Introduction
The upcoming ISO 27701:2025 update marks a significant evolution in Privacy Information Management System (PIMS) standards. This revision brings essential changes, making PIMS a standalone certification rather than just an extension of ISO 27001. Organizations planning to implement or certify for ISO 27701 should wait for the official release, expected around August 5, 2025, to ensure compliance with the latest framework.
Key Changes in ISO 27701:2025
1. PIMS Becomes a Standalone Certification
- Old Standard (ISO 27701:2019): Required ISO 27001 certification as a foundation before implementing PIMS.
- New Standard (ISO 27701:2025): Allows organizations to certify independently, making privacy management more flexible.
Impact: Businesses focusing purely on privacy compliance can now implement ISO 27701 without the need for ISMS (ISO 27001).
2. Restructured Management System Framework
- Old Approach: ISO 27701 followed ISO 27001’s structure, treating privacy controls as an add-on.
- New Approach: The core framework consists of Clauses 4–10, mirroring ISO 27001, but specifically tailored for privacy management.
Clauses Include:
- Context
- Leadership
- Planning
- Support
- Operation
- Performance Evaluation
- Improvement
Impact: Easier integration of privacy management, making it more streamlined without requiring ISMS certification.
3. Annex A Consolidation
- Previous Version: Had separate annexes for PII controllers and processors.
- Updated Version: Combines them into a single Annex A, with:
- A.1 – PII Controllers (previously Clause 7 / Annex A)
- A.2 – PII Processors (previously Clause 8 / Annex B)
- A.3 – Security Controls applicable to both Controllers & Processors, aligned with ISO 27001:2022.
Impact: Simplified compliance and easier implementation of privacy controls.
4. New Annex B – Implementation Guidance
- Old Standard: Provided general privacy control requirements with limited guidance.
- New Standard: Introduces Annex B, offering detailed practical steps for implementing privacy controls:
- B.1 – PII Controllers
- B.2 – PII Processors
- B.3 – Shared Security Controls for both Controllers & Processors.
Impact: Organizations will now have clearer instructions on setting up their privacy management framework.
What Stays the Same?
While the structure is evolving, fundamental control requirements remain unchanged. They are still based on:
- ISO 27701:2019
- ISO 27001:2022
- ISO 27002:2022
Organizations already compliant with ISO 27701:2019 will experience an easy transition to the updated version, without major disruptions.
ISO 27701:2019 vs ISO 27701:2025 – Key Differences
Feature
ISO 27701:2019
ISO 27701:2025
Certification
Required ISO 27001 before PIMS implementation
PIMS can be certified independently
Core Framework
No dedicated structure, followed ISO 27001
Clauses 4–10 define PIMS-specific framework
Annex A
Separate annexes for controllers/processors
Merged into a single Annex A
Implementation Guidance
Limited guidance
Annex B introduced with detailed practical steps
Control Requirements
Derived from ISO 27001:2013
Aligned with ISO 27001:2022 & 27002:2022
Conclusion – Should You Wait for Certification?
Yes! The ISO 27701:2025 update brings more flexibility, better structure, and clearer implementation guidelines for privacy management. Waiting for the official release will ensure organizations align with the latest requirements, making compliance smoother and more effective.
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