What evidence do auditors commonly ask for on A.1.2.3 Identify lawful basis?

Lawful basis recorded against each processing activity, with the reasoning; Where legitimate interests is relied on, the balancing against obligations to individuals; Classification scheme entries covering special categories, mapped to the jurisdictions that define them; Change control showing the basis was re-evaluated when a purpose changed.

What is the most common gap auditors find on A.1.2.3?

Consent recorded as the basis for processing that is in fact contractual, creating a withdrawal right the organization cannot honour

ISO/IEC 27701:2025 · Annex A Table A.1 PIMS controls for PII controllers

`A.1.2.3` Identify lawful basis

The organization must determine, document and comply with the lawful basis for each processing activity against its identified purposes, documenting the basis per activity, including any special categories of personal data in its classification scheme with awareness that the classification and its consequences vary by jurisdiction and regime, and revisiting the basis and any need for fresh consent whenever purposes change or extend.

Source: ISO/IEC 27701:2025, A.1.2.3. 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

Document repository

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

none for this control

governing documentDocuments that govern the control

Lawful basis recorded against each processing activity, with the reasoning · Document repository
Where legitimate interests is relied on, the balancing against obligations to individuals · Document repository
Classification scheme entries covering special categories, mapped to the jurisdictions that define them · Policy repository / GRC workspace
Change control showing the basis was re-evaluated when a purpose changed · Document repository

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

Consent recorded as the basis for processing that is in fact contractual, creating a withdrawal right the organization cannot honour
Legitimate interests asserted with no balancing recorded
Special categories identified under one jurisdiction's definition while operating under several
Purpose extended by a new feature with the legal basis never re-examined
Basis held at organization level rather than per 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

A.1.2.2 Identify and document purpose · A.1.2.4 Determine when and how consent is to be obtained