ISO 27701 Overview and Guides

What are the overlap between ISO 27001 and ISO 27701?

ISO 27701 requires an existing ISMS program to attach to. Clauses 5 to 8 within PIMS extend the requirements of ISO 27001 to incorporate PII considerations. The specific PIMS requirements in the clauses are listed below:

1. PIMS requirements related to ISO 27001 are outlined at clause 5
2. PIMS requirements related to ISO 27002 are outlined at clause 6
3. PIMS guidance for PII Controllers are outlined at clause 7
4. PIMS guidance for PII Processors are outlined at clause 8

It is smart for an organization to combine the ISMS-PIMS programs and extend their ISMS SOA to include the PIMS controls.

1. Annex A + Clause 6 = 37 enhanced controls
2. Annex A + Clause 7 = 31 new controls for controllers
3. Annex A + Clause 8 = 18 new controls for processors

Read our ISO standards and their Internal Audit (IA) requirements article to learn more!

Understanding ISO 27701 and its role in data privacy

ISO/IEC 27701:2019 is an extension to the ISO/IEC 27001 standard, focusing on Privacy Information Management Systems (PIMS). It provides guidelines for managing personal data and helps organizations demonstrate compliance with global privacy regulations such as GDPR and CCPA.

Implementing ISO 27701 involves

1. Establishing a PIMS: Integrating privacy controls with existing Information Security Management Systems.
2. Defining Roles and Responsibilities: Clarifying data controller and processor obligations.
3. Conducting Risk Assessments: Identifying and mitigating privacy risks.
4. Implementing Privacy Controls: Establishing measures to protect personal data.

By adopting ISO 27701, organizations can enhance their data privacy practices, build trust with stakeholders, and ensure compliance with evolving privacy laws.

Why should I pursue an ISO 27701 certification?

For organizations that process customer and employee data in multiple jurisdictions, ensuring compliance with several countries’ data governance laws is complex and not always straightforward. ISO 27701 can be a great start.

Among many benefits, the most notable are the following:

1. It provides a framework for complying with privacy regulations such as the General Data Protection Regulation (GDPR) in the European Union and the California Consumer Privacy Act (CCPA) in the United States.
2. It provides a systematic approach to identifying and mitigating privacy risks, helping organizations better protect personal data and reduce the risk of privacy breaches.
3. It can help organizations streamline their privacy management processes, reduce the cost and complexity of managing personal data and improve overall operational efficiency
4. This certification can help enhance an organization’s brand reputation by demonstrating a commitment to privacy and data protection, which can be particularly important for organizations that handle sensitive personal data such as healthcare or financial information.

Traditionally, ISO 27701 can cost anywhere between $15,000 and $100,000 when you factor in an ISO 27001 certification, the cost of the audit firm, as well as internal costs including productivity, staff training, and resources needed to meet specific requirements.

At TrustCloud, we believe compliance shouldn’t be expensive. To make the readiness and audit process both affordable and simple, the cost has been broken down into two areas:

1. A compliance automation platform. By automating much of the process, platforms such as TrustOps help you reduce and better manage your internal costs. We’ve developed a transparent and straightforward pricing structure to make it easier for you to manage the overall cost of the program.
2. An auditor. We’ve developed strong relationships with a number of audit firms. This means that they are trained on the platform and know how to evaluate your business; they are also able to pass along discounts as a result of a referral from TrustCloud. ISO 27701 audit partners in the TrustCloud network charge between $7,000 and $50,000 for audits, based on the maturity and complexity of the engagement.

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ISO 27701 preparation and tips

Preparing for ISO 27701 requires a comprehensive approach that involves understanding the standard’s requirements, involving stakeholders, leveraging existing information security controls, and providing regular training and awareness programs. By following these tips, organizations can effectively implement and maintain an compliant privacy information management system.

It is important to conduct a gap analysis to identify any areas where the organization may need to make improvements or implement new controls. This can involve reviewing existing policies, procedures, and processes to ensure they meet the requirements.

1. Comprehensive Approach to Preparation
   Preparing for ISO 27701 requires a broad strategy that includes understanding the standard’s requirements, engaging stakeholders, using existing security controls, and conducting regular training programs. These measures collectively support the implementation and maintenance of a compliant privacy information management system (PIMS).
2. Conducting a Gap Analysis
   A gap analysis is essential to identify deficiencies in current policies, procedures, or processes. This analysis helps organizations pinpoint areas requiring improvement or new control implementation to align with ISO 27701 requirements.
3. Stakeholder Involvement Across the Organization
   Privacy compliance extends beyond the IT department to all business units handling personal data. Early involvement of stakeholders ensures organizational cooperation and collective responsibility in the standard’s implementation and ongoing compliance.
4. Leveraging ISO 27001 Controls
   ISO 27701 builds upon ISO 27001’s framework. Organizations can optimize resources by integrating existing information security controls and processes from ISO 27001, reducing redundancy and streamlining the compliance process.
5. Importance of Regular Training and Awareness
   Regular training programs help employees understand their roles in protecting personal data and adhering to privacy best practices. This knowledge fosters a culture of privacy awareness, which is crucial for sustained compliance.

TrustCloud takes care of the preparation and helps you equip yourself to comply with ISO 27701 requirements. It helps you assesses your current security posture to identify gaps and suggest policies and controls.

However, though you can use a GRC tool for preparation, there are still some important considerations:

1. Make sure you have a dedicated team to handle the effort that ISMS-PIMS preparation demands. Compliance is a team effort and does require intent and continual effort. Making sure you have a clear goal and drive will help you succeed in this endeavor.
2. Perform an internal assessment to determine your gaps. This helps you determine how much time is needed. This is also something TrustCloud can help you with.
3. Document everything! If it is not documented, it is not happening!
4. Identify your Internal Audit team! A unique characteristic of ISO 27701 and ISO 27001 is the requirement to perform an internal audit. And this activity can be performed by an independent third-party or by employees of your organization, as long as they are qualified (understand the auditing process and requirements) and objective (have no conflict of interest).

Challenges and considerations

While ISO 27701 offers a comprehensive framework for privacy management, its successful implementation is not without challenges. Organizations should be aware of the following considerations:

1. Cultural and Organizational Change
   Implementing ISO 27701 often requires a shift in organizational culture. Employees at all levels must recognize the importance of data privacy. Securing buy-in might involve overcoming resistance to change, addressing concerns over additional bureaucracy, and ensuring that every stakeholder understands the necessity of aligning with global best practices.
2. Resource Allocation
   Implementing a new management system or upgrading an existing one demands both time and financial resources. Smaller organizations or those with limited resources might struggle with the allocation needed for comprehensive training, technology upgrades, and ongoing maintenance of the PIMS. It is essential to perform a cost-benefit analysis to understand the long-term gains that come from reduced risk exposure and improved stakeholder trust.
3. Regulatory Uncertainty
   The ever-evolving landscape of data protection laws can be a moving target. While ISO 27701 is structured to be flexible and assist in compliance, organizations must remain vigilant in staying updated with local and international regulations that might impose additional requirements.
4. Complexity of Integration
   For organizations with existing frameworks like ISO 27001, integrating privacy-specific processes may be straightforward. However, for those new to structured management systems, the process of integration can be complex and time-consuming. A phased approach with clear milestones can help in managing the change effectively.

TrustCloud has curated a toolkit to help you on your ISO 27701 journey!

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