Transition to the ISO/IEC 27701:2025 Revision: Deadline and Key Changes

The deadline for the transition process should be monitored according to the existing certification structure and announcements made by certification bodies. However, industry practices indicate that ISO/IEC 27701:2019 certificates will cease to be valid after October 2028 and that all organizations should have completed their transition audits by this date.

What Has Changed with the ISO/IEC 27701:2025 Revision?

Compared with the previous version, ISO/IEC 27701:2025 is not merely an update containing terminological or limited explanatory changes. The new version repositions the privacy information management system from being an extension dependent on ISO/IEC 27001 and ISO/IEC 27002 into a more independent, integrated, and auditable management system standard.

The key differences introduced by the revision include the standard's structure enabling independent certification, the restructuring of management system requirements according to the harmonized structure, a clearer emphasis on privacy risk management, and the restructuring of controls relating to data controller/data processor roles.

Independent Certification Structure Comes to the Fore

ISO/IEC 27701:2019 was implemented as an extension standard built on ISO/IEC 27001 and ISO/IEC 27002. For this reason, certification of the privacy information management system was generally assessed together with an existing information security management system structure.

With ISO/IEC 27701:2025, the standard has gained an independent structure with its own management system requirements. While this change enables organizations to maintain their privacy information management system in an integrated manner with ISO/IEC 27001, it also introduces the option of standalone, i.e. independent, certification.

This approach supports addressing privacy information management not merely as an additional component of information security controls, but independently within the organization's overall management system structure.

Management System Requirements Are Restructured

The new revision aligns more clearly with the harmonized structure used in ISO management system standards. The areas of context, leadership, planning, support, operation, performance evaluation, and improvement are addressed more holistically in the context of the privacy information management system.

What Should Organizations Expect During the Transition Process?

With the ISO/IEC 27701:2025 revision, transition planning is required to adapt existing ISO/IEC 27701:2019 certificates and the related management system practices to the new version.

For this reason, the transition process should not be regarded merely as renewing the existing certificate under the new version. Organizations are expected to review the scope, roles, risk assessment methods, control structures, and audit evidence of their existing privacy information management systems in accordance with the new standard.

As part of the transition process, organizations are required to align with the ISO/IEC 27701:2025 requirements, complete the necessary documentation and process updates, carry out internal audit and management review activities in accordance with the new standard, and plan transition audits with certification bodies in a timely manner.

How Can Organizations Prepare for the Transition to ISO/IEC 27701:2025?

During the transition to ISO/IEC 27701:2025, it would be beneficial for organizations, as a first step, to compare their existing privacy information management system structure with the requirements of the new standard and identify the changes that need to be implemented.

In this context:

• Analyzing the structural and content-related differences between ISO/IEC 27701:2019 and ISO/IEC 27701:2025; in particular, identifying changing expectations in terms of management system requirements, control structure, data controller/data processor roles, and the risk-based approach,
• Conducting a comprehensive gap analysis of the existing privacy information management system structure; comparing existing policies, procedures, process flows, job descriptions, risk assessment outputs, and audit evidence with the requirements of the new standard,
• Reassessing personal data processing activities, purposes of processing, data categories, transfer processes, retention and disposal practices, and interested-party expectations in line with current legislation and the ISO/IEC 27701:2025 approach,
• Clarifying responsibilities relating to data controller and data processor roles; reviewing privacy information management obligations in contracts, commitments, and operational processes with parties from which services are received or to which services are provided,
• Aligning the privacy risk assessment methodology with the expectations of the new standard; including matters such as privacy risks, data subject rights, data breach scenarios, third-party risks, and international transfers within the scope of risk assessment,
• Updating the existing control structure; clearly defining the relationship between information security controls and personal data protection controls and reassessing controls in terms of applicability, responsibility, evidence, and monitoring methods,
• Planning the necessary revisions to policies, procedures, inventories, privacy notices, explicit consent processes, retention and disposal rules, data breach response processes, and third-party management documentation,
• Informing employees, process owners, and relevant support functions about the new requirements introduced by ISO/IEC 27701:2025; conducting awareness activities on how privacy information management responsibilities will be reflected in day-to-day operations,
• Updating the internal audit program to cover the requirements of ISO/IEC 27701:2025; completing internal audit, nonconformity monitoring, corrective action planning, and management review processes before the transition,
• • Planning the transition timetable together with the certification body; scheduling the certificate validity date, audit type, need for scope changes, audit evidence, and actions to be completed by the final transition date

may constitute the key steps of the transition process.

What Does the Transition to ISO/IEC 27701:2025 Mean for Organizations?

The ISO/IEC 27701:2025 revision supports addressing privacy information management through a more independent, systematic, and auditable management system approach.

The new standard makes the relationship between the scope of the privacy information management system, leadership responsibilities, the risk-based approach, management of data controller and data processor roles, documentation structure, and continual improvement processes more visible.

For this reason, the transition to the new version should not be regarded merely as an update of existing documentation; it should be considered an opportunity to review the organization's privacy information management approach as a whole.

For organizations adopting a privacy information management system approach, the ISO/IEC 27701:2025 revision offers an important opportunity to strengthen organizational maturity in terms of legal compliance, accountability, risk management, and personal data protection.

Closely monitoring the changes introduced by ISO/IEC 27701:2025 and developments relating to the transition process to the new standard is critically important for organizations to manage the transition process in a timely and effective manner.

You can access the announcement on the transition to the ISO/IEC 27701:2025 and ISO/IEC 27706:2025 standards published by the Turkish Accreditation Agency here. (In Turkish)