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ISO/IEC 27701:2019 ANNEX B · FOUR CONTROL THEMES
ISO 27701:2019 · Annex B

PII
processor controls

If you process personal data on behalf of your customers, you are a PII processor. ISO 27701 Annex B adds the privacy controls for that role — built around acting only on documented instructions.

The defining principle is processing only on documented instructions — never for your own purposes.

4Annex B control themes
B.8.2–8.5Control reference
ProcessorRole covered

ISO/IEC 27701:2019 Annex B · PII processors · Last reviewed June 2026

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Direct Answer

What are the processor controls?

A PII processor handles personal data on a controller’s behalf and does not decide the purpose of processing. ISO 27701 Annex B adds the privacy controls specific to that role, grouped under four themes — all anchored in acting on the controller’s documented instructions, managing sub-processors, and returning or disposing of PII when the engagement ends.

Key Takeaways

  • Annex B applies to PII processors — organisations that handle personal data on a controller’s behalf.
  • The defining principle is processing only on the controller’s documented instructions, never for your own purposes.
  • Controls span records, return and disposal of PII, transmission security, and authorised sub-processor management.
  • Certification answers most of the privacy section of enterprise vendor security reviews with independent evidence.
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 the ISO 27701 processor controls.

Who needs the ISO 27701 processor controls?
Any organisation that processes personally identifiable information on behalf of another party — a SaaS vendor, a BPO, a managed-service or offshore development provider. These are the PII processor controls in Annex B. If you also decide why data is processed, you apply the Annex A controller controls too.
What is the core principle for a PII processor?
Acting only on the controller’s documented instructions. A processor does not decide the purpose of processing and must not use PII for its own ends — Annex B builds the records, contracts, and sub-processor controls that make that demonstrable.
How does this help us win enterprise customers?
Enterprise buyers increasingly require privacy assurance from their vendors. An ISO 27701 certificate covering the processor controls answers most of the privacy section of a vendor security review with independent evidence rather than a questionnaire.

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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