What evidence do auditors commonly ask for on A.5.34 Privacy and protection of personal identifiable information (PII)?

Statement of Applicability entry for control A.5.34, showing inclusion or justified exclusion, implementation status and the risks it treats; The topic-specific privacy and PII protection policy and its communication to relevant parties; Privacy procedures communicated to everyone who processes PII; Appointment of a privacy officer or equivalent with documented responsibilities; A record of processing or PII inventory mapping which laws apply to each processing activity.

What is the most common gap auditors find on A.5.34?

Privacy is treated as a legal matter only, with no link to security controls

ISO/IEC 27001:2022 · Organizational controls

`A.5.34` Privacy and protection of personal identifiable information (PII)

The organization is to identify, and then satisfy, the requirements for preserving privacy and protecting personally identifiable information that arise from applicable laws, regulations and contracts. Purpose (stated in ISO/IEC 27002:2022): ensures compliance with requirements on the information security aspects of protecting PII. As an Annex A reference control, it is compared with the controls determined in risk treatment (6.1.3 c) and recorded in the Statement of Applicability as included or excluded, with the justification and implementation status (6.1.3 d); implementation guidance is ISO/IEC 27002:2022 5.34.

Source: ISO/IEC 27001:2022, A.5.34. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open ISO/IEC 27001:2022 in the compliance library.

Clauses 4 to 10 are the management-system requirements: none of them can be excluded when an organisation claims conformity. The 93 Annex A controls are a reference set: one may be excluded with a justification in the Statement of Applicability. Certification bodies assess conformity; the evidence lists here are what auditors commonly ask for, not a list the standard prescribes.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

A record of processing or PII inventory mapping which laws apply to each processing activity · Policy repository / GRC workspace

governing documentDocuments that govern the control

Statement of Applicability entry for control A.5.34, showing inclusion or justified exclusion, implementation status and the risks it treats · Policy repository / GRC workspace
The topic-specific privacy and PII protection policy and its communication to relevant parties · Policy repository / GRC workspace
Privacy procedures communicated to everyone who processes PII · Policy repository / GRC workspace
Appointment of a privacy officer or equivalent with documented responsibilities · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Privacy is treated as a legal matter only, with no link to security controls
No one is formally responsible for guiding staff and providers on PII handling
Cross-border transfers of PII occur without checking applicable restrictions
Privacy impact assessments are not performed for new processing

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

A.5.33 Protection of records · A.5.35 Independent review of information security