ISO/IEC 27701 Foundation study materials
ISO/IEC 27701 Foundation study resources

ISO/IEC 27701 Foundation: Guidance for PII Processors

ISO/IEC 27701 Foundation · Work through your exam, one topic at a time.

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Guidance for PII Processors

This domain tests Clause 8 and Annex B. The core idea is narrow authority: a processor does only what the controller's documented instructions allow, and the controls exist to keep it inside that boundary.

Role boundary

A PII processor processes PII on behalf of a controller. The moment it determines purposes or means for itself, it becomes a controller for that processing - even if the contract and the labels say otherwise. A processor engaging another party creates a sub-processor relationship that needs authorisation and flow-down of the same obligations.

Annex B control families

  • Conditions for collection and processing - a customer agreement covering scope and instructions; no processing for the processor's own purposes; no use for marketing; handling instructions that may infringe privacy obligations; assisting the controller with its own obligations; records of processing; returning or deleting PII at the end of the relationship.
  • Obligations to PII principals - support the controller in providing information and answering access, correction and erasure requests; tell the controller promptly when a request arrives directly.
  • Privacy by design and by default - temporary files, retention limits, de-identification, processing only what instructions permit.
  • Sharing, transfer and disclosure - a basis for transfers between jurisdictions, a list of destination countries, records of disclosures, notification to the controller of disclosure requests, handling of lawful requests from authorities, and controls over sub-contractors.

Worked example

A cloud backup provider receives a legally binding demand for a customer's data. Annex B expectations: verify the request is lawful, disclose the minimum necessary, notify the controller unless legally prohibited from doing so, log the disclosure, and confirm the sub-processor chain was authorised. The processor does not decide the outcome alone.

Traps that cost marks

  • Using customer PII to improve the processor's own products - that is a controller purpose.
  • Assuming processors owe no duties towards PII principals.
  • No records of disclosures or of authority requests.
  • Onward sub-processing without authorisation and contractual flow-down.