What evidence do auditors commonly ask for on A.2.5.4 Records of PII disclosures to third parties?

Disclosure log covering routine and exceptional disclosures; Source of the disclosure and the authority relied on, per entry; Coverage of investigation and audit disclosures; Access control and retention rules over the log itself.

What is the most common gap auditors find on A.2.5.4?

Law enforcement and audit disclosures handled outside the logged route

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

`A.2.5.4` Records of PII disclosures to third parties

The organization must keep a record of each disclosure of personal data to a third party, stating which data went, to whom and on what date. The record covers disclosures in the ordinary course of business as well as others, for example those made for lawful investigations or outside audits, and for each it notes where the disclosure came from and what gave the authority to make it.

Source: ISO/IEC 27701:2025, A.2.5.4. 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

easy

to go live

SIEM / log platform

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

Disclosure log covering routine and exceptional disclosures · SIEM / log platform
Access control and retention rules over the log itself · Identity provider / directory

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Source of the disclosure and the authority relied on, per entry · Document repository
Coverage of investigation and audit disclosures · Policy repository / GRC workspace

First move

Automate the pull from your SIEM / log platform. Retention and alert rules exported from the SIEM; review evidence is the closed-alert record with reviewer and time.

Common gaps auditors find

Law enforcement and audit disclosures handled outside the logged route
Log recording that a disclosure occurred without identifying what data left or whose
Authority not recorded, so the disclosure cannot later be justified to the customer
Log held by the responding function rather than centrally, so no complete picture exists

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.2.5.3 Countries and international organizations to which PII can be transferred · A.2.5.5 Notification of PII disclosure requests