Compliance — ISO 27701

ISO 27701: privacy management for the AI era.

ISO 27701 extends your information security management system to cover personal data processing. If your AI systems touch PII — training data, user interactions, inference inputs — you need a privacy management system that can keep pace.

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Why Now

AI multiplies your privacy surface.

Every AI system that processes personal data creates privacy obligations. Training data provenance. Inference input handling. User interaction logging. Model output attribution. The privacy surface of an AI-enabled organization is orders of magnitude larger than a traditional one.

ISO 27701 provides the management system to govern that surface. It's not a checklist. It's an operational framework for managing personal data across every touchpoint — including the ones AI creates that didn't exist two years ago.

Combined with ISO 42001 for AI governance, ISO 27701 creates a comprehensive framework for responsible AI deployment. Governance and privacy, together. Most organizations need both.

Our Approach

Assess. Integrate. Certify.

ISO 27701 extends ISO 27001. If you have an ISMS, we extend it. If you don't, we build both. Either way: one engagement, three phases, no gaps between them.

Phase 01 — Assess

Privacy Gap Assessment

Map your current data processing activities against ISO 27701 requirements. Identify personal data flows — including through AI systems. Determine whether you're operating as controller, processor, or both. Assess existing privacy controls against GDPR, CCPA, and sector-specific requirements.

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Phase 02 — Integrate

PIMS Implementation

Forward Deployed Engineers embed in your team to build the privacy information management system. Privacy-by-design integrated into your existing ISMS — not a parallel system. Data subject rights procedures, privacy impact assessments, processor management, breach notification processes, and privacy controls for AI data pipelines.

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Phase 03 — Certify

Certification Readiness

Evidence packaging, documentation review, mock assessments, staff preparation. ISO 27701 certification is audited alongside your ISO 27001 ISMS. We prepare you for both simultaneously. And because the PIMS is built on continuous monitoring, it stays current as your AI systems and data processing activities evolve.

Core Domains

What ISO 27701 actually covers.

ISO 27701 extends both ISO 27001 (management system requirements) and ISO 27002 (controls) with privacy-specific additions. Here are the core domains.

Data Subject Rights

Procedures for handling access, rectification, erasure, portability, and objection requests. Automated decision-making transparency. Mechanisms for individuals affected by AI-driven processing.

Privacy Impact Assessment

Structured methodology for assessing privacy risks of new processing activities — including AI model training, automated profiling, and large-scale personal data analytics.

Controller Obligations

Lawful basis determination, purpose limitation, data minimization, accuracy requirements, storage limitation, and accountability documentation for all personal data processing.

Processor Management

Contractual requirements, sub-processor oversight, data processing agreements, cross-border transfer mechanisms, and audit rights for third-party processors.

Consent & Transparency

Consent collection, withdrawal, and management. Privacy notices. Transparency about automated decision-making. Clear communication when AI systems process personal data.

Breach Management

Incident detection, classification, notification procedures, and remediation. Specific requirements for breaches involving AI-processed personal data, where scope and impact may be harder to determine.

Regulatory Mapping

One PIMS. Multiple regulations.

ISO 27701 maps directly to the world's major privacy regulations. Annex D provides a control-by-control mapping to GDPR. Implement the PIMS once. Demonstrate compliance across jurisdictions.

GDPR (EU)

ISO 27701 Annex D provides direct mapping to GDPR Articles and Recitals. The closest operational framework to a GDPR compliance certification available today.

CCPA / CPRA (California)

Data subject rights, processing inventory, and vendor management controls align with CCPA/CPRA requirements for consumer data protection.

ISO 42001 + EU AI Act

When AI systems process personal data, ISO 27701 (privacy) and ISO 42001 (AI governance) form a comprehensive framework. 9BRAINS implements both as an integrated system.

FAQ

Frequently asked questions.

What is ISO 27701?
ISO/IEC 27701:2019 is an extension to ISO 27001 and ISO 27002 that provides requirements for a Privacy Information Management System (PIMS). It establishes controls for both data controllers and data processors, making it the operational backbone for GDPR, CCPA, and other privacy regulation compliance.
Do I need ISO 27001 before implementing ISO 27701?
Yes. ISO 27701 extends ISO 27001 — it's not standalone. You need an existing ISMS certified to ISO 27001. If you don't have one, 9BRAINS can build both simultaneously as an integrated management system.
How does ISO 27701 relate to GDPR compliance?
Annex D of ISO 27701 maps directly to GDPR Articles and Recitals. Implementing a PIMS provides demonstrable evidence of compliance through documented data processing policies, data subject rights procedures, privacy impact assessments, and third-party processor management. It's the closest operational framework to a GDPR compliance certification.
Why does ISO 27701 matter for organizations deploying AI?
AI systems that process personal data create privacy obligations at scale — training data provenance, inference inputs, user interactions. ISO 27701 provides the privacy management layer. Combined with ISO 42001, it creates a comprehensive framework for responsible AI covering both governance and privacy.
How long does ISO 27701 implementation take?
For organizations with an existing ISO 27001 ISMS: 3–6 months. For organizations building both ISMS and PIMS simultaneously: 6–12 months. Forward Deployed Engineers embed in your team to accelerate delivery.

Privacy management that keeps
pace with your AI.

Tell us about your data processing landscape. We'll assess whether ISO 27701 is the right framework — and how it fits with your existing management systems.

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