What is ISO 27001 Annex A 5.34 Privacy And Protection Of PII?
ISO 27001 Annex A 5.34 is a control for protecting personal data. It mandates compliance with laws like GDPR. You must define a documented process for managing PII. Integrate these requirements into SharePoint or Jira. This keeps privacy data linked to your daily business operations.
Auditor’s Eye: The Shortcut Trap
Automated SaaS platforms often provide generic privacy templates. This creates surface-level compliance. Auditors look for management ownership of privacy risks. We prefer seeing Privacy Impact Assessments within your internal repositories. SharePoint version histories prove human oversight. Software dashboards cannot replace an active privacy culture. If an auditor sees only “green ticks,” they will dig deeper. Use your existing tools to show real intent.
| 2013 Control Reference | 2022 Control Reference | Key Changes and Requirements |
|---|---|---|
| A.18.1.4 Privacy and protection of PII | 5.34 Privacy and protection of PII | The 2022 version emphasises regulatory alignment. It requires more active data mapping and impact assessments. |
How to Implement ISO 27001 Annex A 5.34 (Step-by-Step)
Start by identifying all personal data held by the organisation. Use your existing SharePoint lists to inventory PII. This approach ensures privacy is a cultural habit. It avoids the need for expensive software. Answer-first: Successful implementation requires a clear PII inventory and impact assessments linked to your internal project management tools.
- Map Your Data: Create a data flow diagram in Confluence. Identify where PII enters and leaves the business.
- Conduct PIAs: Perform a Privacy Impact Assessment for every PII-related project. Track these in Jira.
- Draft Policies: Write clear privacy notices for staff and customers. Manage these in a SharePoint library.
- Implement Deletion: Set automated reminders in Jira for data disposal. Follow your documented retention schedule.
- Audit Regularly: Check your privacy controls every six months. Record findings in internal meeting minutes.
ISO 27001 Annex A 5.34 Audit Evidence Checklist
Auditors require records that prove human oversight. We look for internal document versions and meeting notes. Focus on these manual records.
- A comprehensive PII inventory hosted in your internal SharePoint.
- Privacy Impact Assessment records for all major system changes.
- Documented privacy notices with clear internal ownership.
- Minutes from management meetings discussing privacy compliance.
- Version-controlled data retention and disposal logs.
Relational Mapping
- Clause 4.2: Understanding the needs of interested parties.
- Annex A 5.31: Legal and regulatory requirements.
- Annex A 8.10: Information deletion.
- Annex A 8.11: Data masking.
Auditor Interview
Auditor: How do you manage privacy when launching new products?
Manager: We trigger a Privacy Impact Assessment in Jira. Our Data Protection Officer must approve it before we proceed.
Auditor: Where is the evidence of this assessment?
Manager: It is attached to the Jira project ticket. You can see the full version history in SharePoint.
Common Non-Conformities
| Failure Mode | Description | Remediation |
|---|---|---|
| Automated Complacency | Relying on a SaaS tool for privacy without internal oversight. | Move Privacy Impact Assessments to internal tools like Jira. |
| Static Data Maps | PII inventories that are not updated after system changes. | Link PII reviews to your internal change management process. |
| Lack of Training | Staff handling PII without understanding their legal obligations. | Record bespoke privacy training sessions in your internal logs. |
Frequently Asked Questions
What is Personally Identifiable Information (PII)?
PII is any data that can identify an individual. This includes names, email addresses, and phone numbers. It also covers IP addresses and biometric data. You must track all these items in a SharePoint inventory. This allows you to apply the correct security controls.
How does ISO 27001 help with GDPR compliance?
ISO 27001 provides the framework for technical and organisational measures. Annex A 5.34 specifically targets privacy protection. By following this control, you build a system that meets GDPR requirements. It ensures that data protection is documented and verifiable by auditors.
Why should we use SharePoint for privacy records?
SharePoint provides native versioning and access controls. It keeps your privacy records within the organizational boundary. This prevents data from being stored in “Black Box” SaaS tools. Auditors prefer seeing your internal processes. It demonstrates that you own the risk and the data.