What evidence do auditors commonly ask for on A.1.2.7 Contracts with PII processors?

Written contract with every processor, with a register reconciling contracts to processors actually used; Contract terms addressing the processor control set; Justification for any processor control not required, recorded in the Statement of Applicability; Evidence the risk assessment and processing scope informed which controls were required.

What is the most common gap auditors find on A.1.2.7?

Processors engaged under standard purchasing terms with no privacy schedule

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

`A.1.2.7` Contracts with PII processors

The organization must have a written contract with every processor it uses and must ensure those contracts address implementation of the appropriate processor controls, requiring the processor to implement them in light of the risk assessment and the scope of processing it performs, with all such controls assumed relevant by default and any decision not to require one justified in the Statement of Applicability, responsibilities being allocable differently between the parties provided every control is considered and documented.

Source: ISO/IEC 27701:2025, A.1.2.7. 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

Vendor register / contract 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

Evidence the risk assessment and processing scope informed which controls were required · Vendor register / contract repository

governing documentDocuments that govern the control

Written contract with every processor, with a register reconciling contracts to processors actually used · Vendor register / contract repository
Contract terms addressing the processor control set · Vendor register / contract repository
Justification for any processor control not required, recorded in the Statement of Applicability · Vendor register / contract 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

Processors engaged under standard purchasing terms with no privacy schedule
Contract requiring appropriate measures generically, so no specific control is enforceable
Controls omitted by silence rather than by justified exclusion
Processor register incomplete, most often missing tools adopted by individual teams
Contract signed at onboarding and never revisited when the scope of processing grew

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.1.2.6 Privacy impact assessment · A.1.2.8 Joint PII controller