What evidence do auditors commonly ask for on A.2.2.7 Records related to processing PII?

Records of processing held per customer, covering the categories of processing carried out; Record of transfers to third countries and international organizations; Overall account of the technical and organizational safeguards; Named owner and evidence of maintenance through change.

What is the most common gap auditors find on A.2.2.7?

Records held at organization level rather than per customer, which is what the obligation asks for

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

`A.2.2.7` Records related to processing PII

The organization must work out which records it needs to show that it meets its contractual obligations for the processing it performs for a customer, and must keep those records up to date. It should recognise that some jurisdictions require records of, for example, the kinds of processing performed for each customer, any data sent on to a third country or an international organization, and an overall account of the technical and organizational safeguards in place.

Source: ISO/IEC 27701:2025, A.2.2.7. 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 processing held per customer, covering the categories of processing carried out · Document repository
Record of transfers to third countries and international organizations · Document repository
Named owner and evidence of maintenance through change · Document repository

governing documentDocuments that govern the control

Overall account of the technical and organizational safeguards · Policy repository / GRC workspace

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

Records held at organization level rather than per customer, which is what the obligation asks for
Transfers by subcontractors omitted from the record
Security measures described identically for every customer regardless of the service tier they bought
Records rebuilt for audits rather than maintained, so they describe a past state

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.2.2.6 Customer obligations · A.2.3.2 Comply with obligations to PII principals