ISO/IEC 27701:2025 is no longer dependent on ISO/IEC 27001 and introduces a new control structure for PII controllers, PII processors, and shared responsibilities.
The main difference between ISO/IEC 27701:2019 and ISO/IEC 27701:2025 is structural. The 2025 version transforms ISO/IEC 27701 into a standalone privacy management system standard, no longer formally tied to ISO/IEC 27001.
This change reflects regulatory and operational realities observed in 2024–2025, particularly in GDPR enforcement and audit practices. It allows organizations without ISO/IEC 27001 certification to implement a formal PIMS.
From a control perspective, ISO/IEC 27701:2025 removes the direct one-to-one mapping with ISO/IEC 27002. Controls are now grouped into three categories: PII controllers, PII processors, and shared controls. References to ISO/IEC 27002 remain possible but are no longer structurally dominant.
Clauses 4 through 10 have also been revised to align with modern ISO management system standards, with clearer expectations around leadership, planning, and continual improvement.
In practice, organizations must revisit control mapping, governance models, and compliance logic rather than applying superficial updates.
We often see organizations try to overlay ISO/IEC 27701:2025 on their 2019 structure without rethinking the underlying logic. This approach almost always leads to inconsistencies.
Successful transitions require rereading the standard from scratch. Controls must be justified by PII role, which significantly changes how compliance evidence is structured and presented.
““The 2025 version finally forces organizations to treat the PIMS as its own system, not an ISMS extension.””
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