NQA ISO 27701 Implementation Guide

ISO/IEC 27701
IMPLEMENTATION GUIDE
50,000
GLOBALLY
CERTIFICATES 90TRANSPARENT

Since 2016, within a relatively short period, Data Protection
legislation has been passed both in the UK and in the EU
which shaped the requirements necessary to ensure the
privacy of personal data which is taken by organisations.
Both the EU General Data Protection Regulation (GDPR) and
UK Data Protection Act 2018 (DPA) are now applicable to all
organisations, regardless of sector, in the United Kingdom. The
relative speed at which this legislation has been established has
left some organisations unable to adequately respond, and well
publicised breaches have occurred.
Despite the well signposted roll out of both pieces of legislature,
neither regulation provides specific guidance on what measures
should be taken to ensure compliance with their requirements.
Further, existing standards do not have, in most cases, a robust
enough set of clauses or controls to ensure data privacy is
addressed in full through implementation of management
systems.
The International Organisation for Standardisation (ISO) and
the International Electrotechnical Commission (IEC) have
developed a new standard to provide the necessary guidance
for businesses to effectively address data privacy and ensure
the gap between existing management systems requirements
and privacy data legislation is effectively bridged.
MANAGING PERSONAL
INFORMATION WITH
ISO/IEC 27701
GDPR – An overview of legislation
The GDPR was adopted by the EU in April 2016 and
replaced the EU Data Protection Directive 95/46/EC.
This new legislation has initiated obligations to any
organisation with data processing responsibilities, and
is applicable to organisations outside of the EU too. The
penalties for failure to comply can be severe. Fines of up
to 4% of annual global turnover or €20million await any
organisation which breaches the legislation.
Primarily the goal can be perceived as being an EU data
privacy harmonisation. As previously mentioned any
non-EU entity offering goods or services to individuals
located in the EU are also bound by the requirements
of the GDPR. Business sectors with sizeable personal
data processing requirements are uniquely affected and
ensuring conformity to the legislation is paramount.
Organisations are required to confirm explicit and
unambiguous consent from customers, based on specific
purposes for use of their data and for specific periods
of time. Individuals have the right to request a copy of
all data that is held on them, including an explanation of
how such data is used and if third parties have access.
Individuals may request for their data profile to be passed
to another data processor; furthermore, individuals also
have the right to withdraw consent and to request for
data that is no longer required to be erased.
Data responsible processes or individuals are now
required to have appropriate security controls in
place to ensure confidentiality of the data they hold or
process and have mechanisms in place to measure that
effectiveness.
Notifications of data breaches must be submitted to the
supervisory authority; for the UK this is the Information
Commissioners Office (ICO) within 72 hours of
recognition of a breach being identified. The ICO is the
UK’s independent authority set up to uphold information
rights in the public interest, promoting openness by
public bodies and data privacy for individuals. Further
international data transfer rules from the Data Protection
Directive are continued within the GDPR. Personal
data can be transferred outside of the EU, but only to
countries which are considered to have comparable
protection mechanisms.
Further guidance can be found through the UK
Government Data Protection Act 2018 page.

WHAT IS ISO 27701 AND WHY IS IT NEEDED?
As previously indicated there has been no guidance on how
to effectively implement processes within an organisations
existing structure to adhere to GDPR. ISO 27701:2019
is a privacy extension to the international information
security management standard, ISO 27001
(ISO 27701 Security techniques – Extension to
ISO 27001 and ISO 27002 for privacy information
management – Requirements and guidelines).
ISO 27701 details the requirements for and gives the
required guidance for the establishment, implementation,
maintenance and improvement of a Privacy Information
Management System (PIMS). The standard is based
on the requirements, control objectives and controls of
the ISO 27001 standard, and includes a suite of privacy
requirements, controls and control objectives.
Concepts of information safety are familiar to organisations
which already have an operational Information Security
Management System (ISMS). The new PIMS will ensure
that organisations have comprehensive and universal
data governance which directly map to the legislative
requirements.
Instances of GDPR breaches have been well publicised
and have affected organisations with both national and
global mandates. A recent Capgemini report outlines that
up to 70% of all organisations believe that they are not
currently compliant to GDPR requirements. The severity
of the penalties which organisations attract through non-
compliance has necessitated the creation of this standard.
BOLT ON TO ISO 27001
ISO 27701 differs slightly in that the standard requires
an existing management system to attach to. Not every
clause and control is applicable in all instances.
The requirements of the standard are split in to the four
groups listed below:
1. PIMS requirements related to ISO 27001 are outlined
at clause 5
2. PIMS requirements related to ISO 27002 are outlined
at clause 6
3. PIMS guidance for Personally Identifiable Information
(PII) Controllers are outlined at clause 7
4. PIMS guidance for PII Processers are outlined at
clause 8
Additionally, applicable controls are outlined within Annex
constructs to the main body of the standard.
The following can be used as a guide for relevance:
1. Annex A lists all applicable controls for PII Controllers.
2. Annex B lists all applicable controls for PII Processors.
3. Annex C maps the provisions of ISO 27701
against ISO 29100.
4. Annex D maps the provisions of ISO 27701
against the GDPR.
5. Annex E maps the provisions of ISO 27701
against ISO 27018 and ISO 29151
6. Annex F provides guidance for applying ISO 27701
to ISO 27001 and ISO 27002.
In most circumstances, organisations with existing certification
to ISO 27001 should start at Annex F to understand how the
application of PIMS fits in to their existing ISO 27001 ISMS. This
annex refers to three instances for application of the standard to
protection of privacy of PII principals when processing PII:
• Application of security standards as is
• Additions to security standards
• Refinement of security standards
The clause areas within PIMS extend the requirements of
ISO 27001 to incorporate PII considerations. Clause 5 provides a
PIMS-specific guidance set concerning the information security
requirements in ISO 27001 appropriate to an organisation which
acts as either a PII controller or processor.
The sub-clauses outline detailed requirements. This is perhaps
the most pertinent area for those with existing ISMS to consider
and dwell on requirements.

Detailed below are the additional considerations within clause 5 of the ISO 27701 standard which may be observed as extra
to existing ISMS requirements:
5.1 The requirements of ISO 27001 must be extended to the protection of privacy as potentially affected by the
processing of PII. A glance at Annex F provides a table which gives visual indication of how this will look.
5.2.1 An additional requirement to ISO 27001 clause 4.1 is to outline that an organisation will determine its role as a PII
Controller and/or processer. Additionally external and internal factors that are relevant to context and affect the ability
to achieve outcomes of its PIMS require indication. This includes any relevant legislation adherence already in place
as a consideration within the existing ISMS or contractual requirements which hitherto had been identified in differing
clauses or Annex controls within ISO 27001.
Where an organisation has both PII controller and PII processor roles identified, separate roles must be determined, each
of which will be subject to a separate control set.
5.2.2 A consideration extra to ISO 27001 clause 4.2 is the requirement to include interested parties with responsibilities
associated with the processing of PII. This can include customers, which again is not something which may have
previously been considered in an ISO 27001 ISMS. Additionally requirements which are relevant to the processing of
PII can be determined by legal requirements, contractual obligations or self-identified objectives.
5.2.3 The scope of the ISMS is required by ISO 27001 clause 4.3. Additional PIMS factors for scope include an
organisation including processing of PII. PIMS scope determination, therefore, can require a revision of the ISMS
because of the extension to interpretation of what constitutes information security in ISO 27701 clause 5.1.
5.2.4 Further to ISO 27001 clause 4.4 an organisation is required within the new standard to establish, implement,
maintain and continually improve a PIMS in accordance with the requirements of ISO 27001:2013 Clauses 4 to 10,
extended by the requirements in Clause 5.
5.3 Within ISO 27001, organisations are required to demonstrate commitment to the ISMS through leadership initiatives
and the creation of policies, roles responsibilities and guidance. Likewise, the PIMS requires a similar input from
the top management along with relevant PIMS specific interpretations as indicated at 5.1 to ISO 27701 which covers
all mirrored aspects of clause 5 of the ISMS.
5.4.1 The requirements of ISO 27001 to address risks and opportunities require augmentation with the considerations
of clause 5.1 in ISO 27701. Furthermore, Information Security risk assessments identified within ISO 27001 are
applicable with the following additional requirements:
1. The organisation shall apply the information security risk assessment process to identify risks associated with the
loss of confidentiality, integrity and availability, within the scope of the PIMS.
2. The organisation shall apply privacy risk assessment process to identify risks related to the processing of PII,
within the scope of the PIMS.
3. The organisation shall ensure throughout the risk assessment processes that the relationship between information
security and PII protection is appropriately managed.
This can be an integrated risk assessment process or parallel processes which are controlled separately; this
depends entirely on the organisation to determine.
Additionally, ISO 27001 clause 6.1.2.d is refined to include an assessment for potential consequences for both
the organisation and PII principals that would result if the risks identified during the 6.1.2.c (ISO 27001) were to
materialise.
Further considerations are given to the Statement of Applicability which would have been generated by the
organisation when implementing the ISO 27001 ISMS. As an organisation would have encountered an “opt out
and justify” approach to produce the SoA in the first instance, likewise for the PIMS, not all control objectives and
controls listed within Annex areas need to be included during PIMS implementation. Justification for exclusion where
controls are not deemed necessary can be identified.
5.4.2 Information security objectives from the organisations ISMS from clause 6.2 augmented by the interpretation of
ISO 27701 clause 5.1 must be considered.
5.5 Support considerations from ISO 27001 at clause 7 are applicable along with the additional interpretation specified
within ISO 27701 clause 5.1.
5.6 Operational consideration from ISO 27001 at clause 8 including risk treatment planning are similarly required by
ISO 27701 along with additional information which is identified through addressing clause 5.1 to the latter standard.
5.7/5.8 Similarly; the Monitoring/Measuring Improvement considerations which are live within an existing ISMS require
further augmentation from the considerations given to clause 5.1 to ISO 27701.
The processes identified above indicated that clause 5.1 to the new standard is a key point to the
implementation of a PIMS. The extension to the protection of privacy as potentially affected by the
processing of PII is a key element to implementation and guides the consideration given when addressing
the further clause areas of ISO 27701.
ADDITIONAL CONSIDERATIONS

The following table provides a simple overview of the information on the previous page:
ISO 27001 Clause ISO 27701 Extension
5.1
5.2
5.3
7.1
7.4
Top Level Commitment for Privacy Policy and integration of PIMS to the ISMS of an organisation including:
1. Resourcing/Establishment of Roles
2. Communication (Internal/External)
3. Anticipated outcome
4. Control and Guidance
5. Continual Improvement of PIMS
6.2 PIMS/Privacy Objectives
7.2 Competency profiles of individuals assigned to privacy requirements
7.3 Awareness of the PIMS policy and how personnel contribute to the establishment and improvement of the
system
7.5 Documentation for PIMS with additional considerations on information and documentation non-organic to the
organisation.
8.1 PIMS Risk Treatment activation
8.2 PIMS Risk Assessment process
8.3 PIMS Risk Treatment Plan including amendments to existing risk registers
9.1
9.2
9.3
PIMS Performance and analysis of PIMS effectiveness including:
1. Internal Audit
2. Management Review
10 PIMS Continuous Improvement considerations
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NQA ISO 27701 Implementation Guide

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