What evidence do auditors commonly ask for on 6.1.3 Privacy risk treatment?

Risk treatment plan with options, controls, owners and dates; Statement of Applicability listing every Annex A control with inclusion or exclusion justification and implementation status; Documented information security programme covering the areas the standard names; Risk owner approval of the plan and acceptance of residual risk.

What is the most common gap auditors find on 6.1.3?

Statement of Applicability copied from an ISO/IEC 27001 SoA with the 2019 annexes bolted on

ISO/IEC 27701:2025 · Planning

`6.1.3` Privacy risk treatment

The organization shall set and apply a privacy risk treatment process that: chooses suitable treatment options in light of the assessment results; identifies every control needed to carry out those options; checks the chosen controls against Annex A to confirm nothing needed has been missed, Annex A being a reference set of possible controls the organization may extend; identifies and documents the information security programme protecting PII, which the transition documents say must cover a stated set of areas and may, though need not, follow ISO/IEC 27002; prepares a Statement of Applicability listing the needed controls, why each is included, whether each is in place, and why any Annex A control is excluded; draws up a privacy risk treatment plan; and secures the risk owners' approval of that plan and their acceptance of the remaining privacy risks. Documented information on the process shall be kept. The first edition compared controls with Annex A of ISO/IEC 27001:2013 plus the two PIMS annexes; this edition compares them with this document's Annex A only.

Source: ISO/IEC 27701:2025, 6.1.3. 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.

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

Risk owner approval of the plan and acceptance of residual risk · Policy repository / GRC workspace

governing documentDocuments that govern the control

Risk treatment plan with options, controls, owners and dates · Policy repository / GRC workspace
Statement of Applicability listing every Annex A control with inclusion or exclusion justification and implementation status · Policy repository / GRC workspace
Documented information security programme covering the areas the standard names · 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

Statement of Applicability copied from an ISO/IEC 27001 SoA with the 2019 annexes bolted on
Annex A exclusions justified by not applicable with no reasoning
Information security programme asserted by reference to ISO/IEC 27001 certification with no document of its own
Residual risk accepted by the privacy function rather than the risk owner

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

6.1.2 Privacy risk assessment · 6.2 Privacy objectives and planning to achieve them