A.2.5.6·high·Component: PII sharing, transfer & disclosure (processors)What this control requires
Reject non-legally binding disclosure requests; consult customer; accept contractually agreed disclosures authorized by customer. Implementation: Implement vetting procedures and refusal/consult paths; record decisions. Justification: Prevents unauthorized disclosures and preserves contractual obligations.
In plain English
Reject non-legally binding disclosure requests; consult customer; accept contractually agreed disclosures authorized by customer. In practice, this means you can prove you implement legally binding disclosures-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 PII sharing, transfer & disclosure (processors), the assessor will trace your implementation back to the catalogue reference (Annex A A.2.5.6) and look for objective evidence on the latest two assessment cycles.
How to implement
- Write a short policy stating intent, scope and named owner.
- Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
- Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
- Review on a documented cadence and capture the review in the risk register or compliance tracker.
Operational checklist
- Implement. Document the trigger, the owner and the cadence.
- Record. Document the trigger, the owner and the cadence.
- Authorize. Document the trigger, the owner and the cadence.
- Scope: legally binding disclosures.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
- Vendor Risk Management.
vendor_risk_managementevidence
Signed policies, procedures, and registers document the safeguard. Processor due diligence, contracts, and disclosure registers evidence third-party controls. Focus: Legally binding disclosures.
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.
- SOC 2 (2017 TSC) P6.1 — Third-Party Disclosure with Data Subject Consent
- India DPDP Act 2023 DP-001 — Data Processing Agreements (DPA) - Full Compliance
Related controls in ISO/IEC 27701:2025
- Annex A A.2.5.4 — Records of PII disclosures
- Annex A A.1.5.5 — Records of disclosures
- Annex A A.2.5.2 — Basis for transfer
- Annex A A.2.5.5 — Notification of requests
- Annex A A.2.5.7 — Disclosure of subcontractors
- Annex A A.2.5.8 — Engagement of subcontractor
References
- ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
- Catalogue identifier:
Annex A A.2.5.6
Topics: data protectionvendor riskprivacy managementvendor management