What evidence do auditors commonly ask for on A.1.5.2 Identify basis for PII transfer between jurisdictions?

Transfer register naming origin, destination and the documented basis for each transfer; The transfer instruments themselves, such as contractual clauses or binding rules; Assessment of destination jurisdiction requirements; Evidence of supervisory authority review where the jurisdiction requires it.

What is the most common gap auditors find on A.1.5.2?

Transfers identified only where data physically moves, missing remote access from another jurisdiction, which is itself a transfer

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

`A.1.5.2` Identify basis for PII transfer between jurisdictions

The organization must identify and record the legal basis on which personal data moves between jurisdictions, documenting that it meets the laws and regulations that apply given the jurisdiction or international organization the data is sent to and received from. It should be aware that certain jurisdictions require a designated supervisory authority to examine transfer agreements.

Source: ISO/IEC 27701:2025, A.1.5.2. 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

moderate

to go live

Cloud console / configuration management

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

The transfer instruments themselves, such as contractual clauses or binding rules · Cloud console / configuration management

periodic reviewEvidence produced at each review

Assessment of destination jurisdiction requirements · Document repository
Evidence of supervisory authority review where the jurisdiction requires it · Regulator portal / correspondence

governing documentDocuments that govern the control

Transfer register naming origin, destination and the documented basis for each transfer · Policy repository / GRC workspace

First move

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

Common gaps auditors find

Transfers identified only where data physically moves, missing remote access from another jurisdiction, which is itself a transfer
One transfer basis assumed adequate for every destination
Instruments executed and never revisited after the legal landscape changed
Supervisory review requirements unidentified, leaving the instrument unenforceable
Onward transfers by recipients not covered by the basis

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.1.4.10 PII transmission controls · A.1.5.3 Countries and international organizations to which PII can be transferred