Quick Answer

ISO/IEC 27701:2025 is an international standard for establishing, implementing, maintaining and continually improving a Privacy Information Management System (PIMS).

It provides organizations with a structured framework for managing personally identifiable information (PII), privacy risks, responsibilities, controls and accountability.

The standard is relevant to organizations acting as PII controllers, PII processors, or both.

An important change occurred with the 2025 edition: ISO/IEC 27701 is now an independent management system standard. An organization can therefore implement it as a standalone PIMS. It also remains aligned with ISO/IEC 27001 and can be integrated with an existing Information Security Management System (ISMS).

Current edition: ISO/IEC 27701:2025
Previous edition: ISO/IEC 27701:2019 — withdrawn and replaced
Management system: Privacy Information Management System (PIMS)
Primary focus: Privacy and protection of personally identifiable information
Applicable to: Organizations of any type or size processing PII

What Is ISO/IEC 27701?

ISO/IEC 27701 is an international privacy management standard designed to help organizations systematically manage personally identifiable information.

Rather than treating privacy as only a legal, IT or cybersecurity issue, the standard approaches privacy as an organization-wide management responsibility.

A Privacy Information Management System can bring together areas such as:

• privacy policies;
• governance and accountability;
• identification of privacy risks;
• PII inventories;
• data-processing activities;
• access controls;
• privacy roles and responsibilities;
• third-party and supplier management;
• incident handling;
• retention and deletion;
• monitoring and auditing;
• continual improvement.

The objective is not simply to install security software. A PIMS establishes repeatable organizational processes for deciding why personal information is collected, how it is processed, who has access to it, how it is protected, how long it is retained and how privacy obligations are managed.

Important Update: ISO/IEC 27701:2019 vs ISO/IEC 27701:2025

Anyone researching ISO/IEC 27701 may encounter many references to ISO/IEC 27701:2019.

That edition is no longer the current standard.

ISO lists ISO/IEC 27701:2019 as withdrawn and identifies ISO/IEC 27701:2025, Edition 2 as its replacement.

The distinction is particularly important because the role of ISO/IEC 27701 has changed.

Feature	ISO/IEC 27701:2019	ISO/IEC 27701:2025
Edition	First	Second
Current status	Withdrawn	Current
PIMS	Yes	Yes
Relationship with ISO/IEC 27001	Extension to an ISMS	Standalone management system possible
Integration with ISO/IEC 27001	Yes	Yes
Primary purpose	Privacy information management	Privacy information management

The 2019 edition operated as an extension to ISO/IEC 27001 and ISO/IEC 27002.

The 2025 edition has evolved into an independent management system standard while retaining alignment with ISO/IEC 27001.

Organizations planning a new PIMS implementation or certification project should therefore make sure documentation, consultancy, training and certification plans refer to the 2025 edition, unless there is a specific reason to examine the historical 2019 requirements.

What Is a Privacy Information Management System (PIMS)?

A Privacy Information Management System, commonly abbreviated as PIMS, is a structured management framework for controlling how an organization handles personally identifiable information.

It combines people, policies, processes, technology, documentation, risk management and management oversight.

For example, consider a company that stores:

• employee records;
• customer names;
• mobile numbers;
• email addresses;
• billing information;
• support tickets;
• IP addresses;
• account information;
• identity documents;
• website registration details.

A PIMS helps the company answer important questions such as:

What personal information do we have?

Why are we collecting it?

Where is it stored?

Who can access it?

Who receives it outside the organization?

How is it protected?

How long should it be retained?

How is it securely deleted?

What happens if it is accidentally disclosed?

This systematic approach is one of the major advantages of privacy management standards.

What Is Personally Identifiable Information (PII)?

PII refers broadly to information that relates to an identifiable person.

Depending on the circumstances and applicable laws, examples can include:

• name;
• residential address;
• telephone number;
• email address;
• employee identification information;
• customer account information;
• identification numbers;
• photographs;
• location information;
• online identifiers;
• financial information;
• device or network identifiers;
• biometric information;
• combinations of information capable of identifying an individual.

Terminology differs between standards and laws.

For example, privacy legislation may use terms such as personal data rather than PII. Organizations should therefore map ISO terminology to the privacy laws and contractual requirements applicable to them.

PII Controller vs PII Processor

Understanding the distinction between a PII controller and a PII processor is important when implementing ISO/IEC 27701.

PII Controller

A controller determines the purposes and means associated with processing PII.

For example, a company collects employee information for payroll processing.

The company determines:

• which information is required;
• why it is required;
• how it will be used;
• how long it should be retained.

It may therefore be acting as a controller for that processing activity.

PII Processor

A processor processes PII on behalf of another organization.

For example, a cloud payroll provider may process employee information on behalf of its customer.

Depending on the arrangement, the provider may therefore operate as a processor.

Can an Organization Be Both?

Yes.

A business can be a controller for some processing activities and a processor for others.

A managed IT services company, for example, may be a controller for its own:

• employee records;
• customer contacts;
• accounting records.

At the same time, it may process information belonging to customers while providing:

• cloud hosting;
• managed servers;
• technical support;
• backup services;
• software services.

Its privacy responsibilities therefore need to be evaluated according to each processing activity.

Who Should Consider ISO/IEC 27701?

ISO/IEC 27701 can apply to organizations of different sizes and sectors.

Examples include:

• IT service providers;
• managed service providers;
• cloud service providers;
• SaaS companies;
• software developers;
• data centres;
• financial organizations;
• hospitals and healthcare organizations;
• educational institutions;
• government organizations;
• e-commerce businesses;
• HR and payroll providers;
• accounting firms;
• call centres;
• legal firms;
• marketing organizations;
• telecommunications providers;
• professional service firms.

In practical terms, almost any organization processing significant quantities of personal information can benefit from formal privacy management.

Why Is ISO/IEC 27701 Important?

Modern organizations collect enormous quantities of personal information through websites, applications, cloud platforms, email, CRM systems, HR applications, support systems and business software.

Poor privacy governance can lead to:

• unauthorized disclosure;
• excessive data collection;
• inappropriate access;
• accidental sharing;
• excessive retention;
• insecure disposal;
• third-party exposure;
• privacy complaints;
• regulatory problems;
• contractual disputes;
• reputational damage.

ISO/IEC 27701 provides a management framework for addressing such risks systematically rather than handling privacy issues individually when something goes wrong.

Major Objectives of ISO/IEC 27701

A properly implemented PIMS should help an organization improve several areas of privacy management.

1. Privacy Governance

Privacy responsibilities should be clearly assigned rather than being assumed to belong exclusively to the IT department.

Management, legal/compliance, HR, information security, procurement and business departments may all have privacy responsibilities.

2. Identification of PII

Organizations should understand what personally identifiable information they process.

Without a reliable inventory, protecting that information becomes extremely difficult.

3. Privacy Risk Management

Organizations should identify and evaluate risks associated with their processing of PII.

Examples include:

• unauthorized database access;
• accidental email disclosure;
• compromised user accounts;
• insecure cloud storage;
• excessive privileges;
• inappropriate supplier access;
• unnecessary collection;
• lost laptops;
• unencrypted backups;
• incorrect retention;
• insecure disposal.

Controls can then be selected according to identified risks and applicable obligations.

4. Accountability

Privacy management should be demonstrable.

An organization may therefore maintain evidence such as:

• policies;
• procedures;
• processing inventories;
• risk assessments;
• approvals;
• contracts;
• audit records;
• access reviews;
• incident records;
• training records;
• management review records.

Good privacy management requires more than simply claiming that information is protected.

5. Privacy by Design

Privacy should be considered when systems, applications, processes and services are being designed rather than only after deployment.

For example, when developing a customer portal, an organization should consider:

• which personal information is actually necessary;
• who needs access;
• how authentication will work;
• whether information should be encrypted;
• retention requirements;
• deletion processes;
• logging requirements;
• third-party integrations.

6. Data Minimization

Organizations should avoid collecting personal information merely because it might become useful later.

A useful principle is:

Collect the information that is genuinely required for a defined purpose rather than collecting everything available.

Reducing unnecessary personal information can also reduce privacy exposure.

7. Retention and Disposal

Personal information should not necessarily remain in systems forever.

Organizations should establish appropriate retention and disposal processes based on factors such as:

• legal obligations;
• contractual requirements;
• business requirements;
• regulatory obligations;
• defined processing purposes.

When information is no longer required, appropriate deletion, anonymization or disposal procedures may be necessary.

Typical Components of a PIMS

An ISO/IEC 27701 implementation commonly involves documentation and processes covering areas such as:

Area	Example
Privacy policy	Organization-wide privacy commitments
PII inventory	Identification of personal information
Processing records	Documentation of processing activities
Risk management	Privacy risk assessments
Access management	Controlling access to PII
Supplier management	Privacy requirements for vendors
Incident management	Handling privacy incidents
Retention	Rules governing storage duration
Disposal	Secure deletion or destruction
Training	Privacy awareness for employees
Audit	Internal review of the PIMS
Management review	Senior management oversight
Improvement	Corrective and preventive actions

The exact documentation required depends on the organization, its role, processing activities, applicable requirements and PIMS scope.

ISO/IEC 27701 and ISO/IEC 27001

ISO/IEC 27701 and ISO/IEC 27001 are closely related but have different primary objectives.

ISO/IEC 27001	ISO/IEC 27701
Information Security Management System	Privacy Information Management System
Abbreviation: ISMS	Abbreviation: PIMS
Information-security risk	Privacy-information management
Protects information broadly	Focuses strongly on PII/privacy
Confidentiality, integrity and availability	Privacy governance and PII processing
Security management	Privacy management

Security and privacy overlap considerably, but they are not identical.

For example, a customer database might be technically secure against unauthorized access while still presenting a privacy problem if the organization:

• collects unnecessary information;
• uses information for inappropriate purposes;
• keeps information longer than necessary;
• shares it improperly.

ISO/IEC 27001 and ISO/IEC 27701 can therefore complement each other.

ISO/IEC 27701 and ISO/IEC 20000-1

Because ISO/IEC 27701 is frequently relevant to IT service providers, it can also complement ISO/IEC 20000-1, the international standard for IT Service Management Systems.

Their primary purposes differ:

Standard	Primary Focus
ISO/IEC 20000-1	IT Service Management
ISO/IEC 27001	Information Security Management
ISO/IEC 27701	Privacy Information Management

An IT service provider could therefore use:

ISO/IEC 20000-1 to manage service delivery,

ISO/IEC 27001 to manage information-security risks,

and

ISO/IEC 27701 to manage privacy and PII responsibilities.

Together, these management systems can provide a strong governance framework for organizations delivering managed IT, cloud, hosting, SaaS and other technology services.

ISO/IEC 27701 and GDPR

ISO/IEC 27701 can help organizations establish structured privacy governance and demonstrate accountability relevant to privacy regulations such as the EU General Data Protection Regulation (GDPR).

However, an important distinction must be understood:

ISO/IEC 27701 certification does not automatically prove complete compliance with every applicable privacy law.

Privacy legislation differs by jurisdiction and may contain legal requirements outside the scope of a management-system standard.

Organizations must separately identify and satisfy applicable legal, regulatory and contractual obligations.

ISO/IEC 27701 should therefore be viewed as a privacy management framework, not as a universal substitute for legal compliance.

ISO/IEC 27701 and India's Digital Personal Data Protection Framework

Indian organizations processing digital personal data should also evaluate requirements arising from India's applicable data-protection legislation and rules.

ISO/IEC 27701 can provide useful management-system processes for areas such as:

• governance;
• risk assessment;
• accountability;
• access management;
• incident handling;
• vendor management;
• retention;
• privacy awareness;
• continual improvement.

However, obtaining ISO/IEC 27701 certification should not be interpreted as automatically satisfying every obligation imposed by Indian law.

Organizations should separately determine which legal obligations apply to their processing activities and maintain appropriate legal and compliance advice where necessary.

Practical ISO/IEC 27701 Implementation Approach

An organization planning a PIMS can use the following high-level implementation sequence.

Step 1: Obtain the Current Standard

Make sure the organization is working with ISO/IEC 27701:2025, rather than outdated implementation material based exclusively on ISO/IEC 27701:2019.

Step 2: Define the PIMS Scope

Determine:

• organizational boundaries;
• departments;
• business processes;
• locations;
• systems;
• applications;
• services;
• categories of PII;
• controller and processor activities.

Poorly defined scope can create problems later during implementation and auditing.

Step 3: Identify PII

Create an inventory of personal information handled by the organization.

For example:

System	PII
HR software	Employee details
CRM	Customer contact information
Accounting software	Billing information
Helpdesk	Customer names, emails and support information
Email	Business and personal correspondence
Backup system	Copies of production PII
Website	Contact forms and account information

Step 4: Map Data Flows

Determine where PII:

• originates;
• enters the organization;
• is stored;
• is processed;
• is transferred;
• is backed up;
• leaves the organization;
• is eventually deleted.

A simple data-flow diagram can reveal privacy risks that are difficult to see from written policies alone.

Step 5: Identify Legal and Contractual Requirements

Determine which privacy laws, regulations, customer contracts and industry obligations apply.

Requirements can vary significantly depending on:

• jurisdiction;
• industry;
• type of information;
• location of individuals;
• processing purpose;
• international transfers.

Step 6: Perform Privacy Risk Assessment

Identify privacy threats and evaluate their potential impact.

Examples include:

Risk: Unauthorized employee accesses customer records.

Possible controls: Role-based access, least privilege, authentication, logging and periodic access reviews.

Another example:

Risk: Customer data remains indefinitely in old backups.

Possible controls: Defined backup-retention schedule and secure expiration/deletion processes.

Step 7: Implement Appropriate Controls

Depending on the risk assessment, technical and organizational measures may include:

• MFA;
• encryption;
• role-based access;
• least privilege;
• audit logging;
• secure backup;
• network security;
• endpoint protection;
• secure software development;
• supplier controls;
• privacy training;
• incident procedures;
• retention policies;
• secure deletion.

Technology alone, however, does not constitute a complete PIMS.

Step 8: Establish Privacy Policies and Procedures

Typical documentation may include:

• privacy information management policy;
• privacy roles and responsibilities;
• PII inventory;
• risk-management methodology;
• processing records;
• retention policy;
• deletion procedures;
• access-control procedures;
• supplier-management procedures;
• privacy incident procedures;
• training procedures;
• internal audit procedures.

Documentation should reflect actual organizational practices rather than being created solely for an audit.

Step 9: Train Employees

Human error remains an important privacy risk.

Employees should understand topics such as:

• identifying personal information;
• secure handling;
• email privacy;
• phishing;
• password and authentication practices;
• appropriate sharing;
• incident reporting;
• secure disposal.

Training should be appropriate to employee responsibilities.

Step 10: Conduct Internal Audit

Internal audits help determine whether:

• procedures are being followed;
• controls are operating;
• documentation is current;
• deficiencies exist;
• corrective actions are required.

Internal auditing should be treated as an improvement mechanism rather than simply an audit requirement.

Step 11: Conduct Management Review

Senior management should periodically evaluate the PIMS.

Relevant inputs can include:

• audit results;
• incidents;
• privacy risks;
• objectives;
• corrective actions;
• regulatory changes;
• supplier issues;
• performance indicators.

Management involvement is essential because privacy governance cannot be delegated entirely to IT staff.

Step 12: Certification Audit

Organizations seeking accredited third-party certification can engage an appropriate certification body.

The organization should verify the certification body's accreditation, competence, certification scope and ability to certify against the required edition of ISO/IEC 27701.

Common Privacy Risks in IT Environments

IT departments and service providers should pay particular attention to situations such as:

Shared Administrator Accounts

Multiple administrators using the same account reduces accountability.

Prefer named administrative accounts with appropriate auditing.

Excessive Permissions

Users may retain access after changing departments or responsibilities.

Periodic access reviews can identify unnecessary privileges.

Unencrypted Laptops

Portable devices can expose personal information if lost or stolen.

Encryption and appropriate device-management controls can reduce this risk.

Old Backups

Backups may contain personal information long after production systems have removed it.

Backup retention should therefore form part of privacy planning.

Cloud Applications

Employees may upload personal information to unauthorized cloud services.

Approved-service policies and appropriate technical controls can help manage this risk.

Email Attachments

Personal information can easily be sent to the wrong recipient.

Training, process controls and appropriate technical safeguards can reduce accidental disclosure.

Former Employees

Accounts belonging to departed employees may remain active.

A formal joiner-mover-leaver process should cover timely access revocation.

Benefits of ISO/IEC 27701

Potential benefits of implementing ISO/IEC 27701 include:

• stronger privacy governance;
• improved management of PII;
• clearer privacy responsibilities;
• systematic privacy risk management;
• better documentation;
• improved supplier oversight;
• improved incident preparedness;
• stronger privacy awareness;
• evidence of organizational accountability;
• increased customer and partner confidence;
• easier integration of privacy into information-security management;
• support for demonstrating structured privacy practices to customers and regulators.

Actual benefits depend on how effectively the PIMS is implemented and maintained.

What ISO/IEC 27701 Does Not Guarantee

ISO/IEC 27701 should not be misunderstood.

Certification does not mean:

• a data breach can never occur;
• every system is completely secure;
• every employee will always follow procedure;
• every privacy risk has been eliminated;
• every privacy law worldwide is automatically satisfied.

Management systems are designed to establish controlled, repeatable and continually improving processes.

They reduce and manage risk; they do not eliminate all risk.

ISO/IEC 27701 for Small Businesses

ISO/IEC 27701 is not restricted to large enterprises.

A smaller organization can also establish a PIMS, although the scale and complexity should reflect its environment.

A small IT company might begin with:

1. identifying the PII it holds;
2. documenting why it processes that information;
3. defining employee access;
4. identifying third parties receiving the information;
5. establishing retention periods;
6. documenting backup and deletion processes;
7. implementing security controls;
8. establishing an incident-response procedure;
9. training employees;
10. periodically reviewing privacy risks.

The objective should be a practical privacy-management system rather than unnecessary paperwork.

ISO/IEC 27701 for IT Service Providers and MSPs

ISO/IEC 27701 can be particularly relevant to IT service providers because they may have privileged access to customer environments.

Examples include providers offering:

• managed IT services;
• remote support;
• server administration;
• cloud hosting;
• Microsoft 365 administration;
• Google Workspace administration;
• managed backup;
• VPS hosting;
• SaaS;
• helpdesk services;
• database administration;
• cybersecurity services.

Such providers should understand whether they act as controllers, processors or both for each service.

They should also consider:

• administrator access;
• remote-support logs;
• customer credentials;
• backup copies;
• support tickets;
• subcontractors;
• cloud providers;
• retention periods;
• account termination;
• incident notification;
• secure disposal.

This makes privacy management an important component of professional IT service governance.

Frequently Asked Questions

What is the latest version of ISO/IEC 27701?

The current edition is ISO/IEC 27701:2025, Edition 2.

Is ISO/IEC 27701:2019 still current?

No. ISO identifies ISO/IEC 27701:2019 as withdrawn and replaced by ISO/IEC 27701:2025.

What does PIMS stand for?

PIMS stands for Privacy Information Management System.

Is ISO/IEC 27701 only for IT companies?

No. It can apply to public, private and not-for-profit organizations that process personally identifiable information.

Does ISO/IEC 27701 require ISO/IEC 27001?

This is an important area where older online information can be misleading.

The 2019 edition was designed as an extension to ISO/IEC 27001 and ISO/IEC 27002.

The 2025 edition is an independent management system standard and can therefore be implemented on a standalone basis. It remains aligned with ISO/IEC 27001 and can be integrated with an existing ISMS.

Is ISO/IEC 27701 certifiable?

Organizations can pursue certification of their PIMS through appropriate certification arrangements. Organizations considering certification should confirm that the certification body is competent and appropriately accredited for the required scope and current standard.

Does ISO/IEC 27701 guarantee GDPR compliance?

No.

It can support structured privacy governance and accountability relevant to GDPR, but certification should not be interpreted as automatic or complete compliance with every GDPR requirement.

Does ISO/IEC 27701 guarantee compliance with India's privacy laws?

No.

It can support privacy governance and management processes, but organizations must separately identify and comply with applicable Indian legal requirements.

Is ISO/IEC 27701 useful for cloud service providers?

Yes. Cloud providers frequently process customer PII and may benefit significantly from formal privacy governance.

What is the difference between ISO/IEC 27001 and ISO/IEC 27701?

ISO/IEC 27001 primarily addresses information security management, while ISO/IEC 27701 addresses privacy information management and PII processing.

The two standards can be integrated.

Can a small business implement ISO/IEC 27701?

Yes. The standard can apply to organizations of different types and sizes. The PIMS should be designed proportionately to the organization's processing activities, risks and obligations.

Final Recommendation / Conclusion

Organizations increasingly depend on personal information to deliver digital services, manage employees, support customers and operate cloud-based systems. Privacy therefore needs to be managed systematically rather than addressed only after a complaint, audit or data breach.

ISO/IEC 27701:2025 provides an internationally recognized framework for establishing a Privacy Information Management System (PIMS).

It can help organizations understand the PII they process, establish accountability, assess privacy risks, implement appropriate controls, manage suppliers, improve employee awareness and continually improve privacy practices.

For IT service providers, cloud providers and organizations already using management-system standards, a particularly useful combination can be:

ISO/IEC 20000-1 — IT Service Management
ISO/IEC 27001 — Information Security Management
ISO/IEC 27701 — Privacy Information Management

Organizations starting a new privacy-management initiative should ensure that they are using ISO/IEC 27701:2025 rather than implementation material limited to the withdrawn ISO/IEC 27701:2019 edition.

ISO/IEC 27701 should also be treated as a privacy-management framework rather than a substitute for legal advice. Applicable national and international privacy laws must be assessed separately.

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