If you have been navigating the world of data protection recently, you know that privacy is no longer just a “bonus” feature of information security, it is a central requirement. When ISO 27001 transitioned from the 2013 version to the 2022 update, one of the most significant shifts occurred in how we handle Personally Identifiable Information (PII). This is now addressed under Annex A 5.34, and it represents a much more robust approach than its predecessor.
Table of contents
From 18.1.4 to 5.34: More Than Just a Number Change
In the ISO 27001:2013 version, privacy and PII protection were covered under Control 18.1.4. Similar to other compliance-heavy controls, it was located in the “Compliance” domain. Back then, the focus was often on ensuring the organisation met the minimum legal requirements to avoid a fine. It was frequently viewed as a legal hurdle rather than a core security pillar.
With the 2022 revision, this control has been moved to Annex A 5.34 and categorised under “Organisational Controls.” This move is significant. According to the experts at Hightable.io, placing PII protection within the organizational theme signals that privacy must be embedded into the company’s culture and processes, rather than being treated as an isolated legal checkbox. It acknowledges that in a post-GDPR world, protecting personal data is a daily operational necessity.
The Increased Emphasis on PII
The 2022 update hasn’t just moved the furniture; it has expanded the scope. While the 2013 version focused on “Privacy and protection of personally identifiable information,” the 2022 version, Annex A 5.34, explicitly demands that organizations identify and meet requirements throughout the entire data lifecycle. This includes the collection, processing, storage, and even the eventual deletion of PII.
A key difference highlighted by Hightable.io is the alignment with other modern privacy standards. Annex A 5.34 acts as a bridge to more specific frameworks like ISO 27701 (Privacy Information Management) and ISO 27018 (PII in the Cloud). If your organization handles a lot of personal data, the 2022 version of the standard makes it much easier to integrate these specialized privacy requirements into your general security management system.
What is New in the Implementation Guidance?
The implementation guidance for 5.34 is more comprehensive than it was for 18.1.4. Organizations are now encouraged to develop topic-specific policies for privacy and PII protection. It isn’t enough to have a one-sentence mention in your general security policy; you need a defined approach that covers:
- Data Minimization: Only collecting the PII that is absolutely necessary for your business purpose.
- Consent Management: Ensuring you have clear, documented permission to use an individual’s data.
- Transborder Data Flows: Specifically addressing the risks of moving PII across international borders.
- Individual Rights: Having clear procedures for how you will handle data access requests (DSARs) or requests for deletion.
The introduction of “Attributes” in the 2022 version also changes how you view this control. You can now tag 5.34 with attributes such as “Preventive” and “Privacy,” which helps security teams better explain to auditors and board members exactly how they are mitigating privacy-related risks.
Why the Transition to 5.34 Matters
The world has changed significantly since 2013. We have seen the rise of massive cloud platforms, global privacy regulations like GDPR and CCPA, and a general public that is far more aware of their data rights. ISO 27001:2022 Annex A 5.34 is the standard’s response to this reality. It shifts the focus from “doing enough to be legal” to “doing enough to be secure and trustworthy.”
For organizations making the transition, Hightable.io suggests that your first step should be a thorough data mapping exercise. You cannot protect what you don’t know you have. Once you understand your PII footprint, you can align your controls with the new expectations of 5.34. This doesn’t just help with your ISO audit; it strengthens your reputation with customers who trust you with their most sensitive information.
Final Thoughts for Your Transition
While the changes from 18.1.4 to 5.34 might seem daunting at first, they actually provide a much clearer roadmap for modern data protection. By treating PII protection as an organizational priority, you ensure that security and privacy work hand-in-hand. As you update your Statement of Applicability, take the time to really look at how your business handles personal data, it’s an investment that pays off in both compliance and customer confidence.