What evidence do auditors commonly ask for on A.2.2.3 Organization’s purposes?

Documented customer instructions per engagement, with a change route; Contract terms stating the objective and time frame of the service; Controls preventing processing outside the instructions, including by subcontractors; A means for the customer to verify purpose compliance, and evidence it has been offered or used; Distinction recorded between method decisions taken technically and purpose decisions, which are the customer's.

What is the most common gap auditors find on A.2.2.3?

Customer data used to improve the organization's own products or models, which is a purpose the customer never instructed

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

`A.2.2.3` Organization’s purposes

The organization must make sure that personal data it handles for a customer is used only for the purposes set out in that customer's documented instructions, with the contract stating what the service is for and how long it runs. It should recognise that, for technical reasons, it may be right for the organization to choose how processing is carried out, in line with the customer's general instructions, without explicit direction. The customer must be able to check that purpose specification and limitation are respected, which also makes sure neither the organization nor its subcontractors use the data for any other purpose.

Source: ISO/IEC 27701:2025, A.2.2.3. 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

A means for the customer to verify purpose compliance, and evidence it has been offered or used · Document repository
Distinction recorded between method decisions taken technically and purpose decisions, which are the customer's · Document repository

governing documentDocuments that govern the control

Documented customer instructions per engagement, with a change route · Document repository
Contract terms stating the objective and time frame of the service · Vendor register / contract repository
Controls preventing processing outside the instructions, including by subcontractors · 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

Customer data used to improve the organization's own products or models, which is a purpose the customer never instructed
Instructions held as a contract clause with no operational mechanism keeping processing inside it
Subcontractors processing under the organization's general practice rather than the customer's instructions
No verification means offered, so the customer must take the position on trust
Method decisions drifting into purpose decisions with no record of who decided what

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.2.2.2 Customer agreement · A.2.2.4 Marketing and advertising use