What evidence do auditors commonly ask for on A.3.26 Use of cryptography?

Cryptography rules identifying the PII types that jurisdictions require to be encrypted; Customer-facing information on where cryptography is applied to PII and the capabilities offered; Evidence of encryption of the identified PII types at rest and in transit.

What is the most common gap auditors find on A.3.26?

Special categories stored in clear because the rule addressed only data in transit

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

`A.3.26` Use of cryptography

The organization's cryptography rules shall take account of the fact that certain jurisdictions mandate encryption for specific categories of PII, for instance health records, national resident registration numbers, passport numbers and driving licence numbers. The organization shall also tell the customer when and where it applies encryption to the PII it handles, and what features it offers that would let the customer add its own cryptographic protection.

Source: ISO/IEC 27701:2025, A.3.26. 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 encryption of the identified PII types at rest and in transit · Document repository

governing documentDocuments that govern the control

Cryptography rules identifying the PII types that jurisdictions require to be encrypted · Document repository
Customer-facing information on where cryptography is applied to PII and the capabilities offered · Document 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

Special categories stored in clear because the rule addressed only data in transit
Customers unaware whether their PII is encrypted

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.3.25 Logging · A.3.27 Secure development life cycle