ISO 27701 Becomes a Standalone Standard: What This Means for Your Business

In our previous article in this series, we introduced the upcoming overhaul of ISO/IEC 27701:2025, the global standard for Privacy Information Management Systems (PIMS). Today, we are taking a deep dive into the single most transformative update: ISO 27701 is no longer an extension of ISO 27001, it is becoming a fully standalone standard.

While this may sound like a technical detail, it has profound implications for how organizations of all sizes can approach and achieve verifiable privacy compliance. Let's break down what's changing and why it matters.

The Old Model: Privacy as an Extension of Security

When ISO 27701 was first released in 2019, it came with a significant prerequisite: it was written as an extension of ISO 27001, the well-known standard for information security management.

In practice, this meant:

• You could not certify to ISO 27701 unless you first implemented and certified a full Information Security Management System (ISMS) under ISO 27001.

• Your privacy program's scope was directly tied to your security scope, as the PIMS was layered on top of the ISMS.

• The core management system requirements (Clauses 4–10) were not part of ISO 27701; they had to be inherited from your ISO 27001 framework.

  
  

This model was logical, as security is a fundamental component of privacy. However, it also created a high barrier to entry. A company that needed privacy certification to demonstrate GDPR compliance, for instance, had to commit to the full scope of an ISO 27001 program just to begin—a costly and resource-intensive undertaking.

The 2025 Shift: A Standalone, Privacy-First Framework

The upcoming ISO 27701:2025 completely rewrites this rule book.

"The new version includes its own full set of management system requirements, allowing it to function as a self-contained, certifiable standard."

It now features:

• Its own Clauses 4–10, covering context, leadership, planning, support, operations, evaluation, and improvement from a privacy-first perspective.

• A structure that follows the Annex high-level format, ensuring it aligns with other major ISO standards like ISO 9001 (Quality) and ISO 27001 (Security).

• Crucially, no mandatory prerequisite for ISO 27001 certification.

  
  

Organizations can now design, implement, and certify a Privacy Information Management System (PIMS) entirely on its own merits.

The Strategic Impact of Going Standalone

This change does more than simplify the process—it fundamentally transforms the strategic value and accessibility of ISO 27701.

• Greater Flexibility: Privacy teams can now build a PIMS that is tailored to their organization's unique compliance needs and risk profile, without being constrained by a broader security framework.

• Lower Barrier to Entry: This opens the door for startups, SMEs, and non-tech companies to achieve credible, third-party privacy certification without the significant overhead of a full ISMS. For many, this is the difference between pursuing certification and forgoing it entirely.

• Elevating Privacy as a Core Discipline: In the old model, privacy could feel secondary to security. With the 2025 update, privacy is treated as a top-level business function with its own dedicated processes, leadership requirements, and risk management practices.

• Seamless Integration Still Possible: For organizations that already have an ISMS or plan to implement one, the new ISO 27701 remains fully compatible with ISO 27001, allowing for a powerful, integrated management system for both security and privacy.

  
  

Who Benefits Most from This Change?

While any organization can leverage the new structure, it is particularly impactful for:

• SaaS companies that are primarily data processors and need to demonstrate strong privacy practices to customers.

• Consultancies and service providers that handle client data and are subject to privacy regulations.

• Organizations focused on complying with GDPR, CCPA, or LGPD but without a formal mandate for ISO 27001.

• "Privacy-first" startups building their reputation on a foundation of trust and data protection.

  
  

What About Security? A Critical Clarification

It is essential to understand this key nuance: decoupling from ISO 27001 does not mean ignoring security.

ISO 27701:2025 includes its own tailored set of security controls in Annex A, which are aligned with the latest ISO 27001:2022 framework. These controls are focused specifically on what is necessary to protect personal data. You are not skipping security; you are applying the security measures most relevant to privacy risks in a more focused and streamlined way.

A Green Light for Your Privacy Program

The move from "extension" to "standalone" redefines the landscape for privacy certification. It dramatically lowers the cost, complexity, and effort required to build a program that demonstrates robust, verifiable privacy governance.

If your organization has been holding off on ISO 27701 because of the ISO 27001 requirement, the 2025 update represents a green light.

Coming Up Next in Our Series:

In our next post, we’ll explore the modernized privacy controls in ISO 27701:2025, including new requirements for AI governance, cloud services, and cross-border data transfers.

Ready to explore how the new ISO 27701 standard can benefit your business?

Straverra helps organizations design, assess, and implement ISO-aligned privacy and security frameworks. Whether you're new to ISO 27701 or preparing to transition from the 2019 version, we provide the expertise to guide you.