What evidence do auditors commonly ask for on A.3.11 Information security incident management planning and preparation?

Incident procedure with a defined PII breach identification and recording step; Notification procedure naming parties, timing and the authority disclosure route per jurisdiction; Responsibilities assigned for breach handling; Evidence of testing the procedure.

What is the most common gap auditors find on A.3.11?

Security incident process with no PII breach determination step

ISO/IEC 27701:2025 · Annex A Table A.3 information security controls with PII-specific guidance

`A.3.11` Information security incident management planning and preparation

Within its information security incident management arrangements, the organization shall assign responsibilities and set procedures both for detecting and logging PII breaches and for informing the parties who must be told of them, covering when notice is given and how disclosure to authorities is made, in line with the laws and regulations that apply. Where a jurisdiction lays down particular rules on responding to and notifying breaches, the organization shall be able to show that it meets them.

Source: ISO/IEC 27701:2025, A.3.11. 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

Policy repository / GRC workspace

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 testing the procedure · Policy repository / GRC workspace

governing documentDocuments that govern the control

Incident procedure with a defined PII breach identification and recording step · Policy repository / GRC workspace
Notification procedure naming parties, timing and the authority disclosure route per jurisdiction · Policy repository / GRC workspace
Responsibilities assigned for breach handling · Policy repository / GRC workspace

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

Security incident process with no PII breach determination step
Notification timings unknown until a breach occurs
Procedure written for one jurisdiction while PII of several is processed

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.3.10 Addressing information security within supplier agreements · A.3.12 Response to information security incidents