In an era where data privacy is no longer a luxury but a necessity, the ISO/IEC 27701 standard has emerged as a cornerstone for organisations aiming to demonstrate responsible personal data management. With the release of ISO/IEC 27701:2025, the standard has undergone a significant transformation from its 2019 predecessor. At MAST Consulting, we believe it is essential for businesses in the UAE and beyond to understand what these changes mean and how they can prepare for the future of privacy governance.

From Extension to Independence

The most notable shift in the 2025 version is that ISO/IEC 27701 is no longer an extension of ISO/IEC 27001. In the 2019 edition, organisations were required to implement an Information Security Management System (ISMS) under ISO/IEC 27001 before they could adopt a Privacy Information Management System (PIMS) through ISO/IEC 27701. This dependency created a barrier for many businesses, especially small and medium-sized enterprises.

The 2025 revision removes this requirement. ISO/IEC 27701 is now a standalone standard. This change opens the door for a broader range of organisations to implement privacy controls without the prerequisite of a full ISMS. It reflects a global recognition that privacy is a distinct discipline, not merely a subset of information security.

Structural and Control Enhancements

The new version introduces a refined structure aligned with other ISO management system standards. Clauses 4 to 10 now define the core requirements for establishing, implementing, maintaining and continually improving a PIMS. This alignment makes it easier for organisations to integrate privacy management with other systems such as ISO 9001 (quality), ISO/IEC 42001 (AI management), and ISO/IEC 27001 (information security).

In terms of controls, the 2025 edition streamlines and focuses its approach. The previous reliance on the Statement of Applicability from ISO/IEC 27001 has been removed. Instead, the new version introduces:

– 31 controls for Personally Identifiable Information (PII) Controllers
– 18 controls for PII Processors
– 29 shared controls applicable to both roles

This targeted approach ensures that privacy-specific risks are addressed more effectively, especially in areas such as AI, cloud computing, and cross-border data transfers.

Broader Regulatory Alignment

ISO/IEC 27701:2025 has been updated to reflect the evolving global privacy landscape. It now aligns more closely with international regulations such as the GDPR (Europe), CCPA/CPRA (United States), LGPD (Brazil), and emerging laws across Asia and Africa. The scope has also expanded to include biometric data, health data, and Internet of Things (IoT) information.

This global perspective is particularly relevant for organisations operating in the UAE, where cross-border data flows and compliance with international standards are increasingly critical.

Transition and Implementation

Organisations currently certified under ISO/IEC 27701:2019 will need to transition to the new version. While the official transition period is expected to be around two to three years, early planning is advisable. Key steps include:

– Conducting a gap analysis between the 2019 and 2025 requirements
– Updating privacy roles and responsibilities
– Engaging with certification bodies to plan the transition

How Mast Consulting Can Help ?

Mast Consulting helps organisations transition smoothly to ISO/IEC 27701:2025 by:

– Conducting gap assessments between 2019 and 2025 versions
– Developing a transition roadmap for certification
– Updating privacy roles, controls, and documentation
– Providing training and awareness for compliance teams

Stay compliant. Stay ahead. Partner with Mast Consulting for your privacy governance journey.