentation

Increased competitive advantage and customer trust

Efficiency in operations through standardized procedures

Additionally, it lessens duplication and fragmented efforts by bringing your company's security and privacy strategies into alignment.

How to Get Started

Understanding your position or roles, determining the controls that apply, and bringing your current procedures into compliance with the standard are the first steps in implementing ISO 27701.

This frequently entails:

An extension or update to your ISO 27001 ISMS

Performing a gap analysis

Creating new documents that are specific to privacy

Establishing roles and duties

Educating employees and increasing awareness

Establishing systems for monitoring and review

Although it takes a lot of work, the rewards are competitive advantage, resilience, and trust.

Shortcut Your Success with a Ready-to-Use ISO 27701 Toolkit 

It can take weeks or months to write consent management processes, privacy policies, DPIAs, and breach response procedures from scratch. To assist you easily install a PIMS, we developed the ISO 27701:2019 Documentation Toolkit, a professionally designed and fully customizable set of templates.

This toolkit provides all the necessary resources for anyone working as a processor, data controller, or both.

Comply with ISO 27701 specifications

Integrate your ISMS with privacy.

Easily pass audits

Be accountable in accordance with the GDPR and other regulations.

👉 Explore the ISO 27701:2019 Toolkit and expedite your privacy compliance journey by visiting our eCommerce store right now.