ISO/IEC 27701 Clauses 4–10 (how to implement)

ISO/IEC 27701 follows the standard ISO management-system structure: clauses 4–10 describe how to run a privacy information management system (PIMS). This page is not a restatement of the standard — it’s a practical guide to what teams implement and what evidence tends to exist.

Two anchors to keep in mind

• Privacy governance is operational. Policies matter, but audits are won on records: decisions, approvals, and evidence.
• Controller vs processor matters. Many privacy obligations depend on your role, so scope and roles must be explicit.

A quick map: clause → typical outputs

Clause	What you’re putting in place	Typical outputs (examples)
4 Context	Privacy scope and expectations	PIMS scope statement, processing context, interested parties
5 Leadership	Accountability and direction	privacy policy, roles (DPO/privacy lead), decision authorities
6 Planning	Privacy risk method and objectives	privacy risk assessments, treatment decisions, privacy objectives
7 Support	People and documented information	training/awareness, document control, communications
8 Operation	Repeatable privacy operations	control execution records, supplier/subprocessor governance, incident handling
9 Performance evaluation	Assurance cadence	monitoring, internal audit, management review
10 Improvement	Fix and learn	corrective actions, continual improvement backlog

Frameworks

EU AI ActRegulatory

ISO 42001Standard

Requirements

Art. 9.1Risk management

Art. 10.2Data governance

6.1.1Risk assessment

Controls

Risk assessment processReusable

Data validation checksReusable

Components

Risk identification

Impact analysis

Evidence

Risk registerDocument

Test resultsArtifact

Requirements preserve the source structure

Controls are reusable across frameworks

Evidence attaches to components (sub-claims)

Clause 4 — Context of the organization

Goal

Define privacy scope you can defend: what processing is in scope, which systems and vendors matter, and which obligations apply.

What to implement

• A clear PIMS scope statement (systems, processes, vendors, regions, data types).
• Interested parties and obligations (legal, contractual, customer requirements).
• Role clarity (controller/processor) where relevant.

What evidence tends to look like

• Scope statement + exclusions rationale.
• Processing context documentation (data flows, retention boundaries, vendor landscape).

Common pitfalls

• Scope defined at “company level” only, with no tie to systems and processing reality.
• Role ambiguity that makes obligations impossible to explain consistently.

Clause 5 — Leadership

Goal

Make privacy governance real: leadership commitment, policy direction, and explicit responsibilities.

What to implement

• A privacy policy that binds decisions (not just aspirational language).
• Roles and authorities (who approves risk acceptance, exceptions, and disclosures).
• Governance cadence for privacy decisions and incidents.

What evidence tends to look like

• Policy approval and periodic review records.
• Decision records for exceptions and risk acceptance.

Common pitfalls

• “Everyone is responsible” instead of explicit authorities.
• Privacy decisions happening in ad hoc channels without traceability.

Clause 6 — Planning

Goal

Turn privacy intent into a plan: privacy risk assessment, risk treatment, and privacy objectives.

What to implement

• A consistent privacy risk assessment method (criteria, cadence, approvals).
• A risk treatment approach (mitigate/avoid/transfer/accept) and a way to track progress.
• Privacy objectives that are measurable and reviewed.

What evidence tends to look like

• Privacy risk assessment records and treatment decisions.
• Objective tracking and review outputs.

Common pitfalls

• Treating assessments as “one and done”.
• Objectives that are not measurable or not connected to decisions.

Clause 7 — Support

Goal

Ensure you can operate privacy governance consistently: competence, awareness, communication, and documented information control.

What to implement

• Privacy competence requirements (including reviewers and approvers).
• Awareness and training mechanisms (role-based where needed).
• Documented information control (versioning, review cadence, access).

What evidence tends to look like

• Training completion records.
• Document register / document control.

Clause 8 — Operation

Goal

Operate privacy controls as a system: execute controls, manage vendors/subprocessors, and keep evidence current.

What to implement

• Operational planning and control for privacy activities (access, retention, deletion, incidents).
• Supplier/subprocessor governance where it affects privacy outcomes.
• Operational cadence for reassessing privacy risks when systems and vendors change.

What evidence tends to look like

• Execution records (reviews, approvals, retention actions, incident records).
• Vendor/subprocessor assessment records and review cadence.

Common pitfalls

• Privacy controls defined but not operated (no cadence, no evidence).
• Vendor governance treated as procurement paperwork, not an operational risk control.

Clause 9 — Performance evaluation

Goal

Prove the PIMS works: monitoring, internal audit, and management review.

What to implement

• Monitoring signals that indicate control effectiveness.
• Internal audit program with sampling and independence.
• Management review as a decision point (with actions).

What evidence tends to look like

• Internal audit plan and audit reports.
• Management review inputs and outputs.

Clause 10 — Improvement

Goal

Close the loop: corrective actions and continual improvement.

What to implement

• Corrective actions with root cause and effectiveness checks.
• An improvement backlog tied to audits, incidents, and monitoring.

What evidence tends to look like

• Corrective action records and verification evidence.
• Improvement plan and completed improvements.

Integrated Management System (IMS) note

ISO/IEC 27701 is commonly operated alongside ISO/IEC 27001 (security) and ISO/IEC 42001 (AI governance). Shared processes (document control, audits, management review, corrective action) can be reused while keeping privacy-specific governance explicit.

Disclaimer

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