A New Chapter in Privacy Governance

Overview

On 14 October 2025, ISO officially published ISO/IEC 27701:2025, the second edition of the Privacy Information Management System (PIMS) standard, marking a major evolution from the 2019 version.

Previously seen as an extension to ISO/IEC 27001, the 2025 edition now stands independently, reflecting the global realisation that privacy is no longer a subset of security; it’s a discipline in its own right.

As data-driven operations, AI ecosystems, and global data transfers redefine how information moves across borders, organisations are under increasing pressure to prove not just that data is protected, but that privacy is governed, measurable, and auditable.

What’s New in ISO/IEC 27701:2025

The 2025 edition incorporates several key advancements designed for modern digital ecosystems:

• Independent Framework: ISO/IEC 27701 now features its own management system clauses (4–10), allowing PIMS to operate as a standalone standard.
• Enhanced Privacy Risk Management: Greater emphasis on identifying and treating privacy-specific risks, especially around AI-driven processing, automated decision-making, and third-party data ecosystems.
• Broader Scope for Controllers and Processors: Updated control objectives and guidance in Annex A address both PII controllers and processors, ensuring accountability across the data lifecycle.
• Implementation Guidance (Annex B): Clear “best practice” recommendations for deploying A.1–A.3 controls, fostering consistency in implementation and auditability.
• Compatibility and Transition (Annex F): Provides backward alignment with ISO/IEC 27701:2019 to help certified organisations transition smoothly.

These refinements not only modernise privacy management but also align with emerging standards like ISO/IEC 42001:2023 (Artificial Intelligence Management Systems), signalling a future where privacy and AI ethics coexist under an integrated governance model.

Transitioning from ISO/IEC 27701:2019 to ISO/IEC 27701:2025

The ISO/IEC 27701:2019 standard was replaced by ISO/IEC 27701:2025 on 14 October 2025, signifying the transition of Privacy Information Management Systems into a standalone global standard.

While existing ISO/IEC 27701:2019 certifications remain valid for now, organisations are encouraged to begin preparing for the shift. Based on previous ISO transition patterns, a transition period of around two to three years can be reasonably anticipated for organisations to adapt to the new framework.

To ensure a smooth transition, organisations should:

• Conduct a gap analysis to compare current practices with the new requirements.
• Review and update privacy roles and responsibilities to align with the revised governance model.
• Engage with their certification body early to plan transition audits and timelines.

By starting now, organisations can align their privacy management systems with the 2025 requirements, strengthen governance maturity, and avoid last-minute compliance challenges as the transition window progresses.

Why the Update Matters

The 2025 revision transforms ISO/IEC 27701 from a supporting framework into a standalone privacy management system, enabling organisations to establish, implement, maintain, and continuously improve privacy governance independently or in alignment with ISO/IEC 27001:2022.

• For CISOs and Data Protection Officers, this means privacy risk now sits on equal footing with information security risk.
• For Compliance and Privacy Managers, the new edition introduces measurable governance structures, defined privacy roles, and performance metrics for continuous improvement.
• For Executives, ISO/IEC 27701:2025 is a strategic instrument, turning privacy compliance into business trust, competitive advantage, and brand credibility.

FAQs – Frequently Asked Questions