ISO/IEC 27701 guide
ISO 27701 vs ISO 27001: how privacy and security management differ, and how they fit together
ISO/IEC 27001 manages information security; ISO/IEC 27701 manages personal data as a controller or processor, and since 2025 it can be certified on its own. What each covers, where they overlap and when to run both.
Key points
- ISO 27701 vs ISO 27001 is privacy against security: ISO/IEC 27001 manages risks to information of every kind, while ISO/IEC 27701 manages how personal data is collected, used, shared, kept and deleted.
- Since the 2025 edition, ISO/IEC 27701 is an independent management system standard on iso.org, so it can be certified without an ISO/IEC 27001 certificate behind it.
- Both follow the same clauses 4 to 10, which is why an organisation holding one can add the other with one risk method, one document set, one internal audit and one management review.
- Neither certificate replaces the other: an ISMS certificate says little about lawful processing, and a PIMS certificate does not cover information that is not personal data.
ISO 27701 vs ISO 27001: the short answer
The two standards answer different questions about the same organisation. ISO/IEC 27001:2022, with its 2024 amendment on climate change, asks whether you protect the confidentiality, integrity and availability of your information through assessed risks and selected controls. ISO/IEC 27701:2025 examines whether you govern personal data as a controller, a processor or both: why you collect it, on what basis, who receives it, how long you keep it and how you answer the people it describes.
Security is a condition of privacy, not the whole of it. A company can encrypt every database, run access reviews on time and pass an ISMS audit, yet still collect more data than it needs, keep it for years without a reason or pass it to a sub-processor its client never approved. Those are privacy failures that an ISO/IEC 27001 audit is not designed to find. The reverse also holds: a privacy programme with excellent notices and a tidy request log offers little comfort if the systems holding the data are poorly protected.
So the useful question is rarely "which one?" in the abstract. It is which risk your clients, regulators and contracts are asking you to evidence first, and whether the other will follow.
The two standards side by side
| What is compared | ISO/IEC 27001 | ISO/IEC 27701 |
|---|---|---|
| Current edition | ISO/IEC 27001:2022 (edition 3, October 2022) with Amendment 1:2024 | ISO/IEC 27701:2025 (edition 2, October 2025), replacing the 2019 edition |
| Management system | Information security management system (ISMS) | Privacy information management system (PIMS) |
| What it protects | All information in scope: client files, source code, financial records, personal data and more | Personally identifiable information (PII) in scope, across its whole life |
| Whose risk is assessed | Risks to the organisation's information and the systems that process it | Privacy risks to the organisation and to the individuals whose data it processes |
| Controls | 93 Annex A controls in four themes, recorded in a Statement of Applicability | Annex A in three parts: controller controls, processor controls and information security controls for both |
| Roles recognised | No distinction between controller and processor | Controller, processor or both, stated in the scope |
| Certification body accredited under | ISO/IEC 17021-1 and ISO/IEC 27006-1 | ISO/IEC 17021-1 and ISO/IEC 27706 |
| Certification cycle | Stage 1 and Stage 2, annual surveillance, recertification in year three | The same three-year cycle |
| Typical buyers asking | Security questionnaires, tenders, enterprise procurement | Controllers vetting processors, privacy-led tenders and contracts |
| Typical programme length | 4 to 8 months to a certification decision | 3 to 8 months, shorter where an ISMS already runs |
Cost drivers follow the same logic for both: scope, sites, headcount, the maturity of what exists and the certification body's audit days. For ISO/IEC 27701 the processing activities and the roles in scope weigh most; the ISO/IEC 27701 certification cost guide sets out what moves the price.
How the 2025 edition changed the relationship
Until October 2025 the answer to "ISO 27701 or ISO 27001?" was forced. The 2019 edition was written as an extension to ISO/IEC 27001 and ISO/IEC 27002, and the certification rules of the time treated a PIMS certificate as an addition to an ISMS certificate, with the privacy scope sitting inside the security scope. An organisation that wanted privacy certification had to build and certify an ISMS first.
ISO/IEC 27701:2025 removed that dependency. The iso.org entry for the standard now describes it as an independent management system standard that can be used alone, with its own clauses 4 to 10, while noting that it aligns with existing ISO/IEC 27001 systems. Certification bodies audit it under ISO/IEC 27706:2025, which replaced the technical specification that had tied the two certificates together.
Two practical consequences follow. A processor whose clients ask only for privacy assurance can now pursue ISO/IEC 27701 on its own. And an organisation that already holds both certificates is not required to separate them: the PIMS scope can stay aligned with the ISMS scope and be audited alongside it. If you hold a 2019 certificate, the ISO/IEC 27701:2025 transition guide covers the dates accreditation bodies have published and how to plan the move.
Where the two standards overlap and where they part
Both standards use the harmonised structure shared by ISO management system standards, so the clause titles match. What differs is the subject each clause applies to. The table shows what the PIMS asks beyond what an ISMS already provides.
| Clause | What an ISMS already provides | What the PIMS adds |
|---|---|---|
| 4 Context of the organisation | Issues, interested parties, security requirements and an ISMS scope | Your role as controller, processor or both; the privacy laws and contracts that apply; the individuals whose data you process as interested parties |
| 5 Leadership | A security policy, an ISMS lead and risk owners | A privacy policy and an accountable privacy lead |
| 6 Planning | A risk method, a risk register and a Statement of Applicability | Privacy risks judged by their effect on individuals as well as on the business; treatment traced to the Annex A controls for your role |
| 7 Support | Awareness, competence and document control | Competence for the people who answer requests and assess new processing; controlled privacy notices |
| 8 Operation | Risk assessments repeated and controls operated | Records of processing, impact assessments, processor and sub-processor contracts, transfer safeguards, retention and recorded deletion |
| 9 Performance evaluation | Security metrics, internal audit, management review | Privacy measures such as request turnaround and breach response time, audited and reviewed |
| 10 Improvement | Nonconformities and incidents corrected at their cause | Privacy incidents and complaints handled the same way |
The controls
ISO/IEC 27001 sets out 93 controls in organisational, people, physical and technological themes, and you justify each inclusion or exclusion. ISO/IEC 27701:2025 arranges its Annex A differently: controls for PII controllers, controls for PII processors, and a set of information security controls aligned with ISO/IEC 27002 that apply whichever role you hold. That third set is what lets a standalone PIMS protect the data it governs without an ISMS behind it. Where both systems run together, the security controls are implemented once and referenced from both. The Annex A guide explains the controller and processor controls in detail.
Which one, or both?
Start from the demand, not the standard. Four situations cover most organisations we meet.
Clients send security questionnaires and name ISO/IEC 27001
Begin with the ISMS. It answers the widest range of due diligence, covers information that is not personal data, and gives you the risk method and audit programme a PIMS can later reuse.
You process personal data for clients, and their contracts ask about privacy
A processor handling payroll, customer records or patient data for others is judged on whether it follows instructions, controls sub-processors, supports rights requests and deletes on exit. ISO/IEC 27701 speaks directly to those questions. If security is also questioned, run both; if not, a standalone PIMS is now a legitimate route. The PII controller or processor guide helps settle the role your certificate should state.
You already hold ISO/IEC 27001
Adding ISO/IEC 27701 is the natural next step when privacy questions start arriving. The work is the privacy layer: mapping the data, deciding lawful bases, building request, impact assessment, retention and deletion processes, and bringing contracts into line.
You hold neither, and both are being asked for
Build them together as one system rather than one after the other. Designing the risk method, document control and audit programme once for both avoids reworking the ISMS a year later.
Running ISO/IEC 27001 and ISO/IEC 27701 as one system
An integrated system keeps one risk register in which each risk is judged for its security consequence and, where personal data is involved, for its consequence to the people concerned. It keeps one document control, one training plan, one internal audit programme that samples both sets of controls, and one management review with privacy and security measures on the same agenda. Scopes should be written so that the PIMS scope sits within the ISMS scope, or matches it, which keeps sampling and evidence simple.
A certification body accredited for both can audit them in a combined visit. Whether that shortens the total audit days depends on the body's own rules for your scope, so ask for the calculation in writing. The ISO/IEC 27001 integration guide covers running several standards on one frame.
How Sterling runs both standards
One programme for privacy and security, with evidence that serves both audits
Sterling's expert and experienced consultants start with a gap analysis against both standards, then build a single risk method, document set and audit calendar with your privacy, legal and IT owners, through Design™ or Drive™, whichever suits your team. Effivity holds the records of processing, the risk register and the Statement of Applicability in one place, and is used in 50+ countries. We ensure successful certification for our clients. Sterling does not certify; an accredited certification body audits and decides.
Book a free discovery callCommon mistakes when choosing between them
- Treating an ISO/IEC 27001 certificate as proof of privacy management. Clients reviewing a processor will ask about sub-processors, retention and rights requests, and the ISMS certificate does not answer them.
- Assuming ISO/IEC 27701 still needs an ISO/IEC 27001 certificate. That was true under the 2019 edition; plan on the 2025 rules and confirm them with your certification body.
- Writing two scopes that do not meet. A PIMS scope covering services the ISMS scope leaves out complicates the combined audit and confuses clients reading both certificates.
- Running two risk registers. Separate methods for security and privacy produce conflicting ratings for the same system and double the maintenance.
- Choosing a certification body without checking its accreditation for ISO/IEC 27706. Accreditation for ISO/IEC 27001 alone does not cover PIMS certification.
ISO 27701 vs ISO 27001: questions buyers ask
Does an ISO 27001 certificate show that we protect personal data properly?
Only in part. It shows that personal data, like other information in scope, is protected by managed security controls. It does not show why you collect the data, whether you keep it longer than needed, how you handle rights requests or how you control sub-processors, which is what ISO/IEC 27701 addresses.
Will an ISO 27701 certificate replace our ISO 27001 certificate?
No. A standalone PIMS includes information security controls for the personal data it governs, but it does not cover information that is not personal data. Clients and tenders that ask for ISO/IEC 27001 will still expect that certificate.
If we already hold ISO 27001, how much extra work is ISO 27701?
Much less than starting from nothing, because the risk method, document control, internal audit and management review already exist. The new work is the privacy layer: the data inventory, lawful bases, notices, requests, impact assessments, contracts, transfers, retention and deletion.
Can one certification body audit ISO 27001 and ISO 27701 together?
Yes, if it is accredited for both, under ISO/IEC 27006-1 for the ISMS and ISO/IEC 27706 for the PIMS. Ask it to state the audit days for each standard and for the combined visit, and confirm the accreditation in the accreditation body's directory.
Can our ISO 27701 scope differ from our ISO 27001 scope?
Under the 2025 edition the PIMS has its own scope, so it can differ. Keeping it within or equal to the ISMS scope makes a combined audit simpler and gives clients a consistent picture across both certificates.
Is ISO 27701 harder to implement than ISO 27001?
It is different rather than harder. The difficulty usually lies in finding out what personal data the organisation holds and why, and in changing contracts and notices, which needs legal and business owners as much as IT.
More ISO/IEC 27701 guides
Every guide in the ISO/IEC 27701 series is written for one question and links back to the hub for the whole picture.
- ISO/IEC 27701:2025: what changed and how to transition
- Annex A: controller, processor and security controls explained
- ISO/IEC 27701 certification process, step by step
- PII controller or PII processor: scoping your PIMS
- ISO/IEC 27701 certification cost: what moves the price
- ISO/IEC 27701 and data protection law: evidencing accountability
- Effivity for ISO/IEC 27701: the guide
- ISO/IEC 27701 internal audit: planning, conduct and reporting
- ISO/IEC 27701 requirements explained, clause by clause
Keep exploring
Explore more about ISO/IEC 27701
Watch a video on how to implement ISO 27701 here.
Watch a video on ISO 27701 requirements here.
ISO/IEC 27701 resources
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