What evidence do auditors commonly ask for on A.2.2.2 Customer agreement?

Customer contracts carrying the assistance provisions relevant to the engagement; Where the jurisdiction requires it, contract terms stating subject matter, duration, nature, purpose, data types and categories of individuals; Operational capability behind each assistance commitment, not the commitment alone; Contract register reconciling signed terms to live processing engagements.

What is the most common gap auditors find on A.2.2.2?

Assistance promised in contract with no operational capability behind it, discovered only when the customer first asks

ISO/IEC 27701:2025 · Annex A Table A.2 PIMS controls for PII processors

`A.2.2.2` Customer agreement

Where relevant, the contract for processing personal data must set out how the organization will help the customer meet the customer's own obligations, having regard to what the processing involves and what information the organization holds. As applicable this covers privacy by design and by default, keeping processing secure, reporting breaches to a supervisory authority and to customers and individuals, carrying out privacy impact assessments, and guaranteed support where a data protection authority has to be consulted in advance. Some jurisdictions also require the contract to state what is processed and for how long, how and why it is processed, which kinds of data are involved and which categories of individuals are affected.

Source: ISO/IEC 27701:2025, A.2.2.2. 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

Vendor register / contract 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

none for this control

governing documentDocuments that govern the control

Customer contracts carrying the assistance provisions relevant to the engagement · Vendor register / contract repository
Where the jurisdiction requires it, contract terms stating subject matter, duration, nature, purpose, data types and categories of individuals · Vendor register / contract repository
Operational capability behind each assistance commitment, not the commitment alone · Vendor register / contract repository
Contract register reconciling signed terms to live processing engagements · Vendor register / contract 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

Assistance promised in contract with no operational capability behind it, discovered only when the customer first asks
Breach notification assistance limited to telling the customer, with none of the detail the customer needs to notify a regulator
Impact assessment assistance omitted, leaving the customer unable to complete one
Jurisdiction specific content requirements unidentified, so the contract is incomplete where it matters
Legacy customers on older terms that predate the obligations

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.1.5.5 Records of PII disclosures to third parties · A.2.2.3 Organization’s purposes