Implementation & guidance

ISO/IEC 27018 PII Protection in Public Cloud

Current edition: ISO/IEC 27018:2025 · extension to ISO/IEC 27001

Guidelines for public cloud providers acting as processors of personally identifiable information. It adapts ISO/IEC 27002 controls to cloud processing and adds controls based on the ISO/IEC 29100 privacy principles.

2025Third edition

ISO/IEC 27018:2025 is published

The third edition, published in August 2025, aligns the guidance with ISO/IEC 27002:2022 and the updated ISO/IEC 29100 privacy framework. Providers using the 2019 edition should review their control mapping and Statement of Applicability.

Review your controls
What the guidance covers

Protecting PII in the public cloud

ISO/IEC 27018 focuses on what a public cloud processor must do to protect customer personal data and support its customers' obligations.

Customer instructions

PII processed only according to the customer's instructions.

Purpose limitation

No use of customer PII for the provider's own purposes, such as marketing, without consent.

Data subject requests

Support for customers responding to access and deletion requests.

Sub-processors

Disclosure and control of sub-processors that handle PII.

Disclosure requests

Handling of legally binding requests for disclosure of PII.

Breach notification

Prompt notification to customers of incidents affecting their PII.

Return and deletion

PII returned or securely deleted at the end of the service.

Data location

Transparency about the countries where PII may be stored or processed.

Why organisations implement it

What cloud PII assurance delivers

Processor due diligence

A recognised answer to customers' data processing questionnaires.

GDPR support

Controls that support processor obligations under data protection law.

Transparent sub-processing

Clear disclosure and control of your sub-processors.

Faster sales cycles

Fewer bespoke privacy reviews for enterprise customers.

One audit programme

Assessed alongside your ISO/IEC 27001 certification.

Path to a full PIMS

A step towards ISO/IEC 27701 where customers expect it.

How we work

Path to assessed PII controls

One AEC methodology from first assessment to assessment, delivered by registered lead auditors.

  1. AssessGap assessment against ISO/IEC 27018, scope and roadmap
  2. DesignProcesses, risk register, policy and documented information
  3. ImplementProcesses embedded with coaching for process owners
  4. TrainAwareness for all staff and internal auditor development
  5. VerifyInternal audit, management review and mock certification audit
  6. Certify & sustainStage 1 and Stage 2 support, then surveillance readiness
Already ISO/IEC 27001

Control extension

We add the controls to your existing ISMS and Statement of Applicability.

Typically 2 to 4 months
ISMS in progress

Combined build

We build ISO/IEC 27001 and the additional controls together.

Typically 6 to 9 months
Customer assurance

Readiness review

We test your controls against customer or regulator expectations before an audit.

Typically 1 to 2 months
How it is recognised

Assessed as an extension of ISO/IEC 27001

ISO/IEC 27018 is a code of practice, not a standalone certifiable management system standard. Its controls are implemented within an ISO/IEC 27001 management system, and many accredited certification bodies assess them alongside the ISO/IEC 27001 audit, referencing ISO/IEC 27018 on the certificate or in a separate statement. AEC prepares you for that assessment; the decision is the certification body's.

Built on your ISMS

Controls added to your ISO/IEC 27001 risk treatment and Statement of Applicability.

Assessment-ready

Evidence organised so the certification body can assess the additional controls in the same audit.

No guarantees

We prepare you thoroughly and never promise an outcome only an independent auditor can decide.

Questions

ISO/IEC 27018 FAQ

Can we be certified to ISO/IEC 27018 alone?

No. ISO/IEC 27018 is a code of practice. Its controls are implemented within an ISO/IEC 27001 ISMS, and many certification bodies assess them during the ISO/IEC 27001 audit and reference them on the certificate or in a statement.

ISO/IEC 27018 or ISO/IEC 27701?

ISO/IEC 27018 is focused guidance for public cloud processors. ISO/IEC 27701:2025 is a full, standalone privacy management system for controllers and processors. Providers with demanding customers often implement both.

Does it apply if we are a private cloud or hosting provider?

The guidance is written for public cloud processors, but many of its controls are useful for other processing services. We confirm the right scope during the gap assessment.

Does AEC issue the certificate?

No. Certification and any reference to ISO/IEC 27018 are issued by an accredited certification body. AEC prepares your controls and evidence.

Protect customer data in your cloud

Tell us your cloud services and data processing. We reply with a proposal covering control design, implementation and assessment readiness.

Certification decisions are made by independent, accredited certification bodies. AEC prepares organisations for certification and does not guarantee certification outcomes.