What evidence do auditors commonly ask for on 6.3 Planning of changes?

Change records for PIMS changes showing purpose, consequences, resources and responsibilities; Evidence that changes to processing triggered the privacy impact assessment process; Evidence changes were implemented as planned.

What is the most common gap auditors find on 6.3?

New processing introduced through project delivery with no PIMS change planning

ISO/IEC 27701:2025 · Planning

`6.3` Planning of changes

Added in the second edition from the harmonized structure: whenever the organization decides the privacy information management system needs to change, it shall make the change in a planned way. For a PIMS the changes that most often need planning are changes to how PII is processed, to the systems processing it, to processors and subcontractors, and to the legal landscape; this planning links to the privacy impact assessment control in Annex A (A.1.2.6).

Source: ISO/IEC 27701:2025, 6.3. 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

moderate

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

Change records for PIMS changes showing purpose, consequences, resources and responsibilities · Policy repository / GRC workspace

periodic reviewEvidence produced at each review

Evidence that changes to processing triggered the privacy impact assessment process · Data governance / DLP tooling
Evidence changes were implemented as planned · Document repository

governing documentDocuments that govern the control

none for this control

First move

Start with the 1 of 3 artefacts that already live in a system (Policy repository / GRC workspace); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

New processing introduced through project delivery with no PIMS change planning
Reorganisation that moves the privacy role without assessing the effect
Planned changes to processors made without the customer notification the annex controls require

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

6.2 Privacy objectives and planning to achieve them · 7.1 Resources