5.2 Privacy policy
Top management shall set a privacy policy that suits the organization's purpose, gives a basis for setting privacy objectives, commits the organization to meeting the requirements that apply to its processing of PII, and commits it to keep improving the privacy information management system. The policy shall exist as documented information, be made known inside the organization and, where suitable, be made accessible to interested parties. The transition documents note that a written privacy policy is now a requirement in its own right, no longer an add-on to the information security policy.
Source: ISO/IEC 27701:2025, 5.2. 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 27701:2025 in the compliance library.
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
- Communication records within the organization · Policy repository / GRC workspace
- Policy review records · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Approved privacy policy carrying each required element · Policy repository / GRC workspace
- Evidence the policy is available to interested parties, for example published or provided to customers · Policy repository / GRC workspace
First move
Common gaps auditors find
- A privacy notice to individuals presented as the management system policy
- Policy that commits to information security but never to the processing of PII
- Policy never communicated beyond the privacy team
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 sheet5.1 Leadership and commitment · 5.3 Roles, responsibilities and authorities