What evidence do auditors commonly ask for on A.1.5.3 Countries and international organizations to which PII can be transferred?

Documented list of destination countries and international organizations; Evidence the list is made available to customers; Inclusion of destinations arising from subcontractors, not the organization's own operations alone; Reconciliation between the destination list and the transfer bases held; Process for maintaining the list as subcontractors and regions change.

What is the most common gap auditors find on A.1.5.3?

List covering the organization's own locations while subcontractor destinations are omitted, which is where most undisclosed transfers arise

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

`A.1.5.3` Countries and international organizations to which PII can be transferred

The organization must set out and document every country and international organization that personal data may end up being sent to, including destinations that result from subcontracted processing, make that list available to customers, and consider the destinations alongside the documented basis for transfer. It should recognise that a transfer requested by law enforcement may involve countries that cannot be named beforehand, or whose naming is forbidden in order to keep an investigation confidential.

Source: ISO/IEC 27701:2025, A.1.5.3. 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

Evidence the list is made available to customers · Document repository

governing documentDocuments that govern the control

Documented list of destination countries and international organizations · Document repository
Inclusion of destinations arising from subcontractors, not the organization's own operations alone · Document repository
Reconciliation between the destination list and the transfer bases held · Document repository
Process for maintaining the list as subcontractors and regions change · 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

List covering the organization's own locations while subcontractor destinations are omitted, which is where most undisclosed transfers arise
List produced at contract signature and never updated as the supply chain changes
Support and administration access from a country absent from the list, because access is not thought of as transfer
List published without reconciliation to transfer bases, so a destination appears with no lawful route
Availability to customers asserted but the list held internally only

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.1.5.2 Identify basis for PII transfer between jurisdictions · A.1.5.4 Records of transfer of PII