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ISO/IEC 27701 annexes (how to use them) ​

ISO/IEC 27701 includes annexes that help you go from “privacy governance requirements” to “operable controls and evidence”.

This page is a guide to using the annexes without turning ISO/IEC 27701 into checklist theatre.

The practical purpose of the annexes ​

Teams use the annexes to:

  • structure a privacy control catalog (and avoid reinventing it)
  • distinguish responsibilities (especially controller vs processor)
  • define what evidence and cadence “operating the control” implies
  • map privacy work to legal obligations (for example GDPR) in a defensible way

Controls reference (Annex A) ​

What it’s for ​

Annex A provides a privacy controls reference that helps you build a PIMS control catalog.

How to use it effectively ​

  • Treat it as a baseline library, not “the list you must implement verbatim”.
  • Make explicit applicability decisions (what applies in your scope, and why).
  • Translate controls into operable work: owners, cadence, evidence expectations, escalation paths.

Common failure mode ​

Copy/paste control statements into a spreadsheet and calling it done.

Implementation guidance (Annex B) ​

What it’s for ​

Annex B provides implementation guidance to help interpret and operationalize the privacy controls.

How to use it effectively ​

  • Use it to break controls into components (sub-claims) that can each be evidenced.
  • Use it to define cadence and “what good looks like” without overbuilding procedures.
  • Use it to align cross-functional execution (engineering, product, legal, risk, vendor management).

Common failure mode ​

Overbuilding: perfect procedures that no one follows.

Mapping annexes (informative) ​

ISO/IEC 27701 also includes informative annexes intended to help with mapping and transition work. In practice, teams use these to:

  • map PIMS controls to privacy principles and legal obligations (for example GDPR)
  • map to related privacy/security standards where relevant
  • understand differences between editions during migration

Treat these annexes as mapping aids, not as a substitute for scoping and legal interpretation.

How this maps into Modulos ​

In Modulos, the annexes usually translate into an execution and traceability layer:

  • privacy controls become controls and components that teams execute and review
  • evidence is linked to the smallest meaningful claim (component) so audits stay precise
  • controls and evidence can be reused across frameworks (e.g., GDPR + ISO 27701 + ISO 27001)

Disclaimer

This page is for general informational purposes and does not constitute legal advice.