What evidence do auditors commonly ask for on A.3.4 Information security roles and responsibilities?

Appointment of the privacy programme lead with reporting line, independence and competence evidenced; Published points of contact for customers and for PII principals; Evidence the role is consulted on processing decisions and privacy impact assessments; Contact point registered with the supervisory authority where the jurisdiction requires it.

What is the most common gap auditors find on A.3.4?

Role appointed with no authority over the processes that process PII

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

`A.3.4` Information security roles and responsibilities

The organization shall name a contact for customers on matters of PII processing and, where it acts as a PII controller, a contact for PII principals on how their own PII is processed. It shall also give one or more people the job of building, running, keeping up and overseeing a privacy and governance programme across the whole organization that secures conformance with the laws and regulations governing PII processing. Where appropriate, that person shall: be independent and answer directly to the right level of management; take part in handling every matter concerning PII processing; have expert knowledge of data protection law, regulation and practice; serve as the contact for supervisory authorities; brief top management and staff on their duties; and give advice on privacy impact assessments. Some jurisdictions name this role the data protection officer and specify when one must be appointed; it may be filled internally or outsourced.

Source: ISO/IEC 27701:2025, A.3.4. 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

HR system / LMS

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 the role is consulted on processing decisions and privacy impact assessments · Identity provider / directory

governing documentDocuments that govern the control

Appointment of the privacy programme lead with reporting line, independence and competence evidenced · HR system / LMS
Published points of contact for customers and for PII principals · Document repository
Contact point registered with the supervisory authority where the jurisdiction requires it · Policy repository / GRC workspace

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

Role appointed with no authority over the processes that process PII
Point of contact for individuals buried where they cannot find it
Data protection officer who is also the head of the function whose processing they oversee

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.3.3 Policies for information security · A.3.5 Classification of information