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We are presenting a series of articles in this series to spread the awareness and understanding of ISO 27001, ISO 27701 and PDPCSI.

ISO 27001 is a certifiable standard while ISO 27701 is a requirement which can be certified only along with ISO 27001. ISO 27001 refers to ISMS where as ISO 27701 refers to PIMS.

On the other hand, PDPCSI (Personal Data Protection Compliance Standard of India) is a framework for Personal Data Protection by organizations in India in compliance with the legal standards such as Information Technology Act 2000/8 and the upcoming DPDPB 2023. PDPCSI refers to PDPCMS which is the personal data protection compliance management system.

Since PDPCMS/PDPCSI is focussed only on personal data, it compares directly with ISO 27701 instead of ISO 27001. However, since ISO 27701 cannot be implemented without ISO 27001 which is a foundation standard, an understanding of ISO 27001 will help us understand PDPCSI better. Also ISO 27001 is relevant for the preservation of CIA of personal data within PDPCSI where Model Implementation Specifications (MIS) 31-50 address different aspects of security under the CIA concept. Hence there is some comparison between PDPCSI and ISO 27001 which may be relevant.

Readers may kindly appreciate the context in which this series of articles have been presented and read all articles in the series besides information available on PDPCSI.

In this article let us continue our discussion on ISO 27001 and discuss the recommended Governance Structure to meet the objectives of ISO 27001:2022.

Clause 5 of ISO 27001 on leadership lists out the following requirements as “demonstration of leadership and Commitment” of an organization.

a) ensuring the information security policy and the information security objectives are established and are compatible with the strategic direction of the organization;

b) ensuring the integration of the information security management system requirements into the organization’s processes;

c) ensuring that the resources needed for the information security management system are available;

d) communicating the importance of effective information security management and of conforming to the information security management system requirements;

e) ensuring that the information security management system achieves its intended outcome(s);

f) directing and supporting persons to contribute to the effectiveness of the information security management system;

g) promoting continual improvement; and

h) supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.

Under Clause 5.3, the standard prescribes that

Top management shall assign the responsibility and authority for:

a) ensuring that the information security management system conforms to the requirements of this document;

b) reporting on the performance of the information security management system to top management.

We can interpret the above requirements as projecting a need of a designated Information Security Manager (ISM) or Chief Information Security Officer (CISO) so that there is accountability for implementation and reporting to the top management.

Even ISO 27701 does not clearly specify the need of a DPO which is mandatory in many laws for certain category of implementers.

Under PDPCSI which requires compliance of law directly, it is essential to define the role of the implementing organization and the mandatory need for a designated role of a Data Protection Officer. It suggests the three levels of governance Governance Committee, DPO and Process Level Data Controllers besides a “Privacy Officer” in a large organization.

As a recommendation, most experienced auditors recommend that under ISO 27001 there shall be a “CISO” or “ISM” who will be responsible for implementation and monitoring as well as internal audit. It is common for organizations to use the assistance of external consultants when ISO 27001 is implemented for the first time and also get Certified by an independent auditor. Maintenance is done by the CISO and the certification audit is renewed from time to time normally after 3 years.

Naavi suggests that the Governance system

1. A Governance Committee (Steering Committee) to provide overall guidance
2. CISO to be the designated person responsible for coordinating the entire activity
3. Support team which can be called the IS organization.

Though not specified by most ISO auditors, Naavi suggests that it is necessary to identify the following support roles.

a) Data Custodians for each data store

b) Controllers who monitor incoming data and data disclosures

c) Controllers who monitor the different data transformation processes within the organization.

If an organization has multiple locations and business divisions, it would be better if Information Security Champions are identified at each of the divisions and the locations to assist the CISO as a central coordinator.

The Steering committee will have representation of all stake holders within the organization and will ensure that there is cooperation of all stakeholders in the implementation on a continuing basis.

The organization should not project ISMS as the responsibility of only the IT department since it is more an organizational responsibility than the IT responsibility. The “Security Culture” should pervade the entire organization.

Some of these suggestions cannot be directly indicated in a framework document and has to suggested by experienced consultants.

We shall discuss the Annex A controls individually which provides the high level indication of what is expected as a “Control” within which we shall draw inferences on not only the suggested Governance Structure but on other aspects as well.

Naavi

In the previous article we discussed the need for creating Asset Inventory as part of the Context setting.

In the process, we identified four different aspects such as “Data Storage Points”, “Data Collection Points”, Data Processing Points” and “Data Disclosure Points” to be identified in a network to create the Asset inventory. We also discussed the concept of “Data Valuation”. We did not stop at looking at Data Value from the abstract concept of “Everything that assists the business has a value” but went on to underscore the need for assigning the rupee value of the asset that can be brought into the balance sheet if need be.

If we want the CFO to sanction a budget for ISMS, then he has to be convinced that there is an X crores worth of data that needs to be protected and the ISMS will mitigate the risk of loss or erosion of this X Crore asset value. For this purpose assessing the rupee value of the asset is important and Naavi’s DVSI (Data Value Standard of India) tries to suggest some methodology for the purpose particularly for the Personal data.

In the context of ISO 27001, the valuation in rupee terms is relevant since if there is a ransomware attack, the hacker would ask for a ransom based on his estimated value of the data. His valuation of data may either be based on the market value for the data in the Dark Web or the amount upto which the organization would pay to protect its reputation damage or save on cost of reconstruction of data. For the organization therefore “Opportunity Cost” and ” potential damage” is a measure of value. For the hacker the “Realisable market value” is a measure of its value.

If the ISMS manager wants to assign a value it may depend on the nature of the activity of the organization. If Data is a raw material in the business of the Company and gets converted into finished goods at the end of a process (Eg Data Analytics Company) then the value can be computed on the basis of the accumulated cost from generation of the data to its current status in the life cycle moderated by revaluation based on the market value. If data is only a tool of business, its value is based on the cost of creation only.

Whatever be the methodology used for valuation and whether it is only an approximation for the purpose of a “Note to the Accounts” or to be incorporated in the balance sheet as a “Contra Item”, there is a need to first classify the information into different value buckets.

In the ISMS context, data classification is based on the “Risk Potential” and hence it is common to observe a classification as “Confidential”, “Restricted”, “Internal” and “Public”.

Some examples of classification on this basis are

• Confidential: This level of classification applies to information that could cause serious harm to the organization if it were disclosed to unauthorized individuals. Examples of confidential information include trade secrets, financial data, and customer information.
• Restricted: This level of classification applies to information that could cause some harm to the organization if it were disclosed to unauthorized individuals. Examples of restricted information include employee records, marketing plans, and product development information.
• Internal: This level of classification applies to information that is not confidential or restricted, but that should not be disclosed to the public. Examples of internal information include employee training materials, meeting minutes, and financial reports.
• Public: This level of classification applies to information that is not confidential, restricted, or internal. Examples of public information include press releases, product brochures, and website content.

On the other hand, a PII classification has to be done under scales based on the “Sensitivity” . For examples as against a general categorization of “Personal Data”, one can create a category “Sensitive Personal Data” or “Critical Personal Data” based on different risk profiles of the data itself.

Hence Data has to be first classified as “Personal” and “Non Personal”, and then Non Personal Data should be classified based on the Confidential, Restricted, Internal and Public criteria and Personal data classified as is relevant for the applicable law.

PDPCSI or any other Privacy frameworks therefore use a classification different from the ISO 27001. PDPCSI goes a step further than other frameworks since it recommends sensitivity based classification on whether the data belongs to the Employees or others, Minors or Adults , Deceased individuals or Living Individuals etc.

The classification suggested under A 5.12 of ISO 27001 states….

“Information shall be classified according to the information security needs of the organization based on confidentiality, integrity, availability and relevant interested party requirements.”

ISO 27701:2019 refers to EU GDPR in its introductory reference but does not provide clear guidelines within the document. Hence classification based on GDPR will drive ISO 27701.

On the other hand, PDPCSI pitches the classification requirement to be “Compliance Based” and states as follows

“The organization shall classify  data based on nature of personal data, its sensitivity, type of data subject, whether   minor data or employee data is involved,   the country of origin, etc”

Thus the Context setting includes creation of a data inventory along with the classification.

Apart from creating an “Inventory of Data” where it lies in storage, it is also necessary to identify the “Process Inventory” which lists all the processes where the input data and output data is different. The modification of data that occurs within a process is to be captured for risk assessment (eg Automated Decision making risks). This will also assist in designating “Process Controllers”, “Consent Controllers”, “Disclosure Regulators” and “Data Custodians” who are all different organs of the ISMS Manager.

To further take control of the Data inventory, it is necessary to identify the Data Input points and Data Disclosure points so that the Inventory of data in storage and data in process can be managed from the point of view of CIA principles. Data Disclosure in this context is mainly to the external parties since internal data disclosure gets merged with transfer of data from one process to another as an input data into the next process.

To summarize, after setting the context for ISMS, we should have a proper understanding of the classified data based on an acceptable criteria. We should know where the data is stored, where all they are processed, which are the input and exit points to be secured.

In the Planning stage these are important steps that needs to be completed before we go further into the creation of the ISMS Governance structure. Then we go into creation of policy documents, then to implementation of controls, then to review and correction. These are the steps that ISMS has to go through .

(To Be Continued)

Naavi

Before an organization sets about to establish an ISMS or an auditor starts an ISO 27001 audit, it is essential to understand and set the ‘Context’ in which the activity needs to be planned and implemented.

By ‘Context’ we mean the internal and external issues that reflect the constraints for the activity of the organization.

To the extent these constraints are manageable, they can be addressed as part of the suggested business policy changes that can accompany the setting up of the ISMS. To the extent the constraints are internal and affect the ISMS risks, they need to be mitigated as a part of the risk management policy. To the extent the constraints are not controllable, they need to be accepted and risks arising thereof become absorbed risks.

Most of the time the role of an auditor arises in an existing organization which already has established a vision and mission and has a top management Governance system tuned to business objectives. The IS objectives are to be integrated into this structure. In the process it may cause disruptions of existing systems and hierarchy of decision making which has to be recognized as an “Implementation Risk” and has to be handled with finesse.

This is the toughest part of the activity of ISMS and is often addressed as the challenge of getting a Buy-In by the top management. A successful ISMS auditor needs to therefore have the skills of communication and persuasion required to get the plan accepted and resources sanctioned.

Most often, the ISMS activity in an organization is triggered because the market forces dictate them. Some clients would have raised a query “Are you ISO 27001 compliant? or Are you GDPR Compliant?”, or “Are you ITA 2008 Compliant?”, or “Are you DPDPB 2022/23 compliant?” etc.

The marketing person might have given a feedback that they may lose a prospective contract because of not being able to provide an assurance to the client about the status of Information Security/Privacy Protection in their company.

At this time, the Company needs to decide on what is required for them in the given context and chose if they have to go for ISO27001 or DPDPB 2022 or GDPR as a framework of designing its activity.

If a Company is operating in India entirely for the Indian customers, it has more value for ITA 2008 compliance than GDPR certification. If a company is interested in Privacy more than IS, priority has to be for GDPR than ISO 27001. In India ITA 2000/8 today is both an IS law as well as privacy law. The company has to determine this at the time it sets the context.

A GDPR or DPDPB 2022 framework may be recognized as a “Privacy Compliance” requirement and not an ISMS per-se. On the other hand ISO 27001 is an ISMS per-se and when associated with ISO 27701 adds Privacy also. However, a GDPR or DPDPB 2022 does address CIA principles of information security within the “Personal Information” domain and hence ISO 27001 is still relevant for implementation of GDPR or DPDPB. If the same principles are extended to Non Personal Data, a DPDPB compliant organization can be also compliant with ISO 27001 standards as a whole.

When we plan an ISMS under ISO 27001, we need to understand that the context has to take into account that there is a law in India on Information Security called Information Technology Act 2000/8 (ITA 2000/8) and there will be consequences if the ISMS does not meet the requirements of ITA 2000/8. Hence the need to understand the legal environment and ensure that the ISMS is in sync with the ITA 2000/8 is an essential part of the context building.

Available resources of a Company obviously is a constraint which has to be factored into the planning since an SME with a turnover of Rs 10 crores cannot be expected to spend as much money as an MNC with a turnover of Rs 1000 crores. A start up with 20 employees cannot plan an ISMS like an organization with 20000 employees. Hence the ISMS planner/auditor needs to be flexible and this gets reflected in the SOA (Statement of Applicability) or the Implementation Charter (PDPSI specification).

Apart from the legal compulsion which if not complied with, may come with heavy penalties, it is necessary for the management to be convinced about the need for the ISMS or DPCMS (Data Protection Compliance Management System). The best way to achieve this is to present the ISMS requirement as a “Business Objective”. It is for this reason that the ISMS planning has to take into account the needs of the CMO, CFO and the CEO as much as it is an initiative of the CTO to reduce the risk of data breach and meeting the risks of a Cyber attack.

This “Management perspective” of ISMS has to be addressed by linking the ISMS need to the business objective. Unless an organization is a philanthropic organization, management cannot disassociate itself from the profit motive. Hence it will be impractical if we as ISMS planners donot understand the needs of the management to make money for the Company. Hence the views of the CMO/CFO/CEO needs to be adequately respected and their acceptance to any ISMS proposal is a necessity.

Hence it is always better to start the ISMS activity with the development of an Information Asset Inventory and making the management realize the value of the assets they manage and the consequences of not securing these valuable assets. Developing an inventory of Data Assets mean identifying the Data Storage points, Data Collection Points and Data Processing Points. It is better to add the Data Disclosure points also to this “Data Mapping” exercise so that the lifecycle of data in the organization is properly understood for determining the context.

ISO 27001 may not directly refer to any controls that direct them to financially value the information assets while PDPCMS based on PDPCSI does mandate a thought on Data Valuation as a part of brining the visibility of the asset value to the top management. Similarly PDPCMS also takes into account the need for “Monetization” of personal data within the legal permissions by suggesting appropriate policies for “Profiling”, “Monetization” etc.

When a visionary ISO 27001 implementer interprets the “Context” under clause 4, he may include the “Risk Analysis” based on ISO 31000 and may arrive at the same conclusion that PDPCMS arrives at regarding the need for Data Asset Valuation. But as a framework, a majority of the implementers of ISO 27001 may miss these requirements.

It is for these reasons we say that PDPCSI is an improvement over existing frameworks such as ISO 27001 (with ISO 27701 combined).

It may take time for the market to realize this but it will happen over a period of time as PDPCMS becomes more and more common in implementation.

Naavi

ISO 27001:2022 adopts a structure of presenting the requirements through the main document that consists of 10 clauses and the Annexe A which indicates 93 controls.

In comparison, PDPSI adopts 12 Standards and 50 Model Implementation Specifications.

The first three clauses of ISO 27001 cover the scope, Normative references and the Terms and definitions. More critical aspects of implementation are covered by the clauses 4 to 10 namely

4: Context of the Organization

5: Leadership

6:Planning

7: Support

8: Operation

9: Performance Evaluation

10: Improvement.

The structure of the clauses follow the PDCA approach of Plan, Do, Check and Act cycle.

Clause 1 specifies the scope of the document as specifying the requirements for establishing, implementing, maintaining and continually improving an information security management system (ISMS) within the context of an organization. The requirements for assessment and treatment of IS risks are also covered. The scope does make a mention that excluding any part of the requirements specified in clauses 4 to 10 is not acceptable. But this has to be seen along with the “Statement of Applicability” under clause 6.1.3 (d) which allows omission of certain controls based on a justification.

PDPCSI defines its scope as the compliance of laws related to Personal Data Protection and includes the word “Compliance” in the title itself. The target law that a PDPCSI system has to address depends on the “Data Set”.

Hence if an organisation has multiple country data like GDPR data and Indian data, PDPCSI implementation may require application of one set of controls for GDPR data and another set of controls for Indian personal data.

This is achieved through appropriate “Classification” of information with a tag of “Applicable Jurisdiction”. This approach enables PDPCSI to be called a “Unified Framework”.

ISO avoids this difficulty by stating that the requirements are “Generic” and not specific to any sector. But ISO creates multiple standards for different sectors.

The version of PDPCSI applied to Non Personal Data which we may refer some times as “Non Personal Data Compliance Standard of India (NPD-CSI) will similarly focus on jurisdiction of law and NPD-CSI for Indian context will be compliant with ITA 2000/8. This framework titled as IISF 309 was one of the first such frameworks suggested by Naavi way back in 2009 along with three levels of maturity as Level I, II and III. This is now being merged with the concept of DTS and brought under NPD-CSI.

PDPCSI also refers to “Deviation Justification Document” and an “Implementation Charter” which provides flexibility to logically exclude certain Model Implementation Specifications (MIS) and arrive at a set of Adopted Implementation Specifications. (AIS). The PDPCSI supported DTS calculation is done on the basis of MIS but the Certification of Compliance is provided on the AIS and the Implementation Charter approved by the management on the basis of their Risk absorption policy.

DTS represents the maturity of an organisation in implementation and hence adds value to the framework.

PDPCSI therefore provides the flexibility for the management to tailor the framework for different sizes of the organization and different sectors.

ISO 27001 refers to ISO 27000 in its normative reference while PDPSI is a standalone framework.

However we may pick up ISO 27701 (A requirement and not a certifiable standard) for comparison with PDPCSI as it is a privacy framework.

ISO 27701 is presented as an extension of ISO 27001 and hence is dependent completely on ISO 27001. It defines a category of PIMS as an extension of ISMS but does not make distinction of type of organization or the sectoral differences.

In the description of the structure of the document, ISO 27701 states that “This is a sector-specific document related to ISO 27001 and 27002”. It appears to identify PII as a “Sector” by itself. The approach stems from the focus on “Data” more than the “Person behind data” which is necessary for Privacy discussions.

Some of the sectoral requirements are addressed through separate standard definitions making ISO 27701 a maze of multiple standard implementations. Compliance will always be better if it is simple.

If we make Compliance of one standard dependent on another and another as a chain, it will make it difficult for the complying organization to maintain the compliance over a time. PDPCSI tries to achieve simplification by making it a “Unified Model” and enabling flexibility to be achieved at the implementation level.

For Example a consent document under PDPCSI-India may conform to DPDPB 2022 while a similar document under GDPR may conform to GDPR requirements while the standard and the model implementation specification may remain the same for both. By adopting this process PDPCSI avoids duplication of standard to some extent. For the same reason PDPCSI leaves it to the consultants to develop their own templates and not make templates part of the MIS.

The 12 standards of PDPCSI are as follows:

1	Applicable Law
2	Governance Structure
3	Risk Mitigation Charter
4	Compliance By Design
5	Compliance oriented Data Classification
6	Distributed Responsibility
7	Communication with Stakeholders
8	Technical Controls
9	Policy Controls
10	Compliance Culture
11	Certification capability
12	Measurability

The Standards mentioned in PDPCSI are explained in greater detail under the Implementation specifications and some of the title headings may repeat under the MIS with specific responsibility assigned to different divisions.

We have presented the 12 standards of PDPCSI here for comparison with the clauses 1-10 of ISO 27001 only.

The difference in the approach between the the two frameworks is that ISO 27001 tries to follow the PDCA through the 10 clauses. PDPCSI on the other hand expects PDCA in each of the MIS implementations in addition to covering “Audit” as one of the controls. Even the MIS on audit would be subjected to PDCA process.

The four themes of the Annex A controls as against 14 earlier is closer to the PDPCSI approach where 5 responsibility centers were identified for implementing 50 MIS.

ISO 27001 is however more oriented to four processes whereas PDPCSI recognises five responsibility centers.

In a future article we shall present the mapping of ISO 27001 to PDPCSI and identify how may are similar and how many are different.

…Let us continue our discussion in the next article…

Naavi

The Annex A of ISO 27001:2022 contains 93 controls in four categories. The Organizational Controls under A.5 has 37 sub Controls, People Controls under A.6 has 8 sub controls, Physical Controls under A.7 has 14 sub controls and Technology controls under A.8 contain 34 sub controls.

The earlier version of ISO 27001:2013 was unwieldy with 14 different types of controls.

When we look at the categorization adopted by PDPSI, there are 5 categories and it is based on the “Responsibility Centers” . The five responsibility centers used in PDPSI are Management (15 Model Implementation Specifications or MIS), DPO (9 MIS), Legal (2 MIS),HR (4 MIS) and IT (20 MIS).

The 8 people controls under ISO 27001:2022 can be compared directly with the 4 HR (MIS 27-30) controls under PDPSI. The 34 technology controls and 8 physical controls under ISO 27001:2022 can mapped with the 20 MIS of PDPSI (MIS 31-50). The 37 Organizational controls under ISO 27001 can be compared and mapped with the 15 Management level MIS (MIS 1-15), 9 DPO level MIS (16-24) and 2 Legal level MIS (25-26).

ISO 27701 provides a mapping of the guidelines with GDPR. However, PDPSI can be mapped with GDPR as well as DPDPB 2022.

It would be interesting to compare the different controls under ISO 27001:2022 with the corresponding MIS under PDPSI . In this comparison we may find that PDPSI may not only cover the entire ISO 27001:2022 and ISO 27701:2019 but add a few more implementation specifications making it more comprehensive.

We shall discuss these in the next few articles.

Naavi

The scope of the ISO 27001:2022 standard is to provide requirements for establishing, implementing, maintaining and continually improving an information security management system. (ISMS). The ISMS preserves the confidentiality, integrity and availability of information by applying a risk management process. One of the objectives of the standard is to give confidence to interested parties that risks are adequately managed.

If we compare ISO 27001 with a framework such as PDPCSI, the following differences stand out.

1.PDPCSI applies to Personal Data only while ISO 27001 applies to both personal and non personal data

2. PDPCSI is related to mitigation of the risk of non compliance of a given personal data protection law while ISO 27001 is related to preserve the CIA of information

3. PDPCSI is to mitigate/avoid the risk of penalty under the data protection law while ISO 27001 is to provide confidence to the business partners.

There is one school of thought that ISO 27001 is an ISMS system while PDPCSI is a law compliance system and the two are not comparable.

However, law compliance always refers to the “Reasonable Security” to be maintained on personal data as part of the requirement of compliance. It is one of the sections of the law such as Article 32 (2) of GDPR or Section 9(4) of DPDPB 2022

Article 32(2) of GDPR or Section states “In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.”

Article 9(2) of DPDPB 2022 states “Every Data Fiduciary and Data Processor shall protect personal data in its possession or under its control by taking reasonable security safeguards to prevent personal data breach.”

ISO 27001 addresses these specific requirements of the data protection laws since it is a framework for preserving the Confidentiality, integrity and availability of information.

However PDPCSI considers this as one of the important requirements but there are a multitude of other requirements that it tries to address. The main requirements of privacy are establishing the legal basis for processing, protecting the rights of the data subjects, ensuring the compliance through out the life cycle of the data processing etc. Obviously, ISO 27001 does not aim to address these aspects.

In that case, it is unclear what does the change of title of ISO 27001 to include “Privacy Protection” mean.

When the number of controls in Annex A of ISO 27001 reduced from 114 to 93 in the new version, the following 11 new controls have been added.

• A.5.7 Threat intelligence
• A.5.23 Information security for the use of cloud services
• A.5.30 ICT readiness for business continuity
• A.7.4 Physical security monitoring
• A.8.9 Configuration management
• A.8.10 Information deletion
• A.8.11 Data masking
• A.8.12 Data leakage prevention
• A.8.16 Monitoring activities
• A.8.23 Web filtering
• A.8.28 Secure coding

The reduction of the number from 114 to 93 has came about because of merging of several other controls. 35 of the earlier 114 controls remain unchanged, 23 controls were renamed and the remaining controls were merged into 24 new controls.

Hence if “Privacy Protection” has been added to ISO 27001 in the new version, it should be part of the above 11 controls.

On the other hand, ISO 27701 addressed the Privacy related controls applicable for PII as PIMS and included requirements such as

• Awareness and training: These controls address the need to raise awareness of privacy risks among employees and to provide them with training on how to protect personal data.
• Consent: These controls address the need to obtain consent from individuals before collecting, using, or disclosing their personal data.
• Data minimization: These controls address the need to collect only the personal data that is necessary for the purpose for which it is being collected.
• Data security: These controls address the need to protect personal data from unauthorized access, disclosure, modification, or destruction.
• Privacy impact assessment: The organization should conduct a privacy impact assessment (PIA) to identify and assess the privacy risks associated with its processing of personal data
• Privacy policy: The organization should have a privacy policy that sets out the organization’s commitment to privacy and the rights of individuals with respect to their personal data.
• Data protection officer: The organization should appoint a data protection officer (DPO) to oversee the organization’s compliance with privacy laws and regulations.
• Data breach notification: The organization should have a process for notifying individuals and regulators of data breaches.

ISO 27701 was not however a certification standard and it’s implementation had to be done along with ISO 27001 for certification.

Hence if we are looking at ISO 27001 as a standard for PIMS, then we need to look at both ISO 27001:2022 and ISO 27701:2019. However, ISO 27001:2022 does not refer to ISO 27701 in its normative reference list because it is the base standard and ISO 27701 is only a guidance. ISO 27701 on the other hand refers to ISO 27001:2013 and not ISO 27001:2022.

Hence ISO 27001:2022 cannot be considered as a framework for privacy management despite its title. A Creative auditor may however imply several aspects of Privacy into “Confidentiality”.

But ISO 27001+ISO 27701 is comparable to PDPCMS as a standard for implementation and certification of a PIMS.

ISO 27001 is relevant in comparison with PDPCMS to the extent PDPCMS protects CIA of personal data and hence we can continue to look at ISO 27001 from this limited perspective. After completing the discussion on ISO 27001, we shall explore ISO 27701 also.

Naavi