Privacy Management
with ISO 27701

ISO/IEC 27701:2019 is an extension to ISO/IEC 27001 and ISO/IEC 27002 that adds Privacy Information Management System (PIMS) requirements. It provides additional controls for managing personally identifiable information (PII) as a controller and/or processor. Per ISO, organizations must hold (or pursue in parallel) ISO 27001 certification to achieve ISO 27701 certification, because the PIMS extends the underlying ISMS.

ISO 27701 includes a published mapping to the EU GDPR. It operationalises records of processing activities (Article 30), data protection by design and by default (Article 25), data protection impact assessments (Article 35), data subject rights, and processor obligations (Article 28). The same PIMS controls — lawful basis, purpose limitation, consent, breach notification and data-principal rights — map cleanly onto India's Digital Personal Data Protection (DPDP) Act 2023. Certification is not automatic legal compliance, but it gives auditors and regulators documented, systematic evidence of privacy governance.

Yes. ISO 27701 is a PIMS extension to ISO 27001 — it cannot be certified standalone. You must either hold a valid ISO 27001 certificate or implement both standards simultaneously. ISO 27701 layers controller-specific (Annex A) and processor-specific (Annex B) privacy controls on top of the ISO 27001 information-security foundation.

ISO 27701 splits its PII-specific requirements into two annexes. Annex A controls (Clause 7) apply to PII controllers — organisations that determine the purposes and means of processing (e.g. deciding what customer data to collect). Annex B controls (Clause 8) apply to PII processors — organisations that process data on behalf of controllers (e.g. SaaS platforms, payroll providers, cloud vendors). Many organisations are both, and the Statement of Applicability must justify which controls apply.

Auditors verify that your data inventory and Records of Processing Activities (RoPA) are complete and current, that a lawful basis is documented for every processing activity, and that data-subject-rights requests (access, rectification, erasure, portability) are handled within statutory deadlines with evidence. They sample Data Protection Impact Assessments for high-risk processing, test data-processing agreements with sub-processors, and review breach-notification runbooks. The PIMS-specific Statement of Applicability and a privacy-focused management review are mandatory artefacts at Stage 1.

Timeline depends on your ISO 27001 status. If you already hold ISO 27001, expect roughly 6–10 months for PIMS implementation and certification. If pursuing both standards together, plan for 12–18 months. The main variables are data-processing complexity, the number of sub-processors and cross-border transfers, organisational size, and existing privacy maturity.

At Tranquility, ISO 27701 engagements are typically indicative of ₹1.5–4 lakhs depending on scope, number of processing activities and whether it is bundled with ISO 27001. This covers consulting (gap analysis, PIMS documentation, RoPA build, internal audit) and certification-body coordination; accredited certification-body Stage 1/Stage 2 and surveillance fees are billed separately by the registrar.