What evidence do auditors commonly ask for on A.3.16 Compliance with policies, rules and standards for information security?

Compliance review programme covering PII processing components; Monitoring evidence that only permitted processing occurs; Results of penetration, vulnerability or motivated intruder tests on PII systems and de-identified datasets.

What is the most common gap auditors find on A.3.16?

Compliance reviews that test security configuration and never the processing rules

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

`A.3.16` Compliance with policies, rules and standards for information security

When the organization technically checks conformance with its security policies and standards, it shall include ways of examining the tools and components that process PII. These can include continuous monitoring to confirm that no processing takes place beyond what is authorised, as well as targeted penetration or vulnerability testing, such as a motivated intruder exercise against de-identified datasets to confirm that the de-identification techniques satisfy the organization's own requirements.

Source: ISO/IEC 27701:2025, A.3.16. 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

easy

to go live

SIEM / log platform

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

Monitoring evidence that only permitted processing occurs · SIEM / log platform
Results of penetration, vulnerability or motivated intruder tests on PII systems and de-identified datasets · Vulnerability scanner / patch tooling

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Compliance review programme covering PII processing components · Document repository

First move

Automate the pull from your SIEM / log platform. Retention and alert rules exported from the SIEM; review evidence is the closed-alert record with reviewer and time.

Common gaps auditors find

Compliance reviews that test security configuration and never the processing rules
De-identification asserted without any re-identification test

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.3.15 Independent review of information security · A.3.17 Information security awareness, education and training