With rising data breaches and stricter privacy laws, organizations can no longer ignore privacy.
The surge in Personally Identifiable Information (PII) processing and evolving regulations like Indonesia’s UU PDP (UU No. 27/2022), European’s GDPR, and US-California’s CCPA demand a proactive approach.
ISO/IEC 27701:2019 extends security frameworks into robust Privacy Information Management Systems (PIMS), helping organizations ensure compliance, build trust, and mitigate risks in a data-driven world.
What is ISO/IEC 27701?
ISO/IEC 27701 is a critical extension of ISO/IEC 27001, enhancing its security-focused framework with privacy-specific controls. While ISO 27001 ensures data confidentiality, integrity, and availability (CIA principles), ISO 27701 builds upon this by incorporating privacy governance, making it ideal for organizations processing Personally Identifiable Information (PII). In the Indonesian context, ISO 27701 aligns closely with the Personal Data Protection (PDP) Law (UU No. 27/2022), providing a structured approach to compliance. Specifically, it helps businesses define roles as PII controllers or processors, establish lawful bases for data processing, implement data minimization and retention policies, and strengthen governance mechanisms (all key requirements under PDP Law).
The key clauses of ISO 27701 include:
- Clause 5: PIMS-specific requirements related to ISO 27001 – Expands upon the requirements of an Information Security Management System (ISMS) to incorporate privacy controls.
- Clause 6: PIMS-specific guidance related to ISO 27002 – Provides detailed privacy-related security controls.
- Clause 7: Additional guidance for Personally Identifiable Information (PII) controllers – Defines responsibilities for organizations acting as data controllers.
- Clause 8: Additional guidance for PII processors – Specifies privacy management requirements for organizations processing data on behalf of others.
Why ISO/IEC 27701 is Important?
The consequences of neglecting privacy are severe. Beyond hefty fines (up to 4% of global turnover under GDPR), organizations face reputational damage, loss of customer trust, and operational disruptions. ISO/IEC 27701 offers a roadmap to avoid these pitfalls by:
- Legal Compliance: Stringent global data protection laws, such as GDPR and CCPA, impose strict requirements on how personal data should be handled. Non-compliance can lead to hefty fines and legal actions.
- Consumer Trust: Customers are increasingly aware of their privacy rights and expect organizations to safeguard their personal data.
- Risk Mitigation: A strong privacy framework helps organizations prevent data breaches, cyberattacks, and unauthorized access to sensitive information.
- Competitive Advantage: Companies that prioritize data privacy gain a competitive edge, as compliance with international standards enhances credibility and business reputation.
Strategy to Implement ISO 27701
To successfully implement ISO 27701, we recommend organizations to follow these key steps:
Additional Control Objectives for Data Controller and Data Processor
- Ensure processing is lawful, with a valid legal basis and legitimate purposes.
- Provide data subjects with necessary information and fulfill related obligations.
- Limit data collection, processing, and retention to what is necessary.
- Document and ensure compliance when sharing, transferring, or disclosing personal data.
CONCLUSION
With Indonesia’s Personal Data Protection Law (UU No. 27/2022) now in full effect post-September 17, 2024, organizations must ensure compliance to avoid regulatory penalties, reputational risks, and operational disruptions.
ISO/IEC 27701 provides a structured framework to align with the PDP Law by helping organizations:
- Identify & classify personal data (aligned with PDP Law requirements for PII controllers and processors).
- Establish lawful processing mechanisms (ensuring legal bases for data collection, processing, and retention).
- Enhance governance & accountability (defining roles like DPO and implementing privacy-centric risk assessments).
- Ensure data subject rights management (facilitating rights such as access, rectification, and erasure as mandated by PDP Law).
- Strengthen third-party data processing controls (ensuring vendor contracts comply with PDP Law’s processor obligations).
By adopting ISO 27701 alongside ISO 27001, organizations in Indonesia can proactively address compliance risks, avoid regulatory penalties, and build consumer trust in an increasingly data-driven landscape.
By Erikman D Pardamean & Satrio B Pandowo, Technology Risk Consulting Practice