What evidence do auditors commonly ask for on A.1.3.3 Determining information for PII principals?

Documented determination of notice content and timing per processing activity; Traceability from each required content element to where it appears in the notice; Trigger and evidence for updating notices when purposes change; Legal review record supporting the content decisions.

What is the most common gap auditors find on A.1.3.3?

Notice content copied from a template, so elements that do not apply are present and elements that do are missing

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

`A.1.3.3` Determining information for PII principals

The organization must determine and document what information is to be provided to individuals about the processing of their data and when it is to be provided, working out the legal, regulatory and business requirements for timing and content, which typically covers the purpose, the controller's contact details, the lawful basis, the source where data was not obtained from the individual, whether provision is statutory or contractual and the consequences of not providing it, the obligations owed and how to benefit from them including access, amendment, correction, erasure, obtaining a copy and objecting, how to withdraw consent, transfers, recipients or categories of recipients, the retention period, any automated decision making, the right to complain and how, and how often information is provided, updated whenever purposes change or extend.

Source: ISO/IEC 27701:2025, A.1.3.3. 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

Trigger and evidence for updating notices when purposes change · Document repository
Legal review record supporting the content decisions · Document repository

governing documentDocuments that govern the control

Documented determination of notice content and timing per processing activity · Policy repository / GRC workspace
Traceability from each required content element to where it appears in the notice · 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

Notice content copied from a template, so elements that do not apply are present and elements that do are missing
Source of indirectly collected data omitted, which is the element most often absent
Retention period expressed as as long as necessary, which conveys nothing
Timing never determined, so information is given at account creation and never again
Automated decision making not disclosed because the business does not think of its scoring as automated

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.1.3.2 Determining and fulfilling obligations to PII principals · A.1.3.4 Providing information to PII principals