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Implementation walkthrough

How to implement ISO/IEC 27701: video walkthrough

A walkthrough of implementing an ISO/IEC 27701 privacy information management system, from the role the certificate must state to the independent audit.

  • Implementation walkthrough
  • 3 min 14 s

Key takeaways

  • Decide first whether the certificate covers you as a PII controller, a PII processor or both.
  • Data mapping, the record of what you hold and why, comes before the controls.
  • Annex A controls are grouped for controllers, for processors and for both roles.
  • The 2025 edition is a standalone management system standard.
  • An independent, accredited certification body audits the PIMS and decides.

Turning privacy promises into an operated system

ISO/IEC 27701 is the international standard for a privacy information management system, or PIMS: a governed, auditable way of managing personally identifiable information from the decision to collect it to its deletion. It is written for the two roles data protection law recognises, the PII controller that decides why and how personal data is processed and the PII processor that handles it for a controller, and for the many organisations that are both.

Most organisations already have a privacy notice and a policy. What they usually lack is a system that records what personal data they hold and why, answers requests within a deadline, controls sub-processors and transfers, and proves it. This short film walks through how that system is built and prepared for certification.

The ISO/IEC 27701 implementation path

Start with the scope and the role the certificate must state: the processing activities, services, sites and systems covered, and whether you are certified as a controller, a processor or both, matched to the contract or regulator behind the project. A gap analysis then reviews existing notices, policies, contracts, registers and records against clauses 4 to 10 and the Annex A controls for your role, keeps what works and sets a plan with owners and dates.

The build begins with mapping the personal data you hold and the purposes behind it, then puts the controls for your role into operation, from request handling to sub-processor control and transfers, with records accumulating as the system runs. Internal audit and management review test what has been built before an independent certification body, accredited for PIMS certification, audits the system and decides.

ISO/IEC 27701:2025, published on 14 October 2025, is a standalone management system standard, so it can be implemented on its own or integrated with ISO/IEC 27001. Sterling's expert and experienced consultants build the PIMS with your privacy, legal, technology and operations teams under Sterling OS™, guided or fully managed, with the evidence held in Effivity.

ISO/IEC 27701 at a glance

Purpose
Privacy information management: governing how personally identifiable information (PII) is collected, used, shared, retained and deleted, as a controller, a processor or both
Relevant to
Any organisation that processes personal data: software and SaaS, BPO, healthcare, financial services, HR and payroll, e-commerce, and every processor serving clients
Edition
ISO/IEC 27701:2025, published 14 October 2025, a standalone management system standard; 2019 certificates transition on the timetable your certification body confirms, expected to close on 31 October 2028
Certification
Assessed and decided by an independent certification body accredited under ISO/IEC 17021-1 and ISO/IEC 27706
Sterling's role
Consulting with your team, Effivity, training, internal audit and certification readiness, then Sustain™
Cost and timing
Total investment for an ISO/IEC 27701 PIMS depends on the current maturity of your processes, the scope, locations and number of employees. The process typically takes 3 to 8 months

ISO/IEC 27701: the complete guide →

ISO/IEC 27701: questions people ask

Do we need ISO/IEC 27001 before we can be certified to ISO/IEC 27701?

Not any more. The 2019 edition could only be certified as an extension of an ISO/IEC 27001 certificate. ISO/IEC 27701:2025 is an independent management system standard and can be certified on its own. It still contains information security controls, so a standalone PIMS has to operate them; where an ISO/IEC 27001 system exists, integrate the two.

Are we a PII controller or a PII processor?

Usually both. You are a controller for the personal data of your own employees, customers and contacts, and a processor for the data you handle on a client's instructions. The role is determined activity by activity; the certificate scope states the roles covered, which decides which controls apply.

Does ISO/IEC 27701 certification mean we comply with the GDPR or our national data protection law?

No. The certificate confirms that an accredited body found your PIMS conforming to the standard. Laws such as the EU GDPR, the Philippine Data Privacy Act, India's Digital Personal Data Protection Act and the UAE Personal Data Protection Law have their own requirements, which your legal advisers interpret; the PIMS gives you organised, audited evidence of how you meet them.

What changed between ISO/IEC 27701:2019 and 2025, and when must we transition?

The 2025 edition is a standalone management system standard with its own clauses 4 to 10 and a consolidated Annex A of controller, processor and information security controls, with guidance in Annex B. Accreditation bodies have published a three-year transition ending on 31 October 2028; 2019 certificates remain valid until then if maintained. Certification bodies are completing their own accreditation transitions first, so agree your audit date early.

Does Sterling issue the ISO/IEC 27701 certificate?

No. Sterling builds, trains and prepares. An independent certification body accredited for PIMS certification under ISO/IEC 17021-1 and ISO/IEC 27706 audits the PIMS in two stages and decides. A provider that offers the consulting and the certificate on one invoice is selling paper.

More ISO/IEC 27701 questions and answers →

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