What evidence do auditors commonly ask for on A.2.2.5 Infringing instruction?

Documented route for raising an instruction concern, with the decision authority named; Records of instructions challenged and the outcome; Contract terms preserving the ability to raise the concern; Competence evidence for whoever judges whether an instruction infringes.

What is the most common gap auditors find on A.2.2.5?

No route exists, so a questionable instruction is executed because refusing it has no defined path

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

`A.2.2.5` Infringing instruction

The organization must tell the customer whenever it believes a processing instruction breaks the law or regulations that apply, recognising that how far it can make that judgement depends on the technology involved, on what the instruction says and on the terms of its contract with the customer.

Source: ISO/IEC 27701:2025, A.2.2.5. 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

Records of instructions challenged and the outcome · Document repository
Competence evidence for whoever judges whether an instruction infringes · HR system / LMS

governing documentDocuments that govern the control

Documented route for raising an instruction concern, with the decision authority named · Document repository
Contract terms preserving the ability to raise the concern · 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

No route exists, so a questionable instruction is executed because refusing it has no defined path
Route exists but sits with account management, whose incentive is to keep the customer
Concerns raised verbally with no record, so a pattern of them is invisible
Contract silent, leaving the organization exposed if it declines an instruction

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.2.2.4 Marketing and advertising use · A.2.2.6 Customer obligations