What evidence do auditors commonly ask for on A.1.4.10 PII transmission controls?

Documented transmission controls covering authorisation, protection and recipient verification; Access controls over transmission systems; Audit logs of transmissions retained and reviewable; Evidence of recipient verification, not merely of encryption in transit.

What is the most common gap auditors find on A.1.4.10?

Encryption treated as the whole of the control, with no assurance the data reached the right recipient

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

`A.1.4.10` PII transmission controls

Personal data the organization sends across a network must be protected by controls meant to make sure it arrives where it should. Usually this means limiting access to the transmission systems to authorized people and following processes, keeping audit logs among them, that deliver the data to the right recipients without it being compromised.

Source: ISO/IEC 27701:2025, A.1.4.10. 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

moderate

to go live

SIEM / log platform

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

Audit logs of transmissions retained and reviewable · SIEM / log platform

periodic reviewEvidence produced at each review

Evidence of recipient verification, not merely of encryption in transit · Document repository

governing documentDocuments that govern the control

Documented transmission controls covering authorisation, protection and recipient verification · Document repository
Access controls over transmission systems · Document repository

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Encryption treated as the whole of the control, with no assurance the data reached the right recipient
Transmission logs absent, so a misdirection cannot be detected or investigated
Bulk transfers run by individuals with no authorisation step
Recipient addresses maintained manually in scripts, where a single edit misroutes a whole file
Ad hoc transfers by email and file sharing outside the controlled route

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.1.4.9 Disposal · A.1.5.2 Identify basis for PII transfer between jurisdictions