ISO/IEC 27701:2025 A.1.2.6 — Privacy impact assessment

What this control requires

Assess need for privacy impact assessment for new or changed processing. Implementation: Define PIA criteria, process and documentation (use ISO/IEC 29134 guidance where applicable). Justification: Required for high-risk processing; supports risk identification and mitigation.

In plain English

Assess need for privacy impact assessment for new or changed processing. In practice, this means you can prove you implement privacy impact assessment-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.1.2.6) 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.
• Define. Document the trigger, the owner and the cadence.
• Document. Document the trigger, the owner and the cadence.
• Scope: privacy impact assessment.

Evidence to collect

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

Signed policies, procedures, and registers document the safeguard. Focus: Privacy impact assessment.

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.

• India DPDP Act 2023 PD-001 — Data Protection Impact Assessment Programme
• NIST SP 800-53 Rev. 5 RA-8 — Privacy Impact Assessments
• SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
• GDPR Article 2 — Material Scope
• NIST SP 800-171 Rev. 3 3.12.1 — Security Assessment

Related controls in ISO/IEC 27701:2025

• Annex A A.1.2.2 — Identify and document purpose
• Annex A A.1.2.3 — Identify lawful basis
• Annex A A.1.2.5 — Obtain & record consent
• Annex A A.1.2.7 — Contracts with PII processors
• Annex A A.1.2.8 — Joint PII controller
• Annex A A.1.2.9 — Records related to processing PII

References

• ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
• Catalogue identifier: Annex A A.1.2.6

Topics: governance riskdata protectionprivacy managementpolicy management