ISO/IEC 27701:2025·Annex A A.1.2.3·high·Component: Conditions for collection and processing

What this control requires

The organization shall determine, document and be able to demonstrate compliance with the relevant lawful basis for processing PII. Implementation: Record lawful basis per processing activity; update when purpose changes. Justification: Needed to demonstrate lawfulness per jurisdiction.
— ISO/IEC 27701:2025, Annex A A.1.2.3

In plain English

The organization shall determine, document and be able to demonstrate compliance with the relevant lawful basis for processing PII. In practice, this means you can prove you implement identify lawful basis-level controls on a defined cadence.

Why it matters

ISO 27701 is the international way to evidence the GDPR principle of accountability: certified PIMS controls translate directly into the records, contracts and rights-handling that supervisory authorities want, and into the privacy-engineering evidence SOC 2 + Privacy auditors and enterprise procurement teams ask for.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

PIMS auditors expect ISO 27001 to be implemented first and then the 27701-additional controls tested. For PII controllers they look at lawful-basis and rights-handling evidence; for PII processors they look at customer-instructions, sub-processor controls and return/transfer/disposal evidence.

Within Conditions for collection and processing, the assessor will trace your implementation back to the catalogue reference (Annex A A.1.2.3) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

  • Implement. Document the trigger, the owner and the cadence.
  • Document. Document the trigger, the owner and the cadence.
  • Record. Document the trigger, the owner and the cadence.
  • Scope: identify lawful basis.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Focus: Identify lawful basis.

Common pitfalls

  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in ISO/IEC 27701:2025

References

Topics: governance riskdata protectionprivacy managementpolicy management