What evidence do auditors commonly ask for on A.3.3 Policies for information security?

Policy text carrying an explicit commitment to applicable privacy law, regulation and contractual terms; Responsibility allocation between the organization, partners, subcontractors and third parties; Evidence applicable legislation was consulted at each policy review.

What is the most common gap auditors find on A.3.3?

Commitment to the law in general with no identification of which laws apply

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

`A.3.3` Policies for information security

The organization's information security policies, or a separate set of privacy policies, shall declare its backing for, and commitment to, meeting the PII protection laws and regulations that bind it and the contract terms settled with partners, subcontractors and relevant third parties such as customers and suppliers, and shall divide responsibilities among them without ambiguity. Whether it acts as a controller or as a processor of PII, the organization shall take the applicable PII protection laws and regulations into account each time these policies are written or revised.

Source: ISO/IEC 27701:2025, A.3.3. 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 applicable legislation was consulted at each policy review · Policy repository / GRC workspace

governing documentDocuments that govern the control

Policy text carrying an explicit commitment to applicable privacy law, regulation and contractual terms · Policy repository / GRC workspace
Responsibility allocation between the organization, partners, subcontractors and third parties · 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

Commitment to the law in general with no identification of which laws apply
Responsibility allocation absent, so a processor and its customer each assume the other notifies a breach

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.2.5.9 Change of subcontractor to process PII · A.3.4 Information security roles and responsibilities