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IEC 27002 for privacy information management — Requirements and guidelines (first edition)

Abstract

“This document specifies requirements and provides guidance for establishing, implementing, maintaining and continually improving a Privacy Information Management System (PIMS) in the form of an extension to ISO/IEC 27001 and ISO/IEC 27002 for privacy management within the context of the organisation. ...”

[Source: ISO/IEC 27701:2019]

Introduction

Although there is substantial overlap between information security and privacy management, both fields are broader and go beyond each other. This standard explains how to ‘enhance’ (adapt and extend) an ISO/IEC 27001 Information Security Management System and the associated ISO/IEC 27002 controls to manage privacy as well as information security.

Scope of the standard

The standard specifies a Privacy Information Management System based on ISO/IEC 27001(ISMS), 27002 (security controls) and 29100 (privacy framework). It is applicable to both controllers and processors of Personally Identifiable Information.

‘27701 builds and depends upon ‘27001: organisations need to have an ISMS certified compliant to ‘27001 in order for their PIMS to be certified compliant to ‘27701.

Essentially the phrase ‘information security’ in ISO/IEC 27001 becomes ‘information security and privacy’.

Content of the standard

In the style of a sector-specific variant of ISO/IEC 27001, the ~70 page standard elaborates on the PIMS-related differences to the ’27001 and ’27002 standards clause-by-clause.

For example:

“ISO/IEC 27001:2013, 6.1.3.c) is refined as follows:

The controls determined in 6.1.3 b) of ISO/IEC 27001:2013 shall be compared with those in ISO/IEC 27001:2013, Annex A and/or Annex B of this document to verify that no necessary controls have been omitted.

When assessing the applicability of control objectives and controls from ISO/IEC 27001:2013 Annex A for the treatment of risks, the control objectives and controls shall be considered in the context of both risks to information security as well as risks related to the processing of PII, including risks to PII principals.”

Status

The first edition was published in 2019.

The standard is currently being updated to reflect the 2022 editions of ISO/IEC 27001 and ISO/IEC 27002. It is already at Draft International Standard stage, with a shorter title omitting “Information Technology”. However, ISO expects the standard to adopt the updated Management System Standard structure from Annex SL of the ISO Directives, which is awkward since ISO/IEC 27001:2022 pre-dates that update. So, completion and publication of the revised standard will therefore be somewhat delayed.

Personal notes

Practitioners familiar with ‘the ISO27k way’ should have little difficulty applying the usual information risk management principles to personal information i.e.:

Identify privacy-related risks;
Evaluate them;
Decide how to treat them (what, if anything, to do about them);
Treat them (implement the risk-treatment decisions);
Lather, rinse, repeat.

Thanks to the standard elaborating on the requirements, even others ought to be able to have a jolly good stab at it.

An accompanying accreditation standard directs certification auditors on how to audit a PIMS and issue meaningful certificates for conformity with ’27701 - see ISO/IEC TS 27006-2. Note that, as with ‘27001 ISMS certification, the emphasis is on verifying that the management system fulfills all the mandatory requirements of ’27701 ... which is subtly different from actually having all the appropriate privacy arrangements in place. For implementers and certification auditors alike, the challenge is that ‘appropriate’ is not laid out in ’27701 but is determined by the organisation itself. It is context-dependent.

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