Does ISO/IEC 27701 apply to both PII controllers and PII processors?

ISO/IEC 27701 explicitly applies to both PII controllers and PII processors, recognizing that privacy responsibilities differ depending on an organization’s role in processing personally identifiable information.

For PII controllers, the standard focuses on governance obligations such as defining processing purposes, establishing lawful bases, managing data subject rights, and overseeing third-party processors. For PII processors, ISO/IEC 27701 emphasizes contractual compliance, secure processing, and adherence to controller instructions.

The Lead Implementer training addresses this distinction in practical terms. Participants learn how to scope a PIMS correctly, identify controller and processor activities within the same organization, and apply controls proportionately. This is particularly important in hybrid environments where organizations act as both controller and processor depending on the service or dataset.

A common implementation failure is treating ISO/IEC 27701 as controller-only guidance. This course corrects that misconception by teaching how to structure roles, responsibilities, and controls that reflect real-world outsourcing, cloud services, and shared processing models.

Understanding and applying this distinction is critical for audit readiness and regulatory credibility.