What evidence do auditors commonly ask for on A.1.3.7 Access, correction or erasure?

Documented procedures for access, correction and erasure with defined response times; Request log with dates received and completed, and performance against the response time; Evidence corrections and erasures propagated to all systems and to third parties; Dispute procedure including notification of changes made and reasons for refusal; Register of jurisdictional restrictions on these rights.

What is the most common gap auditors find on A.1.3.7?

Erasure performed in the primary system while backups, archives, logs and analytics copies retain the data

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

`A.1.3.7` Access, correction or erasure

The organization must have policies, procedures or mechanisms that let individuals see, correct and erase their personal data without undue delay. It must set a response time and keep to it; carry corrections and erasures through its systems and to authorized users, and pass them on to third parties that received the data; provide a way to resolve disputes over accuracy or correction, which includes explaining to the individual what was changed and, where a correction was not possible, why; and stay up to date with jurisdictional limits on when and how such requests may be made.

Source: ISO/IEC 27701:2025, A.1.3.7. 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

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

Request log with dates received and completed, and performance against the response time · SIEM / log platform

periodic reviewEvidence produced at each review

Evidence corrections and erasures propagated to all systems and to third parties · Vendor register / contract repository

governing documentDocuments that govern the control

Documented procedures for access, correction and erasure with defined response times · Policy repository / GRC workspace
Dispute procedure including notification of changes made and reasons for refusal · Policy repository / GRC workspace
Register of jurisdictional restrictions on these rights · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Erasure performed in the primary system while backups, archives, logs and analytics copies retain the data
Access requests answered from one system because no map exists of where else the person's data sits
Corrections applied without propagation, so systems disagree about the same person
Refusals given without reasons, which the standard requires be explained
Response times defined in policy and not measured in practice

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.1.3.6 Providing mechanism to object to PII processing · A.1.3.8 PII controllers' obligations to inform third parties