A Practical Guide to Implementing ISO 27701:2025 From Scratch

Practical Guide to Implementing ISO 27701:2025 From Scratch

You don’t need to be a Fortune 500 enterprise to take privacy seriously. And with the release of ISO/IEC 27701:2025, you no longer need a massive, pre-existing security program to achieve certification.

In our earlier posts, we explored how the new version of ISO’s Privacy Information Management System (PIMS) standard has evolved into a fully standalone framework. This is a game-changer, especially for privacy-focused startups, lean tech companies, and mid-sized organizations looking to certify their privacy practices without overbuilding their security infrastructure.

This article provides a practical roadmap for implementing ISO 27701:2025 from scratch, even if you have no prior experience with ISO standards.

The Advantage of a Standalone Standard

Previously, the 2019 version of the standard required you to implement ISO 27001 first, forcing you to build a full Information Security Management System (ISMS) just to get started on privacy.

With ISO 27701:2025, that barrier is gone. You can now:

• Implement and certify a PIMS independently of ISO 27001.

• Leverage a clear, built-in governance structure (Clauses 4–10) focused entirely on privacy.

• Use the new Annex B for practical, step-by-step guidance on implementing each control.

• Focus your resources on the privacy-specific controls that matter most to your business and its risks.

  
  

This shift significantly lowers the cost and complexity, making credible privacy certification accessible to a much wider range of organizations.

Your Step-by-Step Implementation Roadmap

Here is a breakdown of the implementation process into actionable steps, suitable for any organization managing personal data.

Step 1: Define Your PIMS Scope

Begin by clearly defining the boundaries of your Privacy Information Management System. Answer these key questions:

• Which of our systems, services, or departments process personal data?

• In this context, are we acting as a PII Controller, a PII Processor, or both?

  
  

Your initial scope should be focused and manageable; you can always expand it later. A clear definition of what is "in" and "out" of scope is critical for aligning your policies, controls, and eventual audit.

Pro Tip: Many organizations start with a single core product or business unit that handles customer data and then expand the PIMS scope over time as the program matures.

Step 2: Understand the Governance Requirements

ISO 27701:2025 now includes its own dedicated management system clauses that provide the foundation for governance and accountability:

• Clause 4: Context of the Organization

• Clause 5: Leadership

• Clause 6: Planning

• Clause 7: Support

• Clause 8: Operation

• Clause 9: Performance Evaluation

• Clause 10: Improvement

  
  

You will also need to identify key internal roles and assign responsibilities, such as a Privacy Officer or Data Protection Officer (DPO), relevant department leads (e.g., Engineering, Legal, Product), and an executive sponsor to champion the initiative.

Step 3: Conduct a Privacy Risk Assessment

A risk-driven approach is fundamental to ISO 27701. Start by identifying and analyzing the potential risks to the rights and freedoms of data subjects. Your assessment should document:

• The types of personal data you collect and process.

• How data flows through your systems (collection, storage, sharing, deletion).

• Potential threats and vulnerabilities associated with that data.

• Factors like the use of AI, third-party cloud vendors, and cross-border data transfers.

  
  

Once risks are identified, you will analyze their potential impact and likelihood to prioritize them for treatment.

Step 4: Implement Core Privacy Controls

The core technical and organizational requirements of ISO 27701 are detailed in Annex A. These controls are organized based on your role:

• A.1 – PII Controller Controls

• A.2 – PII Processor Controls

• A.3 – Foundational Security Controls relevant to protecting PII.

  
  

You only need to implement the controls that are relevant to your scope and role(s). Key examples include consent management, privacy by design, data subject request handling, and third-party processor management. The new Annex B provides valuable "how-to" guidance for putting each of these controls into practice.

Step 5: Operationalize Your Privacy Processes

With your controls defined, you must build the repeatable processes to support them:

• Data Subject Access Request (DSAR) Process: A documented workflow for handling requests for access, correction, and deletion.

• Privacy Impact Assessment (PIA/DPIA) Framework: A structured process for evaluating the privacy risks of new projects or systems.

• Vendor Management Process: A system for assessing the privacy and security risks of third-party vendors and cloud providers.

• Incident Response Plan: A clear plan for detecting, responding to, and reporting a privacy breach.

  
  

Step 6: Train Your Team

Privacy is a collective responsibility. Ensure all employees understand:

• What constitutes personal data in your context.

• Their specific role in protecting that data.

• How to handle data responsibly in their day-to-day work.

• The procedure for reporting a potential privacy incident.

  
  

Training should be tailored to different roles. For example, developers need in-depth training on privacy by design, while marketing teams need to understand consent and lawful bases for processing.

Step 7: Monitor, Audit, and Improve

Once your PIMS is operational, Clauses 9 and 10 require you to maintain and improve it through a cycle of evaluation:

• Conduct internal audits to assess whether your controls are implemented and effective.

• Hold formal management reviews to evaluate performance against privacy objectives and address outstanding risks.

• Track metrics, non-conformities, and incidents to drive continual improvement.

  
  

How Long Will Implementation Take?

The timeline depends on your organization's size, complexity, and existing maturity. However, here are some general estimates for a focused implementation:

• Small Company (<50 employees): 3–6 months

• Mid-Sized Organization: 4–8 months

• Larger, Multi-Department Organization: 6–12 months

  
  

The key is to start small, iterate quickly, and focus on the controls that provide the most significant risk reduction.

A Focused Path to Privacy Certification

For the first time, organizations can build a practical and certifiable privacy program without the significant overhead of a full-blown ISMS. ISO 27701:2025 offers a focused, efficient path forward. If you are starting from scratch, the key is to keep your program lean, relevant, and aligned with your actual risk exposure.

Coming Up Next in Our Series:

In the final post, we’ll walk through how to transition an existing ISO 27701:2019 program to the new 2025 version, highlighting what stays the same, what needs updating, and how to plan for a smooth migration.

Ready to build a certifiable, ISO-aligned privacy program?

Straverra works with startups, SaaS platforms, and privacy-forward organizations to design PIMS frameworks that are tailored to your size, scope, and industry.