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ISO/IEC 27701:2019 ANNEX D · EU GDPR
ISO 27701:2019 · Annex D

ISO 27701 &
the GDPR

ISO 27701 was designed to align with the GDPR. Its Annex D maps each control to specific articles, so a Privacy Information Management System gives you much of the accountability evidence the regulation expects — without a bespoke audit each time.

Certification is evidence of alignment, not a legal ruling that you are GDPR compliant.

Annex DGDPR control mapping
Art. 5(2)Accountability supported
DPDPAlso supported

ISO/IEC 27701:2019 Annex D · EU GDPR · Last reviewed June 2026

  • 21K School
  • Arali AI
  • Assemblage Health
  • Cargoflash
  • Data Alchemy
  • Dsider
  • Factor Avenue
  • GroundHog Apps
  • immiOne
  • IPPC Group
  • LiveMindz
  • Lyik
  • NPCI
  • Phyllo
  • Softsages
  • Surface Labs
  • Vault Infosec
  • Xonar
  • Harriman Global
  • Dune Dynamics
  • Aairo
  • Ardem
  • autoResilience
  • Citius Cloud
  • Datavi Cloud
  • eSolutions
  • Forsys
  • HighRadius
  • Intellify
  • Jarex
  • LookDeep Health
  • Mashreq
  • PayU
  • Provar
  • Soudah Development
  • TalentBridge
  • VisiLean
  • Zepic
  • Procedure
  • incep²t
  • American Express
  • Ascent Risk & Resilience
  • Auxanova
  • Cohivra
  • DollarTraq
  • Excers Technologies
  • Girmiti
  • IIIT Delhi
  • intelXIP
  • Komp AI
  • Loveinstore
  • Maxima
  • Personaify
  • Sebone Technologies
  • Spinny
  • Uni5
  • WyraAI
  • JudoNxt
  • BuyNxt · Green Receipt
Direct Answer

How the mapping works

Annex D of ISO 27701 sets out a clause-by-clause correspondence between the standard’s requirements and the articles of the GDPR. Where the regulation states an obligation, the annex points to the PIMS control that operationalises it — so the work you do to satisfy ISO 27701 is the same work that evidences GDPR accountability. It does not replace legal advice, but it gives you a certified, repeatable system rather than a one-off compliance exercise.

Key Takeaways

  • Annex D maps ISO 27701 controls to specific GDPR articles, so a PIMS evidences accountability under Article 5(2).
  • The same controls support lawful basis, data subject rights, records of processing, privacy by design, breach response, and international transfers.
  • Certification is assurance of alignment — not a legal ruling that you are GDPR compliant.
  • Because the controls are regulation-agnostic, one PIMS also supports India’s DPDP Act and other privacy regimes.
What it supports

GDPR obligations a PIMS supports

Lawful basis & consent

PIMS controls require you to identify and document a lawful basis for each processing activity and to manage consent — directly supporting GDPR Articles 6 and 7.

Data subject rights

Controls for access, correction, erasure, and objection give you a repeatable way to handle the PII principal rights set out in GDPR Articles 12–22.

Records of processing

A PIMS maintains records of processing activities — the Article 30 documentation regulators ask for first in an enquiry.

Privacy by design & default

Data minimisation, purpose limitation, retention, and secure disposal controls operationalise GDPR Article 25.

Breach response

The underlying ISO 27001 incident process, extended for privacy, supports the breach-notification duties in GDPR Articles 33 and 34.

International transfers

Controls for the basis, recording, and disclosure of cross-border PII transfers map to the Chapter V transfer requirements.

Proof

In their words.

Quotes verbatim from G2. Company names added where the client confirmed them.

Verify on G2
They expertly mapped the overlapping controls between SOC 2 and ISO 27001, which saved us from duplicating work.
Jasreet Kaur B.Silicon Physical Design Engineer · Small-BusinessSOC 2 + ISO 27001 · August 2026
Instead of simply providing generic templates or checklists, their team took the time to understand our environment and requirements.
Anand .Market Risk Analyst · Mid-MarketCompliance readiness · September 2026
The team’s willingness to work with us and ease of communication.
sam v.CEO · Small-BusinessSOC 2 Type I + ISO 27001 · August 2026
They delivered the project with speed, accuracy, and cost-effectiveness.
Maneet P.Mid-MarketSOC 2 · August 2026
My only regret is that we didn’t engage them sooner in our compliance journey, which would have saved us even more time.
Mahesh Raju C. · XonarSmall-BusinessSOC 2 · GRC · August 2026
They were always responsive and willing to go the extra mile whenever we had questions or needed guidance.
Chandan J. · DsiderSmall-BusinessSOC 2 Type I · August 2026
Managing the auditor relationship on our behalf was especially valuable — it took a lot of pressure off our internal team.
Achyut B.Senior Software Engineer · Small-BusinessSOC 2 + ISO 27001 · September 2026
Their focus on ensuring that we were genuinely audit-ready rather than simply completing documentation.
Ravi V.Founder & CEO · Mid-MarketSOC 2 Type II · August 2026
The guidance was not generic or simply based on a standard checklist — they suggested practical approaches that made sense for our business.
Verified UserInternational Trade and Development · Small-BusinessSOC 2 + ISO 27001 · September 2026
What I like best is the hands-on support and clear guidance throughout the SOC 1 and SOC 2 process.
Sai Sudha S. · ExcersSmall-BusinessSOC 1 + SOC 2 · September 2026

Frequently Asked Questions

Common questions about ISO 27701 and the GDPR.

Does ISO 27701 cover the GDPR?
ISO 27701 was written to align with the GDPR. Annex D of the standard provides a clause-by-clause mapping between its controls and specific GDPR articles, so implementing a PIMS produces much of the operational evidence the regulation expects.
Is ISO 27701 certification the same as being GDPR compliant?
No. GDPR compliance is a legal status that only a supervisory authority or court can ultimately determine. ISO 27701 certification is independent assurance that you operate a privacy management system aligned with the regulation — strong evidence of accountability, but not a legal ruling.
We already process EU data. Why add ISO 27701?
A certificate gives customers and regulators third-party assurance without a bespoke audit each time. It turns "we follow the GDPR" into something an external body has verified, which shortens vendor security reviews and supports Article 5(2) accountability.
Does ISO 27701 also help with other privacy laws, like India’s DPDP Act?
Yes. Although Annex D maps to the GDPR, the same PIMS controls — lawful processing, principal rights, records, and breach handling — map closely to the duties in other privacy laws such as India’s DPDP Act, so one programme can support multiple regimes.

Continue your ISO 27701 research

Written By Expert Auditors

Surendra Pal SinghChief Information Security Officer & Data Protection OfficerCISODPOCISAMCSEITILISO 27001 Lead AuditorISO 27701 Lead AuditorISO 42001 Lead Auditor
Saundhi ChauhanLead AuditorISO 27001 Lead AuditorISO 27701 Lead AuditorISO 42001 Lead Auditor
Last reviewed: June 2026 • Content verified by certified lead auditors

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