They expertly mapped the overlapping controls between SOC 2 and ISO 27001, which saved us from duplicating work.
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.
ISO/IEC 27701:2019 Annex B · PII processors · Last reviewed June 2026
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.
Annex B control themes
Conditions for collection and processing
Process PII strictly within the bounds the controller has set.
- Process PII only on the customer’s documented instructions
- Do not use PII for your own purposes such as marketing
- Flag any instruction that may infringe applicable law
- Keep records that support the controller’s obligations
Obligations to PII principals
Help the controller meet its duties to individuals.
- Assist the controller in meeting its obligations to PII principals
- Pass on access, correction, and erasure requests appropriately
- Support the controller’s response within agreed timelines
Privacy by design and by default
Protect PII through its lifecycle in your environment.
- Control temporary files and intermediate copies of PII
- Return, transfer, or securely dispose of PII as agreed
- Protect PII in transit with appropriate transmission controls
PII sharing, transfer, and disclosure
Govern onward transfer and the engagement of sub-processors.
- Establish the basis for transferring PII between jurisdictions
- Record disclosures and the jurisdictions PII may be disclosed to
- Handle legally binding requests for disclosure correctly
- Engage sub-processors only with authorisation and notify of changes
In their words.
Quotes verbatim from G2. Company names added where the client confirmed them.
Instead of simply providing generic templates or checklists, their team took the time to understand our environment and requirements.
The team’s willingness to work with us and ease of communication.
They delivered the project with speed, accuracy, and cost-effectiveness.
My only regret is that we didn’t engage them sooner in our compliance journey, which would have saved us even more time.
They were always responsive and willing to go the extra mile whenever we had questions or needed guidance.
Managing the auditor relationship on our behalf was especially valuable — it took a lot of pressure off our internal team.
Their focus on ensuring that we were genuinely audit-ready rather than simply completing documentation.
The guidance was not generic or simply based on a standard checklist — they suggested practical approaches that made sense for our business.
What I like best is the hands-on support and clear guidance throughout the SOC 1 and SOC 2 process.
Frequently Asked Questions
Common questions about the ISO 27701 processor controls.
Who needs the ISO 27701 processor controls?
What is the core principle for a PII processor?
How does this help us win enterprise customers?
Continue your ISO 27701 research
- ISO 27701 controller controls (Annex A) — the controls for organisations that decide why and how PII is processed.
- ISO 27701 certification process — the path from gap analysis to the Stage 1 and Stage 2 audits.
- ISO 27701 hub — PIMS overview, controls, and certification in one place.
Related Reading
ISO 27701 (PIMS)
The privacy extension to ISO 27001 — one audit, two certificates.
Read moreController Controls (Annex A)
PII controller-specific controls mapped to GDPR obligations.
Read morePIMS Framework Explained
How the Privacy Information Management System extends an ISMS.
Read moreISO 27701 × GDPR Alignment
How ISO 27701 maps onto GDPR Articles — and what it proves.
Read moreGDPR Compliance
The EU's data protection regulation for any company with EU users.
Read moreBusiness Associate Agreements
What a BAA must contain and when you need one.
Read more

