ISO/IEC 27701:2025·Annex A A.3.31·high·Component: Security considerations

What this control requires

Protect and manage test information related to PII processing; avoid use of real PII where possible. Implementation: Use synthetic data or equivalent protections; document selection and controls. Justification: Prevents leakage of PII through test environments.
— ISO/IEC 27701:2025, Annex A A.3.31

In plain English

Protect and manage test information related to PII processing; avoid use of real PII where possible. In practice, this means you can prove you implement test information-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.3.31) 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.
  • Document. Document the trigger, the owner and the cadence.
  • Protect. Document the trigger, the owner and the cadence.
  • Scope: test information.

Evidence to collect

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

Signed policies, procedures, and registers document the safeguard. Focus: Test information.

Common pitfalls

  • CI security checks set to warn-only; the merge button is faster than the security feedback.

Related controls in ISO/IEC 27701:2025

References

Topics: data protectionsecure developmentdata loss prevention