GDPR guide
GDPR vs ISO 27701, ISO 27001 and SOC 2: one law, two certificates and a report, and which you need
The GDPR is a law you must meet; ISO/IEC 27701 and ISO/IEC 27001 are certifiable standards and SOC 2 is a CPA firm's report. This guide compares scope, assessor, output, cycle and cost drivers, and shows when to add one, two or none.
Key points
- GDPR vs ISO 27701 is a law against a standard: the GDPR is binding on anyone it reaches, while ISO/IEC 27701 is a voluntary privacy management system you can have certified.
- ISO/IEC 27001 certifies how you manage information security, and SOC 2 is a CPA firm's report on your controls; neither tests whether your processing of personal data is lawful.
- No certificate or report settles GDPR compliance. Article 42 of the Regulation says even an approved GDPR certification leaves your responsibility where it was.
- Most processors serving European and US clients end up with the GDPR programme plus one or two of the others, built as one system with one set of evidence.
GDPR vs ISO 27701: the short answer
You do not choose between the GDPR and anything else. If Article 3 reaches you, because you are established in the EU or EEA, or because you offer goods or services to people there or monitor their behaviour, the Regulation applies whether or not you hold a certificate. The real choice is which, if any, of three independent assurances to add on top of a working compliance programme.
Each answers a different question. ISO/IEC 27701 answers "is privacy managed as a system?" ISO/IEC 27001 answers "is information security managed as a system?" SOC 2 answers "did the controls behind this service operate, according to an independent CPA firm?" The GDPR requires the hardest question of all: "is each use of this personal data lawful, and can you prove it?"
Only your own records answer that last one: Articles 5(2) and 24 put the burden of demonstration on the controller.
The four side by side
| What is compared | GDPR | ISO/IEC 27701 | ISO/IEC 27001 | SOC 2 |
|---|---|---|---|---|
| What it is | EU regulation, Regulation (EU) 2016/679, applied since 25 May 2018 | Privacy information management system standard, 2025 edition | Information security management system standard, 2022 edition with Amendment 1:2024 | AICPA attestation against the 2017 Trust Services Criteria |
| Scope | Every processing of personal data it reaches, as controller or processor | The personal data you handle as controller, processor or both, within a scope you define | Information and systems within a scope you define; personal data is one asset among many | The system behind a service; security always, privacy only if you add that category |
| Who assesses | Supervisory authorities, and in practice your clients' auditors | A certification body accredited under ISO/IEC 17021-1 and ISO/IEC 27706 | A certification body accredited under ISO/IEC 17021-1 and ISO/IEC 27006-1 | A licensed CPA firm, or an equivalent practitioner under ISAE 3000 |
| Output | No certificate; your evidence file, and corrective orders or fines where it fails | Certificate with a public scope | Certificate with a public scope | Restricted-use report with an opinion, usually shared under NDA |
| Cycle | Continuous; the record of processing, DPIAs and transfers follow every change | Two-stage initial audit, annual surveillance, recertification in year three | Two-stage initial audit, annual surveillance, recertification in year three | Type 1 at a date, Type 2 over a period, renewed each year |
| Cost drivers | Processing activities, systems, suppliers, jurisdictions and legal review | Controller or processor role, data flows, scope and certification-body days | Scope, sites, systems and certification-body days | Report type, period length, categories and CPA firm fees |
| Typical buyers asking | Regulators, EU clients, data subjects | Controllers vetting processors, privacy-led tenders | Security questionnaires, tenders, international clients | US and enterprise security and procurement teams |
| Realistic duration | 3 to 8 months to a working programme | 3 to 8 months to a certification decision | 4 to 8 months to a certification decision | 3 to 6 months to Type 1; 9 to 15 months to a first Type 2 |
Prices depend on these drivers, not on the name of the framework; the GDPR compliance cost guide walks through them for the programme itself.
What each one proves, and where it stops
ISO/IEC 27701
The 2025 edition is a standalone management system written for privacy, with Annex A controls for PII controllers, for PII processors and for security shared by both, and an informative mapping to the GDPR. A certificate shows that an accredited body found the system in place and working for its scope. It does not show that a lawful basis was the right one or that a transfer safeguard holds, and it is not a certification approved under Article 42.
ISO/IEC 27001
It covers the security half of the Regulation well. Article 32 asks for measures appropriate to the risk, such as encryption, resilience, restoration and regular testing, and a risk-based ISMS with a Statement of Applicability covering the 93 Annex A controls is a strong way to evidence them. Lawful bases, notices, rights requests and transfers lie outside it.
SOC 2
A Type 2 report tells a client that named controls operated over a period, with any exceptions listed. The privacy category tests personal information against your own notice and commitments, not against the GDPR's articles, so a clean opinion on privacy is still not a legal finding.
Approved GDPR seals
Article 42 allows voluntary mechanisms approved by a supervisory authority or the European Data Protection Board, valid for up to three years; the Board's register lists only a few, Europrivacy among them. Even these, Article 42(4) says, do not reduce the controller's or processor's responsibility.
Which one, or both? A decision table
Start from who is asking, then pick the smallest set that satisfies them.
| Your situation | Recommendation | Why |
|---|---|---|
| Controller in the EU, no client asking for a certificate | GDPR programme only | The regulator judges your records, not a certificate; spend the effort on the inventory, notices and DPIAs |
| Processor handling EU personal data for business clients | GDPR programme plus ISO/IEC 27701 | Controllers must use processors with sufficient guarantees; a PIMS certificate is evidence they can weigh in due diligence |
| Security questionnaires and tenders dominate, privacy questions follow | ISO/IEC 27001 first, extended to ISO/IEC 27701 | One certification body can audit both on a shared management system |
| SaaS or BPO selling to US enterprises and holding EU data | GDPR programme, SOC 2 (with privacy if clients ask), and ISO/IEC 27001 or 27701 for international buyers | US procurement reads the SOC 2 report; European clients look for certificates and GDPR evidence |
| Operating in several countries with several privacy laws | ISO/IEC 27701 as the backbone of one programme | A PIMS can carry the GDPR and national laws through one legal register |
| A client or authority specifically requires a GDPR certification | An approved Article 42 scheme, on top of the programme | ISO/IEC 27701 does not satisfy a requirement written for an Article 42 seal |
Running them as one programme
The overlap is large, so a second framework adds far less work than the first when the records are shared. Build one data inventory that feeds both the GDPR record of processing and the PIMS; one risk method that covers risk to the business and risk to the people whose data you hold; one incident procedure that meets the 72-hour notification test and produces the records a certification body or CPA firm samples; one supplier file holding processor agreements, transfer safeguards and security assessments.
A company with ISO/IEC 27001 in place adds the privacy clauses and controls; one starting from nothing can build the GDPR programme and ISO/IEC 27701 together. SOC 2 then draws most of its controls from the same set, with an evidence calendar for the examination period. The GDPR requirements guide explains each article.
How Sterling builds privacy and security assurance together
One programme, one set of evidence, and the assurance your clients actually ask for.
Sterling's expert and experienced consultants start with a gap analysis against the Regulation and whichever of ISO/IEC 27701, ISO/IEC 27001 and SOC 2 your clients require, then plan one programme with owners and dates. Under Sterling OS™ you choose Design™, where your team implements with Sterling's structure and coaching, or Drive™, where Sterling consultants take on the agreed work with your people. The evidence lives in Effivity, included with the engagement at no additional cost, and Sustain™ keeps it current. We ensure a successful GDPR compliance programme for our clients. Sterling gives no legal advice and does not certify or issue reports: accredited certification bodies and licensed CPA firms do.
Book a free discovery callCommon mistakes when comparing them
- Buying a certificate to solve a legal problem. A client asking about transfers wants the decisions and records, not a logo.
- Scoping the certificate away from the personal data. An ISO/IEC 27001 scope that leaves out the support team handling client records answers the wrong question.
- Running three evidence sets. Separate registers for the GDPR, the PIMS and SOC 2 drift apart within months.
- Treating UK clients as covered automatically. The UK GDPR and the amended Data Protection Act 2018 sit alongside the EU text; the GDPR vs UK GDPR guide sets out what differs.
GDPR, ISO 27701, ISO 27001 and SOC 2: questions buyers ask
Is ISO 27701 better than ISO 27001 for GDPR?
For the privacy duties, yes: ISO/IEC 27701 addresses controller and processor obligations and maps to the Regulation, while ISO/IEC 27001 mainly evidences the Article 32 security measures.
Do we need ISO 27001 before ISO 27701?
Not under the 2025 edition, which is a standalone standard. The 2019 edition could only be certified as an extension of an ISO/IEC 27001 certificate, and a three-year transition from it is under way.
Does a SOC 2 report with the privacy category cover the GDPR?
No, the privacy category tests your controls against your own notice and commitments, not against the Regulation. It can support GDPR evidence, but it does not replace the record of processing, DPIAs or transfer safeguards.
Will European clients accept a SOC 2 report instead of ISO 27701?
It depends on the client: SOC 2 is the report North American security teams ask for most, while many international buyers name ISO certificates in questionnaires and tenders. Ask each client which assurance it accepts before committing to a route.
Which should a processor serving EU clients do first?
The GDPR programme comes first, because the duties apply today. ISO/IEC 27701 can be built alongside it on the same records, with ISO/IEC 27001 or SOC 2 added when clients ask.
More GDPR guides
Every guide in the GDPR series is written for one question and links back to the hub for the whole picture.
- Data subject access request process
- GDPR compliance step by step
- GDPR compliance cost: what moves the price
- GDPR documentation: records, notices, contracts and DPIAs
- Effivity for the GDPR: the guide
- GDPR internal audit: planning, conduct and reporting
- GDPR requirements explained, article by article
- GDPR training: who needs what, and the evidence
- GDPR vs ISO/IEC 27701, ISO/IEC 27001 and SOC 2
- GDPR vs UK GDPR: what differs and what does not
Keep exploring
Explore more about GDPR
Watch a video on how to comply with GDPR here.
Watch a video on GDPR requirements here.
GDPR resources
Services for GDPR
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