Key Takeaways
| Point |
Summary |
| Framework basis |
ISO 27701 extends ISO 27001; SOC 2 Privacy is a TSC option |
| Output |
ISO 27701: Certificate; SOC 2: Attestation report |
| Geographic strength |
ISO 27701: EU/APAC; SOC 2: North America |
| GDPR alignment |
ISO 27701 has explicit mapping; SOC 2 Privacy is general |
| Prerequisite |
ISO 27701 requires ISO 27001; SOC 2 Privacy requires SOC 2 Security |
| Best approach |
Often both, based on customer requirements |
Quick Answer: Choose ISO 27701 for European markets and GDPR demonstration. Choose SOC 2 Privacy for North American tech buyers. Many organizations benefit from both since the significant overlap makes the combined path efficient. The right choice depends primarily on where your customers are and what they request.
Framework Comparison
Structural Differences
| Aspect |
ISO 27701 |
SOC 2 Privacy |
| Developer |
ISO/IEC |
AICPA |
| Type |
Management system certification |
Attestation report |
| Foundation |
Extends ISO 27001 |
Optional SOC 2 TSC |
| Output |
Certificate (3-year) |
Annual report |
| Focus |
Privacy information management system |
Privacy controls attestation |
| Control structure |
Annex A (controller), Annex B (processor) |
Privacy Trust Services Criteria |
Scope and Coverage
| Area |
ISO 27701 |
SOC 2 Privacy |
| Security |
Via ISO 27001 foundation |
Via SOC 2 Security TSC |
| Privacy management |
Comprehensive PIMS |
Control-focused |
| Data subject rights |
Explicit controls |
Addressed in criteria |
| Consent |
Controller controls |
Privacy criteria |
| GDPR mapping |
Annex D provides explicit mapping |
No formal mapping |
| Processor requirements |
Annex B with 18 controls |
Covered in criteria |
Geographic and Market Considerations
When ISO 27701 Has More Weight
| Market/Context |
Why ISO 27701 |
| European Union |
GDPR alignment, European preference for ISO |
| UK |
UK GDPR alignment, ISO recognition |
| Germany, France |
Strong ISO standards tradition |
| Asia-Pacific |
ISO certification widely recognized |
| Government/public sector |
Often require ISO certifications |
| Regulated industries (EU) |
ISO framework preference |
When SOC 2 Privacy Has More Weight
| Market/Context |
Why SOC 2 Privacy |
| United States |
Standard for SaaS and tech |
| North American tech |
Familiar to tech buyers |
| US healthcare |
Combined with HIPAA considerations |
| Venture-backed |
Investor familiarity |
| Fast-moving tech sales |
Quick reference in questionnaires |
Control Framework Comparison
Privacy Principles Coverage
| Privacy Principle |
ISO 27701 |
SOC 2 Privacy |
| Notice |
A.7.3.2 |
P1 |
| Choice and consent |
A.7.2.4, A.7.3.3, A.7.3.4 |
P2 |
| Collection |
A.7.4.1, A.7.4.4 |
P3 |
| Use and retention |
A.7.2.3, A.7.4.7 |
P4 |
| Access |
A.7.3.6, A.7.3.10 |
P5 |
| Disclosure |
A.7.5.1-4 |
P6 |
| Security |
Via ISO 27001 |
Via Security TSC |
| Quality |
A.7.4.3 |
P7 |
| Monitoring and enforcement |
Via PIMS |
P8 |
Control Depth Comparison
| Area |
ISO 27701 |
SOC 2 Privacy |
| Controller specifics |
31 dedicated controls |
General criteria |
| Processor specifics |
18 dedicated controls |
General criteria |
| Rights fulfillment |
Multiple specific controls |
Covered in criteria |
| International transfers |
Explicit controls |
Less specific |
| Sub-processor management |
5 specific controls |
General requirements |
Practical Differences
Implementation Experience
| Aspect |
ISO 27701 |
SOC 2 Privacy |
| Documentation |
More extensive PIMS documentation |
Control evidence focus |
| Management system |
Full management system required |
Control demonstration |
| Continuous improvement |
Explicit requirement |
Expected but less formal |
| Audit approach |
System and control audit |
Control effectiveness testing |
Certification/Attestation Process
| Aspect |
ISO 27701 |
SOC 2 Privacy |
| Frequency |
3-year cert, annual surveillance |
Annual report |
| Observation period |
Not required |
3+ months for Type 2 |
| Auditor type |
Accredited certification body |
Licensed CPA firm |
| Combined audit |
With ISO 27001 |
With SOC 2 Security |
Cost Comparison
| Component |
ISO 27701 |
SOC 2 Privacy |
| Extension to foundation |
€3,000-€15,000 |
€2,000-€8,000 |
| Annual ongoing |
Surveillance: €1,500-€5,000 |
Full report: €10,000-€25,000 |
| 3-year total |
Lower ongoing costs |
Higher annual costs |
Regulatory Alignment
GDPR Alignment
| Aspect |
ISO 27701 |
SOC 2 Privacy |
| Formal mapping |
Annex D provides explicit mapping |
No formal mapping |
| Controller/processor |
Explicit role-based controls |
General coverage |
| Article 30 records |
Direct control requirement |
Addressed but not specific |
| Rights (Art. 15-22) |
Specific controls per right |
General criteria coverage |
| Regulatory recognition |
Designed for GDPR support |
General privacy standard |
Other Regulations
| Regulation |
ISO 27701 |
SOC 2 Privacy |
| CCPA |
Good alignment |
Good alignment |
| LGPD (Brazil) |
Strong alignment (GDPR-based) |
General alignment |
| PDPA (Singapore) |
Good alignment |
General alignment |
| APPI (Japan) |
Good alignment |
General alignment |
Making the Choice
Choose ISO 27701 If
| Scenario |
Rationale |
| European enterprise customers |
Primary market recognition |
| GDPR demonstration critical |
Explicit GDPR mapping |
| Already have ISO 27001 |
Natural extension |
| Public sector targets |
Often ISO preference |
| Healthcare in EU |
Sector preference for ISO |
Choose SOC 2 Privacy If
| Scenario |
Rationale |
| North American tech market |
Primary market standard |
| Already have SOC 2 |
Simple addition |
| Fast-moving tech sales |
Familiar format for buyers |
| US healthcare (with HIPAA) |
Common combination |
| Venture-backed growth |
Investor familiarity |
Consider Both If
| Scenario |
Rationale |
| Global customer base |
Cover both market preferences |
| Mixed market segments |
Different customers want different things |
| Maximizing coverage |
Reduce privacy due diligence friction |
| Long-term enterprise play |
Comprehensive trust positioning |
Pursuing Both Frameworks
Efficiency Opportunities
| Area |
Shared Effort |
| PII inventory |
Same inventory serves both |
| Privacy notices |
Single set of notices |
| Rights processes |
Same DSAR workflow |
| Consent management |
Single mechanism |
| Processor management |
Same DPA program |
| Training |
Combined privacy awareness |
Sequencing Options
Option 1: ISO path first
- ISO 27001 certification
- ISO 27701 extension
- SOC 2 + Privacy (leveraging existing controls)
Option 2: SOC 2 path first
- SOC 2 with Security + Privacy
- ISO 27001 (leveraging existing controls)
- ISO 27701 extension
Option 3: Parallel
- Implement unified privacy program
- Pursue both certifications together
- Maximize audit efficiency
Combined Program Benefits
| Benefit |
Impact |
| Single privacy program |
One set of processes |
| Unified documentation |
Serves both frameworks |
| Coordinated audits |
Reduce total audit time |
| Comprehensive coverage |
Satisfy all customer requests |
| Competitive advantage |
Demonstrate full commitment |
Frequently Asked Questions
Do customers accept one instead of the other?
Some customers are flexible; others have specific requirements. In practice, European enterprises often specifically want ISO 27701, while US tech companies typically request SOC 2. Having both eliminates negotiation.
Which is more rigorous?
They're rigorous in different ways. ISO 27701 requires a full privacy management system with continuous improvement. SOC 2 Privacy provides detailed attestation of control effectiveness. Neither is inherently more rigorous.
Can I use one's evidence for the other?
Yes, substantially. PII inventories, policies, procedures, and most control evidence can serve both frameworks with appropriate documentation.
Which is faster to achieve?
SOC 2 Privacy is typically faster to add to existing SOC 2 (2-4 weeks additional implementation). ISO 27701 extension to ISO 27001 takes 4-8 weeks typically.
How Bastion Helps
We help organizations navigate the choice between ISO 27701 and SOC 2 Privacy, or efficiently achieve both.
| Service |
Description |
| Framework assessment |
Evaluate which framework(s) your market needs |
| Unified implementation |
Build privacy program serving both |
| Efficient certification |
Minimize duplicate effort |
| Ongoing management |
Maintain both frameworks efficiently |
Not sure which privacy framework is right for you? Talk to our team
Sources
