What evidence do auditors commonly ask for on A.1.4.2 Limit collection?

Field level justification linking each item collected to an identified purpose; Assessment of indirectly collected data such as logs, telemetry and tracking; Evidence optional collection is off by default, captured from the live configuration; Periodic review of collection against current purposes.

What is the most common gap auditors find on A.1.4.2?

Justification performed for form fields while telemetry, cookies and logs collect far more without review

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

`A.1.4.2` Limit collection

The organization must collect no more personal data than is adequate, relevant, proportionate and needed for the identified purposes, and this applies equally to data gathered indirectly, for example through web and system logs. Wherever collection or processing includes optional elements, each option must be switched off by default and switched on only when the individual explicitly chooses it.

Source: ISO/IEC 27701:2025, A.1.4.2. 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

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

none for this control

periodic reviewEvidence produced at each review

Assessment of indirectly collected data such as logs, telemetry and tracking · SIEM / log platform
Evidence optional collection is off by default, captured from the live configuration · Cloud console / configuration management
Periodic review of collection against current purposes · Document repository

governing documentDocuments that govern the control

Field level justification linking each item collected to an identified purpose · Document repository

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

Justification performed for form fields while telemetry, cookies and logs collect far more without review
Optional processing enabled by default with an opt out, which reverses the required default
Fields collected because they might be useful later, which is not a purpose
Legacy fields retained in collection long after the purpose that justified them ended
Default configuration correct at launch and drifted since, with no verification

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.1.3.11 Automated decision making · A.1.4.3 Limit processing