ISO/IEC 27701:2025·Annex A A.3.19·high·Component: Security considerations

What this control requires

Define and enforce clear desk/clear screen rules. Implementation: Publish rules, enforce and audit compliance. Justification: Reduces unauthorized access to PII in physical spaces.
— ISO/IEC 27701:2025, Annex A A.3.19

In plain English

Define and enforce clear desk/clear screen rules. In practice, this means you can prove you implement clear desk-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 Security considerations, the assessor will trace your implementation back to the catalogue reference (Annex A A.3.19) and look for objective evidence on the latest two assessment cycles.

How to implement

Physical Security

Inheritance. For cloud-only operations, inherit physical controls from the provider's SOC 2 / ISO 27001 report and document the inheritance in the SoA.

Operational checklist

  • Implement. Document the trigger, the owner and the cadence.
  • Define. Document the trigger, the owner and the cadence.
  • Publish. Document the trigger, the owner and the cadence.
  • Scope: clear desk, screen.

Evidence to collect

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

Signed policies, procedures, and registers document the safeguard. Focus: Clear desk & screen.

Related controls in ISO/IEC 27701:2025

References

Topics: physical security