What evidence do auditors commonly ask for on A.2.5.9 Change of subcontractor to process PII?

Change notification procedure with the notice period and the objection route; Records of notifications given and objections received, with outcomes; Evidence that new subcontractors did not begin processing before authorization; Contract terms establishing the general authorization and its conditions.

What is the most common gap auditors find on A.2.5.9?

Notification given at the point of change or after, so the objection right is theoretical

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

`A.2.5.9` Change of subcontractor to process PII

Where it operates under a general written authorization, the organization must tell the customer in advance about any planned addition or replacement of a subcontractor that processes personal data, so that the customer can raise an objection. Where the organization swaps the subcontractor doing part or all of the processing, the customer's written authorization must be in place before the new subcontractor starts, given either through suitable terms in the customer contract or through a one-off agreement for that change.

Source: ISO/IEC 27701:2025, A.2.5.9. 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 notifications given and objections received, with outcomes · Document repository
Evidence that new subcontractors did not begin processing before authorization · Document repository

governing documentDocuments that govern the control

Change notification procedure with the notice period and the objection route · Policy repository / GRC workspace
Contract terms establishing the general authorization and its conditions · 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

Notification given at the point of change or after, so the objection right is theoretical
Objection received and overridden commercially with no record of the resolution
Replacement subcontractor onboarded and processing during the notice period
Notification published on a webpage the customer is expected to monitor rather than sent
No notice period defined, so timely is whatever the organization decides

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.2.5.8 Engagement of a subcontractor to process PII · A.3.3 Policies for information security