What evidence do auditors commonly ask for on A.1.3.9 Providing copy of PII processed?

Documented export capability with the formats supported; Evidence exports are scoped to the requesting individual only; Procedure for informing an individual that data has already been deleted; Position on re-identification, recording that it is not attempted merely to answer a request; Direct transfer capability where technically feasible, or the assessment that it is not.

What is the most common gap auditors find on A.1.3.9?

Export produced as a screen capture or report rather than a structured format

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

`A.1.3.9` Providing copy of PII processed

When an individual asks, the organization must be able to hand over a copy of the personal data it holds about them, in a structured, widely used format the individual can open, and in a portable, machine-readable form where the jurisdiction demands it. The copy must concern that individual alone. If the requested data has already been deleted under the retention policy, the organization must say so. It must not try to re-identify people merely to meet this control when it can no longer identify them, and where technically possible it must send the data straight to another organization if the individual asks.

Source: ISO/IEC 27701:2025, A.1.3.9. 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

moderate

to go live

Document 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

Documented export capability with the formats supported · Document repository
Evidence exports are scoped to the requesting individual only · Document repository

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Procedure for informing an individual that data has already been deleted · Policy repository / GRC workspace
Position on re-identification, recording that it is not attempted merely to answer a request · Document repository
Direct transfer capability where technically feasible, or the assessment that it is not · Document repository

First move

Start with the 2 of 5 artefacts that already live in a system (Document repository); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Export produced as a screen capture or report rather than a structured format
Export including other individuals' data present in shared records or free text
Re-identification attempted on de-identified holdings in order to answer a request, creating the exposure the de-identification removed
No response where data has been deleted, leaving the individual to assume it is withheld
Portability treated as identical to access, ignoring the format requirement

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.1.3.8 PII controllers' obligations to inform third parties · A.1.3.10 Handling requests