What evidence do auditors commonly ask for on A.2.5.6 Legally binding PII disclosures?

Documented rule that non binding requests are rejected, with the assessment step that decides bindingness; Evidence of customer consultation before disclosure; Register of requests with the outcome and the reasoning; Contract terms covering how consultation and authorisation work.

What is the most common gap auditors find on A.2.5.6?

Informal requests from authorities complied with voluntarily, which the control expressly prohibits

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

`A.2.5.6` Legally binding PII disclosures

The organization must turn down any request to disclose personal data that is not legally binding, must speak to the customer concerned before disclosing anything, and must honour disclosure requests that the contract provides for and the customer has approved. It should recognise that these requests may come from courts, tribunals or administrative bodies in any jurisdiction; how the process works can be written into the customer contract.

Source: ISO/IEC 27701:2025, A.2.5.6. 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

moderate

to go live

Cloud console / configuration management

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

Documented rule that non binding requests are rejected, with the assessment step that decides bindingness · Cloud console / configuration management

periodic reviewEvidence produced at each review

Evidence of customer consultation before disclosure · Document repository

governing documentDocuments that govern the control

Register of requests with the outcome and the reasoning · Policy repository / GRC workspace
Contract terms covering how consultation and authorisation work · Vendor register / contract repository

First move

Start with the 1 of 4 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Informal requests from authorities complied with voluntarily, which the control expressly prohibits
Bindingness judged by operations staff with no legal input
Customer consulted after disclosure rather than before
Cross border requests accepted without checking whether the authority has jurisdiction over the organization
No register, so a pattern of requests about one customer is invisible

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.2.5.5 Notification of PII disclosure requests · A.2.5.7 Disclosure of subcontractors used to process PII