What are the most common reasons organizations fail an ISO 27701 audit — even with a strong ISMS already in place?
The answer lies in the complex intersection between data privacy, governance, and operational discipline.
To help uncover these challenges, we consulted over 100 experienced ISO 27701 Lead Auditors and analyzed real-world certification audit reports across industries.
This guide presents the 100 most frequent non-conformities encountered during the ISO 27701 certification process — along with precise corrective actions mapped to the ISO 27701 framework.
Whether you're developing your ISO 27701 audit checklist, preparing for formal certification, or aligning your privacy controls with the ISO 27701 checklist, this resource will help you avoid costly mistakes, streamline compliance, and build a mature Privacy Information Management System.
📌 Clause: 5.3.1 (for PII Controllers) & 6.3.1 (for PII Processors) – Roles and Responsibilities
What’s Going Wrong: Most organizations can't see the difference between being a PII controller or processor or are simply negligent on formally assigning and documenting such roles within their privacy management system.
Why It Matters During an ISO 27701 Audit:
Lead auditors assess role clarity as fundamental to accountability and control implementation. Confusion over roles results in unclear responsibilities and control misapplication.
How to Fix It:
Detect and note whether your company is a controller, a processor, or both. Clearly define and map responsibilities arising from such roles to the relevant controls. Document such roles in policies, agreements, and internal governance papers.
Get your organization to determine and capture whether it is an act of Controller, Processor, or both. Define the roles and align them to their respective applicable controls. Show such roles in any policy, agreement, and internal governance document.
Real-world result:
Clear role assignment streamlines control mapping, strengthens compliance, and satisfies auditor expectations from the outset.
📌 Clause: 5.2.1 & 6.2.1 – Privacy Policies
What’s Going Wrong: Privacy policies are generic, legalistic, or outdated. They fail to reflect the specific principles and practices required under ISO 27701.
Why It Matters During an ISO 27701 Audit: Auditors assess whether your privacy policy reflects your privacy management objectives, roles, and risk-based approach to PII processing.
How to Fix It: To make the privacy policy compliant with the elements of the ISO 27701 framework, it needs to incorporate data subject rights, controller/processor responsibilities, and a lawful basis for the processing. It should then be reviewed at least once annually and amended as required when there are any regulatory developments.
Real-world result: An ISO-aligned privacy policy enhances transparency, improves audit outcomes, and strengthens stakeholder trust.
📌 Clause: 5.4.1 & 6.4.1 – Determining PII Processing Purposes and Controls
What’s Going Wrong: Many organizations fail to maintain a complete inventory of PII processing activities, data flows, and associated risks.
Why It Matters During an ISO 27701 Audit: Mapping is foundational for identifying applicable controls, risk exposure, and legal obligations. Gaps here compromise the PIMS structure.
How to Fix It: A Move Towards an Inclusive Record of Processing Activities (ROPA). Information Categories, Purposes, Retention Periods for Data Subjects, Transfer Mechanisms, Legal Basis.
Real-world result: Proper mapping enables accurate control application and simplifies compliance with GDPR, CCPA, and ISO 27701 audit requirements.
📌 Clause: 5.4.3 & 6.4.3 – Lawful Basis and Consent
What’s Going Wrong: Organizations process PII without documenting the lawful basis or relying solely on user consent without justification.
Why It Matters During an ISO 27701 Audit: Auditors must see how your organization determines the legal justification for each processing activity, including when consent is used.
How to Fix It: Document lawful bases (e.g., contract, legal obligation, consent, legitimate interest) for all processing activities. Review and update this as regulations evolve.
Real-world result: Legal clarity reduces risk and strengthens defensibility during both audits and regulatory inquiries.
📌 Clause: 5.4.2 – Risk Assessments Related to PII
What’s Going Wrong: New systems, tools, or vendors are implemented without assessing the impact on privacy or documenting risk mitigation.
Why It Matters During an ISO 27701 Audit: Auditors expect formal PIAs to evaluate how PII processing affects data subjects, especially for high-risk activities.
How to Fix It: Create a standardized Privacy Impact Assessment process. Require PIAs for all new PII-related projects. Involve legal, IT, and compliance teams.
Real-world result: Proactive PIAs improve risk management, meet GDPR Article 35 expectations, and provide key ISO 27701 audit evidence.
📌 Clause: 5.2.2 & 6.2.2 – Privacy Objectives
What’s Going Wrong: Organizations set vague privacy objectives (e.g., “protect data”) without KPIs, targets, or documented progress reviews.
Why It Matters During an ISO 27701 Audit: Objectives must be specific, aligned with risks, and subject to ongoing evaluation. Otherwise, auditors may flag them as ineffective.
How to Fix It: Define SMART objectives (e.g., “respond to 100% of data subject requests within 30 days”). Monitor regularly and include results in management reviews.
Real-world result: Measurable objectives enable data-driven improvements and demonstrate active governance to auditors.
📌 Clause: 5.1.1 & 6.1.1 – PIMS Integration with ISMS
What’s Going Wrong: PIMS controls are managed separately from the ISMS, leading to duplicated efforts or inconsistent treatment of security and privacy risks.
Why It Matters During an ISO 27701 Audit: ISO 27701 is designed as an extension to ISO 27001. Lack of integration reflects weak system maturity.
How to Fix It: Align privacy risks with information security risks. Use common frameworks, registers, and review structures. Involve shared roles and oversight bodies.
Real-world result: Integrated governance streamlines compliance, reduces complexity, and improves audit efficiency.
📌 Clause: 5.5.2 – Data Subject Rights Handling
What’s Going Wrong: Organizations don’t have a consistent method for managing data subject requests (access, correction, erasure, etc.), or staff are unclear on the process.
Why It Matters During an ISO 27701 Audit: Effective response to subject rights is a core privacy requirement. Delays or inconsistencies may be flagged as non-compliance.
How to Fix It: Implement a formal procedure for receiving, documenting, verifying, and responding to requests. Train relevant staff and document responses.
Real-world result: Efficient request handling demonstrates procedural control and meets both ISO and regulatory expectations.
📌 Clause: 5.4.6 – PII Retention and Disposal
What’s Going Wrong: PII is retained indefinitely, or retention schedules are not aligned with business, legal, or contractual requirements.
Why It Matters During an ISO 27701 Audit: Excessive data retention increases privacy risk and violates data minimization principles.
How to Fix It: Define and document retention periods for all categories of PII. Automate data disposal where feasible. Include retention enforcement in internal audits.
Real-world result: Proper retention supports data minimization, lowers legal exposure, and strengthens audit readiness.
📌 Clause: 6.7.2 – Managing Processor Compliance (for Controllers)
What’s Going Wrong: Controllers use third-party processors without verifying their privacy controls, contractual commitments, or compliance history.
Why It Matters During an ISO 27701 Audit: Controllers are accountable for ensuring processors meet privacy obligations. Lack of oversight poses legal and reputational risks.
How to Fix It: Conduct due diligence during onboarding. Use data protection agreements (DPAs). Monitor compliance through audits or attestations.
Real-world result: Effective third-party oversight reduces outsourcing risk and meets both ISO 27701 and GDPR controller obligations.
To achieveISO 27701 Lead Auditor Certification needs much more than just this; the first 10 non-conformities enumerate but a few points that leave a question mark of disappointment trailing behind.
It needs a systemic and in-depth approach for privacy governance and operation realities within your organization.
Our entire guide showcases all 100 audit non-conformities of ISO 27701 along with clause references, practical audits' insights from the field, and doable remediation steps that can help keep you ahead of compliance risks.
✅ Built from interviews with 100+ certified ISO 27701 lead auditors
✅ Includes real audit observations across data privacy programs
✅ Mapped to the ISO 27701 framework for controller and processor roles
✅ Provides quick, practical solutions for every audit weakness
✅ Enhances your internal ISO 27701 audit checklist and readiness plan
Don’t risk non-compliance with ISO’s most privacy-focused standard. Download the full guide now and prepare your PIMS for successful certification.
The ISO 27701 standard should not only be perceived as an extension to ISO 27001 but rather as the bedrock of an organization's mature, transparent, and audit-ready privacy program.
Closing up these nonconformities is not just about getting through the next subsequent audit; it is about inculcating a culture of privacy accountability, regulatory compliance, and trust.
There are constant places where organizations must be flexible to changes brought around by privacy threats — reassessing risk continuously, training personnel, testing its systems, and updating policies to come in line with laws that operate globally and the ISO 27701 framework.
Tackling the above issues preemptively prepares the organization not just to be audit-ready but also to build privacy aversion, reduce its regulatory exposure, and enhance stakeholders' trust in the organization in the management of personal data.
Privacy is considered an essential business driver now. This guide will help you implement it into your systems- not just for the sake of compliance but on an additional level: that of resilience.
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