What evidence do auditors commonly ask for on 9.3.1 General?

Management review schedule and records; Evidence top management, not only the privacy function, conducts the review.

What is the most common gap auditors find on 9.3.1?

Management review held for the certification audit only

ISO/IEC 27701:2025 · Performance evaluation

`9.3.1` General

At planned intervals, top management shall review the privacy information management system of the organization to confirm that it remains suitable, adequate and effective.

Source: ISO/IEC 27701:2025, 9.3.1. 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

Management review schedule and records · Policy repository / GRC workspace
Evidence top management, not only the privacy function, conducts the review · Data governance / DLP tooling

governing documentDocuments that govern the control

none for this control

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

Management review held for the certification audit only
Review conducted by the privacy team and reported upward as a summary

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

9.2.2 Internal audit programme · 9.3.2 Management review inputs