ISO 27701: What the 2025 standard for certifiable privacy provides
ISO 27701 is now the central benchmark for truly certifiable and measurable privacy. ISO 27701 allows organizations to transform personal data protection from a bureaucratic requirement into a strategic lever for trust and competitiveness: are you ready to make this leap?
The ISO/IEC 27701:2025 standard goes beyond the 2019 approach, strengthening accountability and integration with daily business processes. At its core is the organization's ability to consciously assess the risks arising from the processing of personal data, with a focus on individuals' rights.
Risk analysis, in fact, is not limited to IT vulnerabilities alone, but requires assessing the potential consequences for the rights and freedoms of data subjects. An incident, unauthorized access, or improper use of data is critical not only because it threatens the infrastructure, but also because it can cause tangible harm to individuals: loss of privacy, social or professional marginalization, discrimination, and economic or psychological harm.
The regulation therefore requires the precise identification of processing operations, an understanding of the contexts of use, and the definition of appropriate technical and organizational measures, based on a rigorous principle of proportionality. Each control must be justified by the actual risk and not applied abstractly: this shifts the management model from a purely document-based approach to one truly focused on protecting individuals.
While the 2019 version was a natural extension of ISO/IEC 27001 and ISO/IEC 27002, designed primarily to integrate the information security management system with specific controls dedicated to the protection of personal data, the new ISO/IEC 27701:2025 takes a broader conceptual and operational leap. The standard promotes a mature approach, in which data protection is not a formal obligation, but a key driver of market credibility.
ISO 27701 and understanding the organizational context
The adoption of ISO 27701:2025 follows a gradual process that begins with defining the system's scope and fully understanding the organizational context. This begins with a precise mapping of the business context: it is necessary to identify which types of personal data are processed, for what purposes, on what legal bases, and with which stakeholders.
It's also essential to understand data subjects' expectations and the obligations arising from national and international regulations, from the GDPR to non-EU regulations. This preliminary analysis allows us to concretely define the scope of the PIMS (Privacy Information Management System), because a management system cannot be designed in the abstract, but must be implemented within the organization's operational reality.
The model required by ISO/IEC 27701:2025 encourages integrating privacy into core processes: product development, marketing, sales, supplier management, cloud services, and customer care. This is where natural connections emerge with the use of digital channels like WhatsApp Business and automation platforms, which must be assessed in terms of risk, legal bases, information, and data subject request management.
In this initial phase, the regulation encourages companies to accurately record processing operations, classify data (e.g., general, sensitive, and judicial data), define flows between internal systems and external providers, and analyze dependencies on cloud platforms. It is on this basis that the PIMS can be realistically planned, avoiding both underestimation and overburden.
Roles, responsibilities and documentation in the ISO 27701 model
After understanding the context, ISO 27701 requires defining roles, responsibilities, and organizational structure. Data protection cannot be delegated to a single technical department: it must be governed by management, with clear and traceable lines of responsibility.
The organization must identify decision makers (management, DPO, department heads), who applies measures, who controls, who monitors, who performs internal audits, and who maintains contact with data subjects. This aspect becomes crucial in contexts where data processing is distributed across multiple digital channels, such as websites, CRMs, business messaging platforms, and third-party APIs.
Once the accountability structure has been defined, the system's documentary framework must be established. This isn't about producing forms for their own sake, but rather translating into procedures what the company chooses to do in practice. The value of documentation lies in its ability to provide operational evidence of the choices made: retention criteria, consent management, data breach management, and instructions for data controllers.
This documentation framework becomes even more important when orchestrating automated communication flows, such as WhatsApp Business campaigns or chatbots based on official APIs. Clear policies and procedures allow you to demonstrate that automation is privacy-by-design and that customer interactions remain fully GDPR compliant.
Risk assessment, proportionate measures and continuous improvement
At the heart of ISO 27701 remains a risk assessment focused on human rights. To achieve compliance, the company must demonstrate its ability to analyze processing operations, identify threats, estimate the likelihood of an adverse event, and quantify its impact on individuals' rights and freedoms.
Only after this analysis is it possible to define appropriate technical and organizational measures. Each control must be risk-based and not applied mechanically: encryption, pseudonymization, network segmentation, access segregation, storage limitations, and supplier verification must be proportionate to the nature of the processing and the exposure to harm.
ISO/IEC 27701:2025 also requires specific attention to supply chains and the use of cloud services. This is particularly relevant for those using SaaS platforms, marketing automation tools, or API-based customer messaging solutions. Each provider must be assessed, contracted, and monitored for data protection requirements and applicable regulations, such as the GDPR, CCPA/CPRA, or LGPD.
With this structured foundation, the system must become part of everyday business operations. The standard requires real, not theoretical, implementation: policies must be understood by staff, procedures implemented, and measured through performance indicators, internal audits, and periodic management reviews.
It is precisely this control cycle that distinguishes a living system from a simple collection of documents. The company must be able to demonstrate that it has not only defined a model, but that it manages it over time, correcting critical issues and continuously improving its data processing processes.
ISO 27701, Owner and Responsible: Roles, Supply Chain, and Certification
ISO 27701 emphasizes the operational distinction between data controller and data processor, clarifying roles and responsibilities in the standard's two main annexes: Annex A for PII Controllers and Annex B for PII Processors. The new wording mandates a shared accountability model, in which each stakeholder in the supply chain must adopt consistent and verifiable measures.
This approach is crucial in a digital ecosystem where most data processing involves suppliers, cloud platforms, and external services. Consider, for example, omnichannel communications solutions or analytics and AI services applied to user behavior: every link in the chain must contribute to the protection of personal data.
Companies that choose to adopt ISO/IEC 27701:2025 achieve tangible benefits. Certification provides documentary proof of compliance, strengthens reputation, and speeds up the closing of commercial agreements with partners who process personal data extensively. It also allows for harmonized compliance with different regulations, from the GDPR to US laws such as CCPA and CPRA, to global standards such as LGPD and PIPL, avoiding fragmented requirements and procedures.
The issue of IAF accreditation remains open.’International Accreditation Forum has not yet published official guidelines on the accreditation of ISO/IEC 27701:2025 standalone certifications. The standard clearly states that it can be certified on its own, but until an official position paper is released, there may be a transition phase with inconsistent interpretations across countries. This is a transition already seen with other standards, and is expected to be resolved with the publication of unambiguous rules.
A well-designed PIMS doesn't limit innovation: it makes it sustainable, transparent, and robust over the long term. In a market built on trust, the ability to demonstrate that people's data is managed responsibly represents a competitive advantage and a distinguishing feature in tenders, partnerships, and customer engagement.
To further explore the regulatory framework on the protection of personal data, it is also useful to refer to the text of the Regulation (EU) 2016/679 (GDPR) and the general references on privacy present on Wikipedia, so as to contextualize ISO 27701 in a broader regulatory ecosystem.
ISO 27701: Impact on Marketing and Business
ISO 27701 has a direct impact on digital marketing strategies and customer experience. In an environment where campaigns are increasingly data-driven, the ability to demonstrate certifiable privacy becomes a key factor in building trust throughout the customer journey.
Lead generation, segmentation, campaign automation, and communication activities on channels such as WhatsApp Business, email, or social media rely on the systematic processing of personal data. A PIMS compliant with ISO/IEC 27701:2025 allows you to document legal bases, consents, retention periods, and profiling methods, reducing the risk of disputes and penalties.
For businesses, this means being able to scale marketing initiatives with greater security, integrating CRM, marketing automation, and business messaging tools into a clear control framework. Companies can, for example:
- automate transactional and promotional communications by demonstrating the lawfulness of the processing;
- connect chatbots and campaigns to granular and updatable consent logic;
- measure the performance of initiatives without resorting to invasive profiling.
In terms of customer experience, ISO 27701 encourages transparent processes: clear information, simple channels for exercising rights, clear response times, consistent marketing messages, and effective data management. Those who successfully combine personalization and privacy protection achieve stronger conversion rates and long-term customer relationships.
Furthermore, in complex B2B markets, the presence of an ISO/IEC 27701:2025 certification can become a tender requirement or an accelerator in commercial negotiations, because it reassures partners and customers of the level of maturity in privacy management.
How SendApp Can Help with ISO 27701
SendApp provides concrete support to companies seeking to align their digital communication channels with ISO 27701 and GDPR requirements. Specifically, it allows you to design WhatsApp Business workflows and conversational automations while keeping track of data processing, consent, and traceability.
With SendApp Official Businesses can use the official WhatsApp APIs in a structured and compliant manner, integrating the channel into their CRM and PIMS systems. This facilitates the application of the privacy by design and by default principles required by ISO/IEC 27701:2025.
SendApp Agent It allows you to manage customer conversations in teams, with differentiated roles and permissions, activity logs, and chat assignments. These elements help demonstrate access control, clear responsibilities, and traceability of operations, as required by the ISO 27701 model.
For advanced automation needs, SendApp Cloud It allows you to orchestrate campaigns, notifications, templates, and API integrations in a centralized environment. This allows companies to standardize messages, define data retention rules, and manage opt-ins and opt-outs consistently with their PIMS policies.
Implementing a SendApp-based communication system, integrated with an ISO 27701-compliant PIMS, means transforming WhatsApp Business and messaging channels into powerful yet secure and privacy-friendly tools. This approach reduces risk, improves the customer experience, and strengthens the company's reputation as a reliable partner.
If you are considering a path towards ISO/IEC 27701:2025 or want to make your WhatsApp Business activities more structured and compliant, you can discover all the solutions on the website SendApp and request a dedicated consultation. This is the first step towards aligning marketing, customer care, and compliance into a single, integrated ecosystem.
