What evidence do auditors commonly ask for on A.1.3.5 Providing mechanism to modify or withdraw consent?

Withdrawal mechanism on the same channel as consent collection; Withdrawal records held to the same standard as consent records; Evidence of propagation to internal systems and to third parties who received the data; Defined response time and performance against it; Rules preventing further use of results derived from withdrawn consent.

What is the most common gap auditors find on A.1.3.5?

Withdrawal accepted centrally and never propagated, so downstream systems keep processing

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

`A.1.3.5` Providing mechanism to modify or withdraw consent

The organization must provide a mechanism for individuals to modify or withdraw consent, inform them of their rights to withdraw at any time, use a withdrawal mechanism consistent with the one used to obtain consent, treat modification as capable of restricting processing including restricting deletion in some cases, record withdrawal or change requests as it records consent itself, disseminate any change through its systems to authorized users and relevant third parties, and define and meet a response time, with processing already performed before withdrawal remaining appropriate but its results not used for new processing.

Source: ISO/IEC 27701:2025, A.1.3.5. 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

Withdrawal records held to the same standard as consent records · Data governance / DLP tooling
Evidence of propagation to internal systems and to third parties who received the data · Vendor register / contract repository

governing documentDocuments that govern the control

Withdrawal mechanism on the same channel as consent collection · Policy repository / GRC workspace
Defined response time and performance against it · Policy repository / GRC workspace
Rules preventing further use of results derived from withdrawn consent · 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

Withdrawal accepted centrally and never propagated, so downstream systems keep processing
Withdrawal harder than consent, for example consent by one click and withdrawal by written request
Derived artefacts such as profiles and models retained and still used after withdrawal
Third parties who received the data never told
No response time defined, so withdrawal is honoured whenever someone gets to it

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.1.3.4 Providing information to PII principals · A.1.3.6 Providing mechanism to object to PII processing