Who Needs ISO 27701?

Key Takeaways

Point	Summary
Primary candidates	Organizations processing significant PII, especially with EU exposure
Prerequisite	Must have or be pursuing ISO 27001
Regulatory drivers	GDPR, CCPA, LGPD, and other privacy regulations
Market drivers	Enterprise customers, healthcare, financial services, government
Role consideration	Both PII controllers and processors benefit
Size threshold	No minimum size, but ROI improves with scale of PII processing

Quick Answer: ISO 27701 is most valuable for organizations that process significant personal data, serve European enterprise customers, operate in regulated industries, or want to differentiate on privacy. You need ISO 27001 first, so evaluate whether both certifications align with your business needs.

Organizations That Benefit Most

By Business Model

Business Type	Why ISO 27701 Helps
SaaS platforms	Demonstrates privacy management to enterprise customers
Data processors	Shows responsible handling to controller clients
Healthcare technology	Aligns with sector-specific privacy requirements
HR/payroll services	Builds trust for sensitive employee data handling
Financial services	Complements regulatory compliance requirements
Marketing technology	Addresses consent and data usage concerns
Identity verification	Critical for services handling sensitive PII

By Geographic Market

Market	ISO 27701 Relevance
European Union	High value, demonstrates GDPR alignment
United Kingdom	Strong recognition for UK GDPR compliance
Brazil	Supports LGPD compliance demonstration
Asia-Pacific	Growing recognition, particularly in Singapore, Japan
United States	Emerging value as state privacy laws proliferate
Global operations	Unified framework across multiple jurisdictions

Trigger Events for ISO 27701

Organizations typically pursue ISO 27701 when specific business events create the need:

Customer Requirements

Enterprise sales scenarios:

• European enterprises requesting privacy certification alongside security
• Healthcare customers requiring demonstrated privacy management
• Financial services clients with strict vendor privacy requirements
• Government contracts specifying privacy management standards

Processor relationships:

• Controller clients asking for evidence of systematic privacy practices
• RFPs including privacy certification as evaluation criteria
• Customer audits identifying privacy management gaps

Regulatory Pressures

Trigger	Response
GDPR enforcement action in your sector	Proactive demonstration of compliance commitment
New privacy regulation in key market	Framework for meeting multiple requirements
Supervisory authority guidance	Structured approach to meeting expectations
Industry-specific rules	Baseline for sector compliance requirements

Business Strategy

• Market differentiation: Privacy-first positioning
• M&A preparation: Due diligence readiness
• IPO readiness: Demonstrating operational maturity
• Trust center enhancement: Third-party validated privacy claims

Assessing Your Need

Questions to Evaluate Fit

Volume and sensitivity of PII:

• Do you process personal data for more than 10,000 individuals?
• Does your processing include special categories (health, financial, children)?
• Are you a processor handling data for multiple controllers?

Market and customer factors:

• Do European enterprises represent significant current or target revenue?
• Have customers requested privacy certification in the past 12 months?
• Do competitors hold ISO 27701 or equivalent privacy certifications?

Regulatory exposure:

• Does GDPR apply to your processing activities?
• Are you subject to multiple privacy regulations across jurisdictions?
• Has your sector seen recent regulatory enforcement actions?

Strategic priorities:

• Is privacy a differentiator in your market positioning?
• Are you preparing for significant fundraising or exit?
• Do you want to reduce time spent on customer privacy audits?

Readiness Assessment

Factor	Ready	Not Ready
ISO 27001 status	Certified or in process	No plans for ISO 27001
PII inventory	Documented processing activities	Unclear what PII you process
Legal basis	Defined for each processing activity	Ad hoc or undocumented
Privacy roles	DPO or privacy lead assigned	No dedicated privacy function
Data subject processes	Can handle rights requests	No formal process
Vendor agreements	DPAs with processors	Incomplete coverage

Industry-Specific Considerations

Healthcare and Life Sciences

Healthcare organizations process some of the most sensitive personal data. ISO 27701 complements sector-specific requirements:

Consideration	ISO 27701 Benefit
Patient data sensitivity	Systematic approach to health data protection
Research data	Framework for consent and purpose limitation
Cross-border transfers	Supports international data sharing compliance
Vendor management	Structure for healthcare data processor oversight

Financial Services

Financial institutions face overlapping privacy and security requirements:

Consideration	ISO 27701 Benefit
Customer financial data	Privacy controls for sensitive financial PII
Regulatory expectations	Demonstrates systematic compliance approach
Third-party risk	Framework for processor and vendor privacy
Cross-border operations	Unified global privacy standard

Technology and SaaS

Technology companies often act as both controllers and processors:

Consideration	ISO 27701 Benefit
Platform data	Controller controls for user data
Customer data	Processor controls for B2B relationships
Product development	Privacy by design integration
Enterprise sales	Certification for procurement requirements

When ISO 27701 May Not Be Necessary

Alternative Approaches

Situation	Alternative
US-focused, tech-savvy customers	SOC 2 + Privacy TSC may suffice
Minimal PII processing	Documented privacy practices without certification
Very early stage	Focus on fundamentals, certify later
Single large customer	Meet their specific requirements directly

Signals to Wait

• No customer has requested privacy certification in the past year
• You process minimal personal data (primarily B2B, no consumer data)
• ISO 27001 isn't yet on your roadmap
• Major product or infrastructure changes are planned
• Resources are constrained for compliance investments

Controller vs. Processor Considerations

If You're Primarily a Controller

You determine purposes and means of processing. ISO 27701 helps you:

Area	Benefit
Legitimacy	Document legal bases for all processing
Transparency	Structure privacy notices and communications
Rights management	Systematic data subject request handling
Third-party oversight	Framework for processor management
Accountability	Evidence of privacy governance

If You're Primarily a Processor

You process on behalf of controllers. ISO 27701 helps you:

Area	Benefit
Controller assurance	Demonstrate systematic privacy practices
Instruction compliance	Document processing under controller direction
Sub-processor management	Framework for downstream relationships
Incident response	Clear notification and cooperation procedures
Contract compliance	Support for DPA requirements

If You're Both

Most SaaS companies act as both. ISO 27701 provides:

Scenario	Controls Applied
Employee data	Controller controls (Annex A)
Direct customer accounts	Controller controls (Annex A)
Customer's customer data	Processor controls (Annex B)
Analytics on platform data	Depends on purposes and legal basis

Making the Business Case

Quantifiable Benefits

Benefit	Potential Impact
Faster sales cycles	Reduced time in security/privacy reviews
Deal access	Qualification for privacy-conscious enterprises
Audit efficiency	Single framework for multiple customer audits
Incident preparedness	Reduced breach response costs
Regulatory confidence	Lower risk of enforcement actions

Investment Considerations

Factor	Consideration
ISO 27001 status	If already certified, extension is efficient
Processing scale	ROI improves with volume of PII
Customer concentration	High value if key customers require it
Competitive landscape	Higher value if competitors are certified

How Bastion Helps

Determining whether ISO 27701 fits your organization requires understanding both your current state and your market requirements. We help organizations evaluate the fit and, when appropriate, achieve certification efficiently.

Service	Description
Needs assessment	Evaluate whether ISO 27701 aligns with your business
Gap analysis	Identify what's needed to achieve certification
Combined roadmap	Plan ISO 27001 + 27701 for efficiency
Implementation support	Guide privacy control implementation
Certification preparation	Prepare for successful audit

---

Not sure if ISO 27701 is right for your organization? Talk to our team

---

Sources

• ISO/IEC 27701:2019 - Privacy information management standard
• GDPR Article 24 - Responsibility of the controller
• GDPR Article 28 - Processor requirements
• IAPP Global Privacy Law Map - Overview of privacy regulations worldwide