ISO/IEC 27701:2025·Annex A A.3.22·high·Component: Security considerations

What this control requires

Protect PII on or accessible via user endpoint devices. Implementation: Endpoint controls, MDM, encryption and policies. Justification: Mobile and endpoints are high-risk vectors for PII compromise.
— ISO/IEC 27701:2025, Annex A A.3.22

In plain English

Protect PII on or accessible via user endpoint devices. In practice, this means you can prove you implement user endpoint devices-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.3.22) and look for objective evidence on the latest two assessment cycles.

How to implement

Endpoint Protection

MDM. Make MDM enrollment a hard gate for device access (Intune compliance + Conditional Access, or Jamf + Okta device trust). Unmanaged devices simply don't get a session token.

EDR. Deploy CrowdStrike / SentinelOne / Defender for Endpoint to every server and laptop; alert on any host that stops sending telemetry for >24h.

Operational checklist

  • Implement. Document the trigger, the owner and the cadence.
  • Encrypt. Document the trigger, the owner and the cadence.
  • Protect. Document the trigger, the owner and the cadence.
  • Scope: user endpoint devices.

Evidence to collect

  • User Device Scan. MDM compliance state per user device (Intune / Jamf / Workspace ONE).
  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policies, procedures, and registers document the safeguard. Endpoint/MDM telemetry proves device-side controls. Focus: User endpoint devices.

Common pitfalls

  • Pilot MDM rollouts that quietly exclude executives or engineers; carving out the highest-risk users is the most common audit failure.

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.

References

Topics: endpoint securityendpoint protection