What evidence do auditors commonly ask for on A.2.5.5 Notification of PII disclosure requests?

Documented procedure for handling legally binding disclosure requests, including the notification route and timeframe; Contract terms setting the agreed timeframe and procedure; Records of requests received, notifications made, and where notification was prohibited, the basis; Legal review step before any disclosure is made.

What is the most common gap auditors find on A.2.5.5?

Requests handled by whoever receives them, with no procedure and no notification

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

`A.2.5.5` Notification of PII disclosure requests

The organization must tell the customer about every legally binding request it receives to disclose personal data, doing so within the timescales and through the process agreed, which the customer contract may set out. It should recognise that some binding requests forbid telling anyone about them, for instance a criminal law restriction intended to keep an investigation confidential.

Source: ISO/IEC 27701:2025, A.2.5.5. 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 requests received, notifications made, and where notification was prohibited, the basis · Document repository
Legal review step before any disclosure is made · Document repository

governing documentDocuments that govern the control

Documented procedure for handling legally binding disclosure requests, including the notification route and timeframe · Policy repository / GRC workspace
Contract terms setting the agreed timeframe and procedure · 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

Requests handled by whoever receives them, with no procedure and no notification
Notification prohibition assumed from the tone of the request rather than established legally
No record kept where notification was prohibited, so the organization cannot show it acted properly once the prohibition lifts
Timeframe agreed in contract but not achievable by the actual process
Notification sent to a commercial contact rather than the customer's privacy function

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.2.5.4 Records of PII disclosures to third parties · A.2.5.6 Legally binding PII disclosures