What evidence do auditors commonly ask for on A.3.18 Confidentiality or non-disclosure agreements?

Confidentiality clauses or agreements covering everyone with access to PII, with duration stated; Evidence agents and contractors are bound as well as employees; Processor agreements binding staff to the data handling policy.

What is the most common gap auditors find on A.3.18?

Confidentiality obligation that ends at termination when the PII obligation does not

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

`A.3.18` Confidentiality or non-disclosure agreements

Everyone working under the organization's direction who can reach PII shall be bound by a duty of confidentiality, set out either in their contract or in a standalone agreement that states how long the duty continues. Where the organization acts as a PII processor, the confidentiality undertaking, however it is framed, between the organization and its staff and agents shall commit them to follow the data handling and protection policy and procedures.

Source: ISO/IEC 27701:2025, A.3.18. 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

Vendor register / contract 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 agents and contractors are bound as well as employees · HR system / LMS

governing documentDocuments that govern the control

Confidentiality clauses or agreements covering everyone with access to PII, with duration stated · Vendor register / contract repository
Processor agreements binding staff to the data handling policy · 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

Confidentiality obligation that ends at termination when the PII obligation does not
Agents and outsourced staff never signed

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.3.17 Information security awareness, education and training · A.3.19 Clear desk and clear screen