What evidence do auditors commonly ask for on A.1.3.10 Handling requests?

Documented request handling procedure covering identification, triage, response and escalation; Response times published in the privacy policy and measured in operation; Delay notification procedure and evidence of use; Complaint route distinct from general customer service, with records; Fee policy where a fee is charged, with the justification for each charge.

What is the most common gap auditors find on A.1.3.10?

Requests handled through general customer service with no privacy specific triage, so clocks start late

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

`A.1.3.10` Handling requests

The organization must set out and document policies and procedures for dealing with valid requests from individuals, such as asking for a copy of their data or making a complaint, and must answer them within suitable, defined timescales. It should take account of jurisdictions that fix response times according to how complex and numerous requests are and require individuals to be told of any delay, with the applicable timescales stated in the privacy policy, and of jurisdictions that allow a fee in limited situations, such as requests that are excessive or repeated.

Source: ISO/IEC 27701:2025, A.1.3.10. 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

Complaint route distinct from general customer service, with records · Document repository

governing documentDocuments that govern the control

Documented request handling procedure covering identification, triage, response and escalation · Policy repository / GRC workspace
Response times published in the privacy policy and measured in operation · Policy repository / GRC workspace
Delay notification procedure and evidence of use · Policy repository / GRC workspace
Fee policy where a fee is charged, with the justification for each charge · 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

Requests handled through general customer service with no privacy specific triage, so clocks start late
Response times published but not measured, so breaches are invisible
No delay notification, so a complex request simply goes quiet
Complaints resolved individually with no analysis of the systemic cause
Identity verification demanding more personal data than the request itself involves

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.1.3.9 Providing copy of PII processed · A.1.3.11 Automated decision making