What evidence do auditors commonly ask for on A.3.5 Classification of information?

Classification scheme with PII and special categories as explicit classes; Data inventory or map derived from the classification showing where PII resides and flows; Evidence systems processing PII are classified accordingly.

What is the most common gap auditors find on A.3.5?

PII treated as ordinary confidential information with no distinction for special categories

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

`A.3.5` Classification of information

The organization's scheme for classifying information shall treat PII expressly, including its kinds and any special categories, so that classification becomes the way the organization knows which PII it handles, where it is held and which systems it may pass through.

Source: ISO/IEC 27701:2025, A.3.5. 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 systems processing PII are classified accordingly · Data governance / DLP tooling

governing documentDocuments that govern the control

Classification scheme with PII and special categories as explicit classes · Policy repository / GRC workspace
Data inventory or map derived from the classification showing where PII resides and flows · 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

PII treated as ordinary confidential information with no distinction for special categories
Classification applied to documents but not to databases and data flows

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.3.4 Information security roles and responsibilities · A.3.6 Labelling of information