What evidence do auditors commonly ask for on A.1.2.5 Obtain and record consent?

Consent records holding timestamp, individual identity and the exact statement consented to; The version of the information presented before consent, retained alongside; Evidence consent was freely given, meaning a real alternative existed; Ability to produce a single individual's consent history on request.

What is the most common gap auditors find on A.1.2.5?

Consent recorded as a boolean flag with no record of what wording the person actually saw

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

`A.1.2.5` Obtain and record consent

The organization must obtain and record consent according to its documented process, recording it so that on request it can produce the details of the consent given, including when it was given, the identity of the individual and the consent statement itself, having first provided the information required before consent, and the consent must be freely given, specific as to the purpose, and unambiguous and explicit.

Source: ISO/IEC 27701:2025, A.1.2.5. 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

Evidence consent was freely given, meaning a real alternative existed · Data governance / DLP tooling

governing documentDocuments that govern the control

Consent records holding timestamp, individual identity and the exact statement consented to · Policy repository / GRC workspace
The version of the information presented before consent, retained alongside · Policy repository / GRC workspace
Ability to produce a single individual's consent history on request · 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 recorded as a boolean flag with no record of what wording the person actually saw
Consent statement changed without versioning, so old consents cannot be interpreted
Consent obtained as a condition of a service that does not need it, which is not freely given
Consent stored in a marketing platform outside the retention and access regime
Pre-ticked or inferred consent recorded as explicit

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.1.2.4 Determine when and how consent is to be obtained · A.1.2.6 Privacy impact assessment