What evidence do auditors commonly ask for on A.3.6 Labelling of information?

Definition of PII communicated to personnel with examples; Labelling conventions for PII in systems and documents; Evidence personnel can recognise PII in practice, for example through spot checks.

What is the most common gap auditors find on A.3.6?

Labelling limited to a confidentiality marking that says nothing about PII

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

`A.3.6` Labelling of information

The organization shall make sure the people working under its direction know what counts as PII and can tell when a piece of information is PII, so that the labelling and handling rules are applied to it wherever it appears.

Source: ISO/IEC 27701:2025, A.3.6. 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 personnel can recognise PII in practice, for example through spot checks · Data governance / DLP tooling

governing documentDocuments that govern the control

Definition of PII communicated to personnel with examples · Policy repository / GRC workspace
Labelling conventions for PII in systems and documents · 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

Labelling limited to a confidentiality marking that says nothing about PII
Personnel unable to recognise indirect identifiers as PII

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.3.5 Classification of information · A.3.7 Information transfer