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

A.3.27 Secure development life cycle

The organization's system design and development policies shall give direction on how it handles PII, grounded in its duties to PII principals, the laws and regulations that apply and the kinds of processing it carries out, with the Annex A controls supplying the points to weigh. Policies supporting privacy by design and by default shall take into account: direction on protecting PII and on applying the ISO/IEC 29100 privacy principles through the development life cycle; privacy requirements set at design stage on the basis of a privacy risk or impact assessment; privacy checkpoints built into project milestones; the privacy expertise the work calls for; and keeping PII processing to a minimum as the default.

Source: ISO/IEC 27701:2025, A.3.27. 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.

4
artefacts
1
held by a system
1
at each review
moderate
to go live
Source control / CI pipeline
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

  • Default settings that minimise PII processing · Source control / CI pipeline

periodic reviewEvidence produced at each review

  • Privacy checkpoints in project milestones and evidence they are applied · Source control / CI pipeline

governing documentDocuments that govern the control

  • Development policy carrying the privacy by design and by default elements · Policy repository / GRC workspace
  • Privacy requirements captured at design from risk or impact assessment · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Source control / CI pipeline); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

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.

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A.3.26 Use of cryptography · A.3.28 Application security requirements