ISO 27001:2022 Annex A 5.34 – Privacy and Protection of Personally Identifiable Information (PII) Explained

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.

ISO 27001

Quick Guide: Annex A 5.34 at a Glance

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:

  • Identifying where PII is processed, stored, or transferred
  • Protecting PII from unauthorised access, disclosure, or misuse
  • Respecting individual privacy rights
  • Aligning information security controls with privacy obligations
  • Complying with applicable legal, regulatory, and contractual requirements

The control does not replace data protection law or privacy regulation. It ensures that information security supports privacy obligations, rather than undermining them.

In-Depth Guide to Annex A 5.34

What Is Annex A 5.34 and Why Does It Matter?

PII includes any information that can be used to identify an individual, such as:

  • Names, addresses, and contact details
  • Identification numbers
  • Financial or health information
  • Online identifiers and credentials

Loss or misuse of PII can result in:

  • Regulatory penalties
  • Legal action
  • Contractual breach
  • Loss of trust and reputational damage

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.

How to Implement Annex A 5.34 Effectively

A pragmatic approach to Annex A 5.34 typically includes the following elements.

1. Identify and Understand PII Processing

Organisations should understand:

  • What PII they process
  • Why it is processed
  • Where it is stored or transmitted
  • Who has access to it

Visibility is essential. PII cannot be protected if it is not understood.

2. Define Privacy and PII Protection Responsibilities

Clear responsibility supports consistent handling.

Organisations often assign oversight to:

  • A Privacy Officer
  • A Data Protection Officer
  • Or an equivalent accountable role

This role typically provides guidance, oversight, and advice to management and operational teams.

3. Establish PII-Specific Policies and Procedures

PII protection benefits from dedicated guidance.

Policies and procedures often address:

  • Lawful and appropriate use of PII
  • Access control and authorisation
  • Secure handling, storage, and transmission
  • Retention and disposal
  • Incident reporting involving PII

Generic information security policies are rarely sufficient on their own.

4. Apply Appropriate Technical and Organisational Controls

Protection of PII typically involves a combination of:

  • Access controls and authentication
  • Encryption or other protective measures
  • Logging and monitoring
  • Segregation of duties
  • Secure disposal processes

Controls should reflect the sensitivity and volume of PII involved.

5. Align with Legal and Regulatory Requirements

PII protection obligations vary by jurisdiction.

Organisations should consider:

  • National and regional privacy laws
  • Sector-specific regulation
  • Cross-border data transfer requirements
  • Contractual commitments

Annex A 5.34 expects organisations to design controls with these obligations in mind, not attempt to retrofit compliance later.

6. Address Third-Party and Cross-Border Processing

Where PII is processed by suppliers or transferred internationally, organisations should ensure:

  • Responsibilities are clearly defined
  • Appropriate safeguards are in place
  • Compliance obligations are understood and enforced

Third-party processing does not transfer accountability.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Practical Considerations

Annex A 5.34 recognises that:

  • Privacy requirements differ between jurisdictions
  • PII processing evolves over time
  • Technology and data use change rapidly

The control does not prescribe a single privacy framework. It expects organisations to:

  • Understand their obligations
  • Apply appropriate information security controls
  • Review and adapt as requirements change

For organisations with significant privacy obligations, alignment with standards such as ISO/IEC 27701 may be appropriate.

Common Challenges and How to Overcome Them

  • Treating PII like any other data
  • Apply enhanced protection based on sensitivity and obligation
  • Unclear ownership of privacy responsibilities
  • Assign clear accountability and oversight
  • Relying solely on legal or compliance teams
  • Integrate privacy into operational security controls
  • Ignoring cross-border implications
  • Consider jurisdictional requirements explicitly

Privacy failures usually result from fragmentation, not absence of controls.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Final Recommendations

Annex A 5.34 is about protecting individuals as well as organisations.

When privacy and PII protection are managed effectively:

  • Legal and regulatory risk is reduced
  • Trust with customers and staff improves
  • Security controls align with real-world obligations
  • Incident impact is contained more effectively

Personally identifiable information carries inherent responsibility.
Annex A 5.34 ensures organisations recognise and manage that responsibility deliberately.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

The Annex Control Table

ISO 27001:2022 Organisational Controls
ISO 27001:2022 Technological Controls