7.2 Competence
The organization shall: determine what competence is needed by people working under its direction whose work affects its privacy performance; make sure they have that competence through suitable education, training or experience; where relevant, act to build the competence needed and check whether those actions worked; and keep suitable documented evidence of competence. Knowledge of privacy law and practice among those who advise on and carry out PII processing is the competence on which the system depends.
Source: ISO/IEC 27701:2025, 7.2. 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
- Training, education and experience records · HR system / LMS
- Evaluation of actions taken to close competence gaps · HR system / LMS
governing documentDocuments that govern the control
- Competence requirements for PIMS roles including the privacy lead and data protection officer where appointed · Policy repository / GRC workspace
First move
Common gaps auditors find
- Privacy role appointed with no competence assessment
- Competence records that stop at course attendance
- Personnel handling PII requests with no training in the obligations to PII principals
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