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Operationalizing ISO/IEC 27701 in Modulos

ISO/IEC 27701 becomes manageable when you treat privacy governance as execution: clear controls, repeatable evidence, and decisions that are reviewable over time.

Most organizations use:

  • One organization project for privacy governance artifacts (scope, roles, policies, shared controls).
  • System projects to capture system-specific privacy evidence (data flows, retention, vendor-specific measures, incident records).

This keeps the management system stable while allowing system-level execution to move at product speed.

A sequence that works

1

Define privacy scope and roles

Clarify what processing is in scope and where you act as controller vs processor

2

Plan privacy risk assessments

Define criteria, cadence, and approvals for privacy risk and impact decisions

3

Select and structure controls

Use the standard’s annexes as a reference and translate controls into owned, operable work

4

Execute controls with evidence

Link evidence as a byproduct of operations (DPIAs, records, retention actions, vendor reviews)

5

Review and improve

Use reviews, internal audits, and corrective actions to keep the system current

6

Export audit packs

Generate point-in-time snapshots once scope and key decisions are stable

Use the standard without reproducing it

Avoid copy/pasting standard text into documents. Instead:

  • translate requirements into controls you can execute
  • define what “operated” means (cadence + evidence expectations)
  • keep decision records durable (risk acceptance, exceptions, corrective actions)

Related:

Integration note: ISO 27001 + GDPR

ISO/IEC 27701 is commonly integrated into an IMS with ISO/IEC 27001. Many controls and evidence artifacts are reusable across:

  • security governance (ISO 27001)
  • privacy governance (ISO 27701)
  • legal obligations (GDPR and others)

Related: Integration with GDPR.

Disclaimer

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