What evidence do auditors commonly ask for on A.1.2.6 Privacy impact assessment?

Documented trigger criteria for when an assessment is required, including the mandated cases; Screening records showing the need was assessed even where no assessment followed; Completed assessments with data types, storage locations, transfers and data flows; Evidence assessment findings changed the design or were formally accepted; Link from the change process into the screening step.

What is the most common gap auditors find on A.1.2.6?

Assessment performed only for projects that reach a funding threshold, so small high risk changes escape

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

`A.1.2.6` Privacy impact assessment

Each time new processing of personal data, or a change to current processing, is planned, the organization must judge whether a privacy impact assessment is required and carry one out where appropriate. It must decide what the assessment should cover, which may include the kinds of personal data involved, where the data is held and where it could be sent, supported by data flow diagrams and data maps. It should recognise that some jurisdictions make an assessment compulsory in cases such as automated decisions producing legal effects, large-scale processing of special categories, or systematic large-scale monitoring of publicly accessible areas.

Source: ISO/IEC 27701:2025, A.1.2.6. 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

HR system / LMS

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

Screening records showing the need was assessed even where no assessment followed · HR system / LMS
Completed assessments with data types, storage locations, transfers and data flows · Data governance / DLP tooling
Evidence assessment findings changed the design or were formally accepted · Data governance / DLP tooling

governing documentDocuments that govern the control

Documented trigger criteria for when an assessment is required, including the mandated cases · Policy repository / GRC workspace
Link from the change process into the screening step · HR system / LMS

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

Assessment performed only for projects that reach a funding threshold, so small high risk changes escape
Screening decisions not recorded, so the absence of an assessment cannot be justified
Assessment completed after go live, when it can no longer influence anything
Findings recorded with no owner, so mitigations are never implemented
Data flows described in prose without identifying transfers out of jurisdiction

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.1.2.5 Obtain and record consent · A.1.2.7 Contracts with PII processors