When you tell the story of your business, privacy management may just play a leading role. On October 14, 2025, ISO 27701:2025 was published. This is the updated Privacy Information Management System standard.

The 2019 version of ISO 27701 was an extension to ISO 27001. Organisations needed an ISMS (Information Security Management System) before they could certify their privacy practices. That requirement is now gone. 

With ISO 27701:2025, organisations can now prove their privacy maturity without first certifying their security framework.

Want to implement ISO 27701:2025 in your organisation? Schedule a free 15-minute consultation with Riskora.

What Changed: From Extension to Independence

The change at the heart of ISO 27701:2025 is simple but profound. ISO 27701:2025 no longer requires ISO 27001 certification as a prerequisite. Privacy-focused organisations can now pursue PIMS certification directly. This lowers the barrier for entry for small businesses, non-profits and data-driven companies.

The new standard follows ISO’s harmonised high-level structure and has been streamlined to 29 information security controls from ISO 27001. These are specifically the ones with a direct impact on privacy. The GDPR mapping annexe has also been revised to better illustrate how the new standard supports compliance with global privacy laws.

Stronger Accountability and Legal Alignment

One of the most critical improvements is the emphasis on accountability. ISO 27701:2025 doesn’t just tell you what to do, it requires you to prove you’re doing it.

Clause 5 strengthens leadership requirements and means that top management must demonstrate an active commitment to privacy governance. They must assign clear roles and establish measurable privacy objectives.

The standard requires privacy objectives to be tracked through KPIs. Management must review privacy performance periodically. Privacy management becomes a governance function requiring the same attention as financial controls or operational risk.

Expanded Risk Controls and Integration

Clause 6 incorporates risk-based thinking for privacy, aligning with ISO 27001:2022 and ISO 31000. Privacy risk is no longer treated as secondary to security risk – it’s evaluated, tracked and mitigated with the same rigor.

Organisations must identify privacy risks across the data lifecycle, assessing the likelihood and impact of potential breaches as they go. They must implement controls proportional to those risks, overseeing the collection, usage, sharing and deletion of data. They include requirements for consent management, data subject rights, and breach notification.

The alignment with ISO 42001, the AI management system standard, is particularly significant. Organisations using both standards can create integrated governance, ensure AI systems respect privacy principles, and demonstrate accountability for automated decision-making.

The integration with ISO 31000 strengthens risk management – empowering organisations to identify privacy risks in the context of enterprise risk. Mitigation can be prioritised based on overall risk appetite.

Privacy as a Trust Framework for Responsible AI

Privacy management has evolved from a compliance checkbox to a trust framework. In an era of AI, big data, and global digital commerce, privacy is fundamental to business sustainability. The EU AI Act requires transparency, human oversight and accountability for high-risk AI systems. ISO 27701:2025 provides mechanisms to demonstrate compliance with these requirements.

Organisations can differentiate themselves when they manage privacy well. In the process they can win customer trust,reduce regulatory risk, and attract privacy-conscious partners. Privacy can become a competitive advantage rather than a compliance burden.

What Organisations Should Do Now?

Organisations currently certified to ISO 27701:2019 standards should begin planning their transition. Certification bodies are expected to establish a 24 to 36 month transition period.

Start your transition planning with a gap analysis – compare your current PIMS to the 2025 requirements. Focusing on Clauses 4 through 10 and the revised annexes, identify where policies, procedures and controls need updating.

Review and update your statement of applicability (SoA). The SoA is your declaration of which controls you’ve implemented and why – you should ensure it reflects the 29 security controls and all privacy-specific requirements.

Update your risk assessment to incorporate privacy-specific risks. Align your privacy and security objectives to your organisational strategy, involving leadership early and actively. Privacy governance now requires board-level attention – executives must understand their accountability and allocate appropriate resources.

Update your documentation systematically, refreshing your privacy policy to reflect top management endorsement. Clarify roles and responsibilities. Define KPIs for privacy performance and document how technical controls link to the PIMS framework.

Train your teams comprehensively – engineers need to understand privacy-by-design principles, product managers need to recognise privacy implications, and customer-facing staff need to handle data subject requests properly. Training should be role-specific and practical.

Ready to Build Enterprise-Grade Privacy?

Don’t let the transition catch you unprepared. Riskora specialises in helping organisations implement ISO 27701:2025 and build comprehensive PIMS. Whether you’re starting fresh or upgrading from a 2019 certification, we can provide your organisation with expert guidance.

We help you conduct gap analysis, carry out risk assessments, and develop policies, procedures and controls. We can also prepare your organisation for any future certification audits.

Our free ISO 27001 audit checklist provides a structured approach to assessing organisational readiness. It covers documentation, core requirements, organisational controls, people controls, physical controls and technological controls. Use it to identify gaps, collect evidence, and build trust with clients.

Schedule a consultation with Riskora.io.
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