ISO/IEC 27701:2025 — Align Security and Privacy (ISMS + PIMS)

ISO/IEC 27701:2025 is the refreshed privacy standard for building a Privacy Information Management System (PIMS). The 2025 edition makes 27701 a stand-alone standard while keeping strong alignment with ISO/IEC 27001:2022 and ISO/IEC 27002:2022.

For Australian organisations, this means you can certify privacy on its own — or integrate it with your ISMS for a single, efficient governance system that buyers and regulators recognise.

This page explains what changed, why security + privacy work best together, and how to reach dual assurance quickly using Microsoft 365 for evidence.

1️⃣ What’s New in ISO/IEC 27701:2025

Stand-alone PIMS: 27701 is no longer only an “extension” to 27001 — it can be implemented and certified independently.
Terminology & control alignment: Updated language to match ISO/IEC 27001:2022 and ISO/IEC 27002:2022 for smoother dual operations.
Sharper governance focus: Clearer accountability for controller/processor roles, oversight, and metrics.
Interoperability: Continued mapping support for global privacy frameworks (e.g., ISO/IEC 29100) to ease cross-jurisdiction readiness.

In practice: you can pursue privacy certification alone or run a combined audit with ISO 27001 for a unified management system and less duplicate evidence.

2️⃣ Why Align 27701 with 27001 (ISMS + PIMS)

One governance system

Shared risk processes, reviews, management meetings, internal audits, and continuous improvement across security and privacy.

Faster audits

Combined certification minimises duplicate interviews and sampling. One set of artefacts, two outcomes.

Buyer confidence

Strong trust signal for healthcare, government, and enterprise SaaS procurement in Australia.

Regulatory readiness

Supports APPs compliance and positions you for Privacy Act reforms, GDPR obligations, and cross-border data rules.

3️⃣ What Auditors Expect (Deliverables that Pass)

Area	PIMS Evidence (27701)	How it aligns with ISMS (27001)
ROPA	Accurate processing records (systems, purposes, retention, processors)	Links to asset inventory, data flows, supplier register
DPIA	Risk thresholds, approvals, outcomes, treatment plans	Feeds risk register; control owners & corrective actions
Rights handling	SLA-driven access/erasure/objection processes	Ticketing, metrics, management review inputs
Third-party privacy	Due diligence, DPA clauses, renewal cadence	Supplier risk assessment & monitoring controls
Metrics & oversight	KPI set, trends, corrective actions	Feeds ISMS performance evaluation and continual improvement

✅ Reality check: Auditors prefer traceable evidence (timestamps, versions, owners) over long policies. Use SharePoint libraries with retention and versioning.

4️⃣ A Practical Roadmap to Dual Assurance

Weeks 1–2: Confirm scope (systems, data, processors), align ISMS/PIMS governance, draft updated privacy policy and roles.
Weeks 3–6: Build ROPA in SharePoint; stand up DPIA workflow (Power Automate + Teams Approvals); define rights handling SLAs.
Weeks 7–10: Evidence automation — monthly exports (access reviews, supplier logs), versioned artefacts, metrics dashboard.
Weeks 11–12: Readiness review and sampling rehearsal; close actions and book dual audit window.

Most organisations with a healthy ISMS can add 27701 in 4–8 weeks; new dual programmes typically complete in 12–16 weeks depending on scope and suppliers.

5️⃣ Migrating from ISO/IEC 27701:2019

Gap-check your terms & controls against the 2025 edition (aligned to 27001:2022/27002:2022).
Re-validate roles (controller/processor) and update related artefacts (ROPA rows, DPA clauses).
Unify governance: one management review, one audit calendar, one corrective-action register for ISMS + PIMS.
Refresh metrics for privacy performance and feed into ISMS performance evaluation.

💡 Tip: Keep your artefacts simple and repeatable (lists, workflows, exports). Automation beats catch-up every audit cycle.

6️⃣ How Compliance365 Accelerates ISMS + PIMS

ISMS ↔ PIMS integration plan: scope, roles, governance, and shared evidence model.
Privacy accelerator pack: ROPA template, DPIA thresholds & forms, rights workflow, DPA checklist.
Microsoft 365 automation: SharePoint evidence libraries, Power Automate schedules, Teams Approvals, Purview labels.
Audit support: readiness review, sampling packs, and dual-audit orchestration.

🎯 Outcome: One governance system, two certifications — faster procurement approvals and fewer questionnaires.

Next steps

Explore ISO 27001 Services and ISO 27701 Services, download the ISO 27701 Checklist, or book a roadmap call — we’ll map your fastest path to dual assurance.

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