A.1.3.5·high·Component: Obligations to PII principalsWhat this control requires
Provide mechanism for principals to modify or withdraw consent. Implementation: Implement withdrawal/modification channels consistent with consent capture; log changes and propagate to third parties. Justification: Jurisdictions may require mechanisms and recording of changes.
In plain English
Provide mechanism for principals to modify or withdraw consent. In practice, this means you can prove you implement modify-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.1.3.5) 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.
- Log. Document the trigger, the owner and the cadence.
- Provide. Document the trigger, the owner and the cadence.
- Scope: modify, withdraw consent.
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: Modify/withdraw consent.
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 DS-005 — Consent Withdrawal Mechanism
- GDPR Article 6 — Lawfulness of processing
- SOC 2 (2017 TSC) P3.2 — Consent Management for Personal Information Collection
Related controls in ISO/IEC 27701:2025
- Annex A A.1.3.2 — Comply with 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.1.2.5 — Obtain & record consent
- Annex A A.1.3.3 — Information for PII principals
References
- ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
- Catalogue identifier:
Annex A A.1.3.5
Topics: data protectiongovernance riskprivacy managementpolicy management