What evidence do auditors commonly ask for on A.2.4.4 PII transmission controls?

Documented transmission controls covering authorisation, protection and recipient verification; Audit data retained for transmissions of customer personal data; Contract terms on transmission requirements where they exist; Evidence of consulting the customer before transmission where the contract is silent.

What is the most common gap auditors find on A.2.4.4?

Transmission performed on the organization's own default standard where the customer had a higher requirement it was never asked about

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

`A.2.4.4` PII transmission controls

Personal data the organization sends across a network must be protected by controls meant to make sure it arrives where it should. Usually this means limiting access to the transmission systems to authorized people and following processes, retention of audit records among them, that get the data to the right recipients without it being compromised. Transmission requirements may be written into the customer contract; where the contract says nothing, the organization should seek the customer's guidance before sending.

Source: ISO/IEC 27701:2025, A.2.4.4. 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

Evidence of consulting the customer before transmission where the contract is silent · Vendor register / contract repository

governing documentDocuments that govern the control

Documented transmission controls covering authorisation, protection and recipient verification · Document repository
Audit data retained for transmissions of customer personal data · Policy repository / GRC workspace
Contract terms on transmission requirements where they exist · 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

Transmission performed on the organization's own default standard where the customer had a higher requirement it was never asked about
Encryption applied with no verification that the recipient was the intended one
Audit data not retained, so a misdirected transmission cannot be traced
Ad hoc transfers to customer nominated endpoints arranged over email with no authorisation step

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.2.4.3 Return, transfer or disposal of PII · A.2.5.2 Basis for PII transfer between jurisdictions