A.3.3·high·Component: Security considerations (controllers/processors)What this control requires
Define, approve, publish, communicate and review information security policies related to PII processing. Implementation: Develop privacy/security policies (or augment ISMS), review at intervals, record approvals. Justification: Policies show management commitment and provide control framework.
In plain English
Define, approve, publish, communicate and review information security policies related to PII processing. In practice, this means you can prove you implement information security policies-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 (controllers/processors), the assessor will trace your implementation back to the catalogue reference (Annex A A.3.3) 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.
- Define. Document the trigger, the owner and the cadence.
- Provide. Document the trigger, the owner and the cadence.
- Scope: information security policies.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policies, procedures, and registers document the safeguard. Focus: Information security policies.
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.
- ISO/IEC 27001:2022 A.5.1 — Policies for information security
- ISO/IEC 42001:2023 A.2.2 — Policies for the responsible development or use of AI systems
- HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
- GDPR Article 8 — Conditions applicable to child's consent in relation to information society services
- India DPDP Act 2023 SE-005 — Information Security Governance, Training & Audit
Related controls in ISO/IEC 27701:2025
- Annex A A.3.4 — Information security roles & responsibilities
- Annex A A.3.5 — Classification of information
- Annex A A.3.16 — Compliance with policies
- Annex A A.1.3.3 — Information for PII principals
References
- ISO/IEC JTC 1/SC 27 — ISO/IEC 27701:2025
- Catalogue identifier:
Annex A A.3.3
Topics: governance riskpolicy management