ISO 27001:2022 Annex A Control 5.34

Explaining Annex A Control 5.34 Privacy and protection of PII

ISO 27001 Control 5.34 focuses on the privacy and protection of Personally Identifiable Information (PII) to ensure organizations comply with legal, statutory, regulatory, and contractual obligations. Protecting PII is not only a legal requirement in many jurisdictions but also a critical aspect of information security that helps prevent data breaches, unauthorized disclosures, and privacy violations.

Annex A Control 5.34 Privacy And Protection Of Pii

Control Type

  • Preventive

Information Security Properties

  • Confidentiality
  • Integrity
  • Availability

Cybersecurity Concepts

  • Identify
  • Protect

Operational Capabilities

  • Information Protection
  • Legal and Compliance

Security Domains

  • Protection

Objective of Control 5.34

The objective of this control is to ensure that organizations identify, implement, and maintain security measures that protect PII from unauthorized access, disclosure, modification, and destruction.

By complying with this control, your organization can:

  • Meet legal and contractual requirements related to PII security.
  • Protect individuals’ privacy rights and prevent regulatory penalties.
  • Establish accountability for handling PII within your organization.
  • Ensure business continuity by minimizing privacy-related risks.
  • Enhance stakeholder trust by demonstrating a commitment to privacy protection.

Purpose of Control 5.34

The purpose of ISO 27001 Control 5.34 is to guide organizations in preserving privacy and securing PII through appropriate technical, administrative, and procedural measures. via establishing a structured privacy management framework, your organization reduces legal exposure and strengthens information security resilience.

Your organization must:

  1. Identify applicable data privacy laws and contractual requirements.
  2. Develop clear policies and procedures for processing PII securely.
  3. Assign roles and responsibilities for PII protection.
  4. Implement safeguards that prevent unauthorized access or misuse.
  5. Monitor compliance through audits, risk assessments, and continuous improvements.

 

Scope of Control 5.34

This control applies to all organizational processes and covers all employees, contractors, third-party vendors, and service providers who handle PII directly or indirectly within your organization. Involving:

  • Collection of PII from employees, customers, vendors, or partners.
  • Processing and storage of PII in digital or physical formats.
  • Transmission of PII across networks, including cloud storage.
  • Sharing or disclosure of PII with third parties.
  • Retention and deletion of PII based on legal or business requirements.

Components of Control 5.34

1. Establishing a Privacy Policy

Your organization should develop a topic-specific privacy policy that:

  • Defines what PII is collected and the purpose of its use.
  • Explains how PII is stored, processed, and shared securely.
  • Outlines employee responsibilities for safeguarding PII.
  • Includes provisions for incident response in case of a data breach.
  • Provides guidelines for third-party data processors.

This policy should be accessible to all stakeholders and regularly reviewed and updated to reflect regulatory changes.

2. Implementing Privacy Procedures

In addition to a policy, your organization must establish clear procedures for handling PII, including:

  • PII Classification: Identifying and labeling different types of PII.
  • Data Collection: Ensuring PII is collected with consent and for legitimate business purposes.
  • Data Access Control: Restricting PII access to authorized personnel only.
  • Data Encryption: Encrypting PII at rest and in transit.
  • Data Retention & Deletion: Defining retention periods and ensuring secure deletion when PII is no longer needed.

These procedures must be documented, enforced, and communicated across all relevant departments.

3. Assigning Roles and Responsibilities

Your organization should appoint a Privacy Officer (or Data Protection Officer – DPO) to:

  • Oversee compliance with privacy laws and Control 5.34.
  • Develop training programs for employees handling PII.
  • Advise on best practices for protecting PII.
  • Monitor third-party compliance with data protection agreements.
  • Conduct internal privacy audits to ensure policy enforcement.

Employees, IT administrators, and third-party vendors should also have clearly defined roles and accountability for handling PII.

4. Implementing Technical and Organizational Protection

To protect PII from cyber threats, your organization must implement the following safeguards:

Technical Controls

  • Encryption: Use strong encryption (AES-256, TLS) for PII storage and transmission.
  • Access Controls: Implement role-based access control (RBAC) and multi-factor authentication (MFA).
  • Data Masking: Mask or anonymize PII in non-production environments.
  • Audit Logs: Maintain logs for all PII access and modifications.
  • Intrusion Detection & Prevention: Deploy firewalls, endpoint security, and DLP solutions to monitor and prevent data leakage.

Organizational Controls

  • Privacy Awareness Training: Educate employees about PII risks and security protocols.
  • Third-Party Risk Management: Ensure vendors handling PII comply with contractual security obligations.
  • Data Minimization: Collect only necessary PII to reduce privacy risks.
  • Incident Response & Breach Notification: Develop a PII breach response plan with clear reporting and remediation steps.

Implementation Steps for Control 5.34

Step 1: Identify Applicable Laws and Regulations

  • Research data protection laws (e.g., GDPR, CCPA, LGPD) relevant to your business.
  • Identify contractual obligations related to PII security.
  • Map PII processing activities to compliance requirements.

Step 2: Develop a Privacy Program

  • Draft policies and procedures for PII handling.
  • Appoint a Privacy Officer or compliance lead.
  • Conduct a Privacy Impact Assessment (PIA).

Step 3: Implement Security Measures

  • Deploy technical and administrative safeguards (encryption, access control, monitoring).
  • Establish incident response plans for data breaches.
  • Train employees on PII security best practices.

Step 4: Monitor Compliance & Continuous Improvement

  • Perform regular internal audits on PII protection measures.
  • Update policies based on regulatory changes.
  • Use key performance indicators (KPIs) to measure privacy effectiveness.

Relevant Standards and Frameworks

ISO Standards

Legal & Compliance Frameworks

Related ISO 27001 Controls

Control 5.34 aligns with:

  • Control 5.9 – Information and asset inventory.
  • Control 5.31 – Legal and regulatory compliance.
  • Control 5.33 – Record protection.
  • Control 5.35 – Independent security reviews.

Supporting Templates Available

templates can facilitate efficiency and consistency in implementing Control 5.34.

  • Privacy Policy Template – For drafting a compliant privacy policy.
  • PII Handling Procedure Template – For defining data protection steps.
  • Privacy Impact Assessment (PIA) Template – For evaluating PII risks.
Control 5.33
ISO 27001 overview
Control 5.35