ISO 27701 Blog
2 min

The Compliance Challenges for ISO 27701

Posted by: Ông Nur Kamal Bin Kamari Date: 10 Oct 2023

Implementing a PIMS is a significant undertaking with potential challenges. Addressing these hurdles ensures a successful and seamless implementation. A few common challenges can be categorised into the following:

  • Scoping and Documentation Issues: The implementation of policies, procedures, or systems often faces the common challenge of scoping, which involves defining the specific elements, operations, and personnel encompassed within the system. With ISO 27701 being an extension of ISO 27001, it is crucial to ensure that the Privacy Information Management System's (PIMS) scope does not surpass that of the Information Security Management System (ISMS). Any system or application not included in the ISMS cannot be part of the PIMS either. Additionally, documentation challenges frequently arise during PIMS implementation, such as inadequate documentation of relevant parties and PII principals.
  • Incorrect Documentation of Statement of Applicability: Organisations often include anticipated controls in the Statement of Applicability (SOA), which should only feature current applicable controls. Proper documentation and alignment with risk assessment are crucial for an accurate SOA.
  • Drawbacks in ISO 27701 Risk Assessment: Ensuring the mitigation of PII security risks demands the identification and implementation of relevant controls from Annex A and Annex B of the ISO 27701. Often, companies face challenges in correctly identifying applicable controls based on the nature of their PII. Thus, it is essential to thoroughly identify, analyse, document, and address risks while applying the appropriate ISO 27701 controls within the PIMS.
  • Lack of Internal Audit: After a risk assessment is conducted, it is important to conduct an internal audit if the controls are in place and effective. A management review should also be done to demonstrate management’s commitments towards the implementation of both ISMS and PIMS.

How to implement the ISO 27701 standard?

ISO 27701 implementation guide

While implementation of a successful PIMS is a tedious task, it can be made easier by following the implementation guide mentioned below:

  • Ensuring that an ISMS is already in place or an ISMS is set up simultaneously with the implementation of a PIMS.
  • Defining which personal information, applications, processes and systems will come under the scope for implementation of a PIMS. Proper documentation is essential to ensure that there is a proper Statement of Applicability.
  • It is important to understand the types of risks that the organisation has to deal with in terms of protecting private data and then implementing controls accordingly. Organisations are to identify the applicable controls for ISMS and PIMS.
  • Once the controls are implemented, an internal audit must be conducted, and the senior management must conduct a review of the PIMS while embarking on the certification.
  • Apply for ISO 27701 Certification, our auditors will assess PIMS, identify non-conformities, if any. Organisation will be awarded with the ISO 27701 certification once all of the non-conformities are addressed.
  • It is important to conduct regular reviews to ensure that the PIMS is effective and efficient and modify it if required.

Preserving the privacy of individuals is critical for every company. ISO 27701 plays a pivotal role in fulfilling this duty that will foster a sense of trust among stakeholders. In today's digitally interconnected world, where information is easily accessible, the risk of misuse is significant. Thus, the implementation of ISO 27701 is imperative to safeguard against potential threats and ensure privacy protection.

TÜV SÜD's ISO 27701 certification services provide the best option to organisations aiming to obtain an ISO 27701 certification. Our Awareness Training, Implementer Training, and Internal Auditor Training train an organisation’s employees about the needs and requirements of a PIMS, helps in its implementation and even train personnel on the process of conducting internal audits.

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