What evidence do auditors commonly ask for on A.1.2.4 Determine when and how consent is to be obtained?

Documented consent process covering when consent is required and what valid consent demands; Mapping from each purpose to whether and how consent is obtained; Analysis of jurisdiction specific consent requirements and how the mechanism meets them; Provision for heightened requirements such as children or research collections.

What is the most common gap auditors find on A.1.2.4?

Consent bundled into terms of service acceptance, which several jurisdictions treat as no consent at all

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

`A.1.2.4` Determine when and how consent is to be obtained

The organization must set and document a process that lets it prove whether consent to processing was given, when and in what way. It must record plainly when consent is required and what is needed to obtain it validly, link each purpose to the way consent is gathered for it, and allow for jurisdiction-specific rules, for example that consent must not be tied to other agreements, and extra conditions for certain collections or for certain individuals such as children.

Source: ISO/IEC 27701:2025, A.1.2.4. 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

Analysis of jurisdiction specific consent requirements and how the mechanism meets them · Data governance / DLP tooling

governing documentDocuments that govern the control

Documented consent process covering when consent is required and what valid consent demands · Policy repository / GRC workspace
Mapping from each purpose to whether and how consent is obtained · Policy repository / GRC workspace
Provision for heightened requirements such as children or research collections · 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

Consent bundled into terms of service acceptance, which several jurisdictions treat as no consent at all
One consent mechanism for all purposes, so a person cannot agree to one and refuse another
Age assurance absent where children's data is foreseeably collected
The process described but never mapped to purposes, so nobody can say which purposes rest on consent

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.1.2.3 Identify lawful basis · A.1.2.5 Obtain and record consent