A.3.27·high·Component: Security considerationsWhat this control requires
Establish and apply secure development rules for software/systems handling PII. Implementation: Integrate privacy/security requirements into SDLC, checkpoints and reviews. Justification: Embeds privacy-by-design and reduces vulnerabilities.
In plain English
Establish and apply secure development rules for software/systems handling PII. In practice, this means you can prove you implement secure development life cycle-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.3.27) and look for objective evidence on the latest two assessment cycles.
How to implement
Secure Development
Pipeline. Require code review, SAST (Semgrep / Snyk Code), SCA (Dependabot / Renovate), secret-scanning and IaC scanning in the merge pipeline.
Branch protection. Protected branches enforce reviews, signed commits and passing CI before merge; document the protection rules as the control evidence.
Operational checklist
- Implement. Document the trigger, the owner and the cadence.
- Review. Document the trigger, the owner and the cadence.
- Scope: secure development life cycle.
Evidence to collect
- Code Repo Scan. Source-control evidence — branch protection, required reviewers, CI status, SCA / SAST reports.
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policies, procedures, and registers document the safeguard. SDLC and repository gates evidence secure development. Focus: Secure development life cycle.
Common pitfalls
- CI security checks set to warn-only; the merge button is faster than the security feedback.
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.
- NIST SP 800-53 Rev. 5 SA-18(1) — Multiple Phases Of System Development Life Cycle
- BSI C5:2020 DEV-08 — Version Control
- ISO/IEC 27001:2022 A.8.25 — Secure development life cycle
- ISO/IEC 42001:2023 A.6.1.3 — AI system design and development process
Related controls in ISO/IEC 27701:2025
References
- ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
- Catalogue identifier:
Annex A A.3.27
Topics: secure developmentdevsecops