A.1.3.2·high·Component: Obligations to PII principalsWhat this control requires
Provide means to meet legal, regulatory and business obligations to PII principals. Implementation: Document obligations, implement mechanisms for access, correction, erasure, objections, portability. Justification: Ensures ability to respond to rights requests and obligations.
In plain English
Provide means to meet legal, regulatory and business obligations to PII principals. In practice, this means you can prove you implement comply with obligations-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 Obligations to PII principals, the assessor will trace your implementation back to the catalogue reference (Annex A A.1.3.2) 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.
- Ensure. Document the trigger, the owner and the cadence.
- Scope: comply with obligations.
Evidence to collect
- Ticketing Workflow.
ticketing_workflowevidence - Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policies, procedures, and registers document the safeguard. Service management or request-handling tickets prove timely handling. Focus: Comply with obligations.
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.
- GDPR Article 9 — Processing of special categories of personal data
- India DPDP Act 2023 DS-005 — Consent Withdrawal Mechanism
- SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
Related controls in ISO/IEC 27701:2025
- Annex A A.1.3.11 — Automated decision obligations
- Annex A A.1.3.6 — Mechanism to object
- Annex A A.1.3.9 — Providing copy
- Annex A A.1.3.10 — Handling requests
- Annex A A.1.3.3 — Information for PII principals
- Annex A A.1.3.5 — Modify/withdraw consent
References
- ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
- Catalogue identifier:
Annex A A.1.3.2
Topics: data protectiongovernance riskprivacy managementpolicy management