What evidence do auditors commonly ask for on A.2.5.7 Disclosure of subcontractors used to process PII?

Current subcontractor list with names, the countries they can transfer to, and how their obligations are secured; Evidence of disclosure before use, not after; Contract provisions covering subcontractor disclosure; Where disclosure is restricted, the risk assessment behind it and evidence the customer knows the information is available; Evidence the country list is disclosed in all cases.

What is the most common gap auditors find on A.2.5.7?

Subcontractors disclosed only on request, with customers never told the information exists

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

`A.2.5.7` Disclosure of subcontractors used to process PII

The organization must tell the customer, before it happens, whenever subcontractors will process personal data, with terms to that effect in the customer contract. The disclosure covers the fact of subcontracting, who the subcontractors are, which countries and international organizations they may send data to, and how they are bound to match or go beyond the organization's own obligations. If making subcontractor details public would push security risk past acceptable levels, the organization may disclose them under a non-disclosure agreement or on request, provided the customer is told the details can be obtained. The list of countries must be disclosed in every case, so that the customer can inform the individuals affected.

Source: ISO/IEC 27701:2025, A.2.5.7. 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

Evidence of disclosure before use, not after · Document repository
Where disclosure is restricted, the risk assessment behind it and evidence the customer knows the information is available · Policy repository / GRC workspace
Evidence the country list is disclosed in all cases · Document repository

governing documentDocuments that govern the control

Current subcontractor list with names, the countries they can transfer to, and how their obligations are secured · Document repository
Contract provisions covering subcontractor disclosure · 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

Subcontractors disclosed only on request, with customers never told the information exists
New subcontractors used first and disclosed at the next contract review
List naming subcontractors without their transfer destinations, so the customer cannot inform individuals
Security risk cited to withhold the country list, which the standard says must always be disclosed
Fourth party subcontractors, engaged by the organization's own subcontractors, omitted entirely

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.2.5.6 Legally binding PII disclosures · A.2.5.8 Engagement of a subcontractor to process PII