Personally Identifiable Information is not just another data type.
It carries legal obligation, regulatory scrutiny, and reputational risk by default.
Annex A 5.34 exists to ensure organisations protect the privacy, confidentiality, and integrity of PII in line with applicable legal, statutory, regulatory, and contractual requirements.
This control recognises that PII requires additional, deliberate handling beyond general information security controls.

Annex A 5.34 of ISO 27001:2022 focuses on the privacy and protection of personally identifiable information (PII).
At a practical level, this means:
The control does not replace data protection law or privacy regulation. It ensures that information security supports privacy obligations, rather than undermining them.
PII includes any information that can be used to identify an individual, such as:
Loss or misuse of PII can result in:
Annex A 5.34 ensures organisations treat PII as a special category of information, requiring focused governance, protection, and oversight.
This control reinforces that privacy is not achieved through policy statements alone — it relies on effective information security practices.
A pragmatic approach to Annex A 5.34 typically includes the following elements.
Organisations should understand:
Visibility is essential. PII cannot be protected if it is not understood.
Clear responsibility supports consistent handling.
Organisations often assign oversight to:
This role typically provides guidance, oversight, and advice to management and operational teams.
PII protection benefits from dedicated guidance.
Policies and procedures often address:
Generic information security policies are rarely sufficient on their own.
Protection of PII typically involves a combination of:
Controls should reflect the sensitivity and volume of PII involved.
PII protection obligations vary by jurisdiction.
Organisations should consider:
Annex A 5.34 expects organisations to design controls with these obligations in mind, not attempt to retrofit compliance later.
Where PII is processed by suppliers or transferred internationally, organisations should ensure:
Third-party processing does not transfer accountability.
Annex A 5.34 recognises that:
The control does not prescribe a single privacy framework. It expects organisations to:
For organisations with significant privacy obligations, alignment with standards such as ISO/IEC 27701 may be appropriate.
Privacy failures usually result from fragmentation, not absence of controls.
Annex A 5.34 is about protecting individuals as well as organisations.
When privacy and PII protection are managed effectively:
Personally identifiable information carries inherent responsibility.
Annex A 5.34 ensures organisations recognise and manage that responsibility deliberately.
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