What evidence do auditors commonly ask for on A.2.3.2 Comply with obligations to PII principals?

Documented capabilities for access, correction, deletion, export and restriction, offered to customers; Contract terms specifying the information and technical measures the customer may rely on; Service level or response time for assistance, and performance against it; Evidence the capabilities work at the volumes the customer's obligations imply.

What is the most common gap auditors find on A.2.3.2?

Deletion offered only as a bulk end of contract operation, which cannot serve an individual erasure request

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

`A.2.3.2` Comply with obligations to PII principals

The organization must give the customer what it needs to meet its duties to individuals. It should recognise that those duties may come from law, regulation or contract, and may cover things the customer depends on the organization's services to carry out, such as promptly correcting or erasing data. Any information or technical support from the organization that the customer depends on to meet its duties, those must be set out in a contract.

Source: ISO/IEC 27701:2025, A.2.3.2. 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

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 capabilities work at the volumes the customer's obligations imply · Document repository

governing documentDocuments that govern the control

Documented capabilities for access, correction, deletion, export and restriction, offered to customers · Document repository
Contract terms specifying the information and technical measures the customer may rely on · Vendor register / contract repository
Service level or response time for assistance, and performance against it · 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

Deletion offered only as a bulk end of contract operation, which cannot serve an individual erasure request
Assistance provided by manual engineering effort with no service level, so the customer's own deadline is at risk
Capabilities existing in the product but not specified in the contract, so the customer cannot rely on them
Correction possible in the primary store while derived and cached copies stay stale
Assistance excluding data held by the organization's own subcontractors

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.2.2.7 Records related to processing PII · A.2.4.2 Temporary files