What evidence do auditors commonly ask for on A.2.5.2 Basis for PII transfer between jurisdictions?

Documented transfer basis per route, disclosed to the customer; Notification records for changes, with the agreed advance timeframe; Contract terms setting the limits of any change made without notification; Identification of the transfer instruments, the countries and the circumstances in which each applies; Evidence the customer had a real opportunity to object.

What is the most common gap auditors find on A.2.5.2?

Change notification given after the change took effect, removing the ability to object

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

`A.2.5.2` Basis for PII transfer between jurisdictions

The organization must tell the customer promptly on what basis personal data moves from one jurisdiction to another, and about any planned change to that basis, so that the customer can object or end the contract. It must document that it meets the laws and regulations that apply given where the data comes from and where it goes; inform the customer when data goes to suppliers or other parties, or to another country or an international organization; give notice of changes ahead of time within an agreed period; define the boundaries of any contractual right to make changes without telling the customer; and name the international transfer instruments it uses, along with the countries concerned and the situations each covers.

Source: ISO/IEC 27701:2025, A.2.5.2. 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

Notification records for changes, with the agreed advance timeframe · Document repository
Evidence the customer had a real opportunity to object · Document repository

governing documentDocuments that govern the control

Documented transfer basis per route, disclosed to the customer · Document repository
Contract terms setting the limits of any change made without notification · Vendor register / contract repository
Identification of the transfer instruments, the countries and the circumstances in which each applies · 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

Change notification given after the change took effect, removing the ability to object
Contractual allowance to change without notice drawn so broadly that the customer effectively waives the control
Transfer instruments named generically without saying which country each covers
Remote support access from another jurisdiction not treated as a transfer, so it is never disclosed
Notification sent to a commercial contact who has no privacy remit

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.2.4.4 PII transmission controls · A.2.5.3 Countries and international organizations to which PII can be transferred