What evidence do auditors commonly ask for on 9.2.1 General?

Internal audit reports covering conformity to this document and to the organization's own requirements; Evidence audits assess effective implementation, not only documentation.

What is the most common gap auditors find on 9.2.1?

Internal audit scoped to the ISMS with the PIMS sampled incidentally

ISO/IEC 27701:2025 · Performance evaluation

`9.2.1` General

At planned intervals the organization shall run internal audits that tell it whether the privacy information management system meets both the requirements the organization has set for it and the requirements of this document, and whether it is effectively put into practice and kept up.

Source: ISO/IEC 27701:2025, 9.2.1. 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

Internal audit reports covering conformity to this document and to the organization's own requirements · Policy repository / GRC workspace

governing documentDocuments that govern the control

Evidence audits assess effective implementation, not only documentation · 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

Internal audit scoped to the ISMS with the PIMS sampled incidentally
Audit that checks documents exist and never tests a processing activity

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

9.1 Monitoring, measurement, analysis and evaluation · 9.2.2 Internal audit programme