ISO/IEC 27701:2025·Annex A A.1.3.9·high·Component: Obligations to PII principals

What this control requires

Be able to provide a copy of processed PII on request. Implementation: Implement export functionality and delivery controls; verify identity before disclosure. Justification: Supports portability / access rights; machine-readable formats recommended.
— ISO/IEC 27701:2025, Annex A A.1.3.9

In plain English

Be able to provide a copy of processed PII on request. In practice, this means you can prove you implement providing copy-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.1.3.9) 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.
  • Provide. Document the trigger, the owner and the cadence.
  • Verify. Document the trigger, the owner and the cadence.
  • Scope: providing copy.

Evidence to collect

  • Ticketing Workflow. ticketing_workflow evidence
  • 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: Providing copy.

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: data protectiongovernance riskprivacy managementpolicy management