🔐

What is ISO/IEC 27018?

A code of practice that extends ISO/IEC 27002 with privacy controls specifically for public cloud service providers acting as PII processors. It operationalizes processor obligations under privacy regulations like GDPR.

Cloud-Specific Controls

Addresses purpose limitation, consent handling, data subject rights support, breach notification, geographic transfer safeguards, secure deletion, and multi-tenant segregation requirements.

📋

Attestation Path

Organizations can pursue conformity assessment and attestation to demonstrate 27018 compliance. Major cloud providers publish 27018 compliance reports and certificates.

How ISO/IEC 27018 Relates to Other Standards

ISO/IEC 27018 works as part of an integrated privacy and security framework, building on established management system standards.

ISO/IEC 27001

Foundation: Information Security Management System. Strongly recommended prerequisite for implementing 27018 controls.

ISO/IEC 27002

Base Controls: Security controls catalogue that 27018 extends with privacy-specific guidance for cloud processors.

ISO/IEC 27018

Cloud PII: Privacy controls for public cloud processors handling personally identifiable information.

ISO/IEC 27017

Cloud Security: Complementary guidance for cloud security controls. Often implemented together with 27018.

ISO/IEC 27701

Privacy Management: Privacy Information Management System (PIMS) extension to 27001 for broader privacy governance.

ISO/IEC 29100

Privacy Framework: Privacy principles that 27018 aligns to for consistent privacy protection approaches.

Who Needs ISO/IEC 27018?

Primary Audience

CSP
Public Cloud Service Providers
Acting as PII processors for customer data
SaaS
Software-as-a-Service Providers
Processing customer PII in cloud environments
MSP
Managed Service Providers
Offering cloud-based data processing services
API
Platform-as-a-Service Providers
Enabling applications that process PII

Secondary Audience & Industries

👥
Cloud Customers
Assessing cloud provider privacy controls
🏥
Healthcare Organizations
HIPAA compliance in cloud environments
🏢
Financial Services
Regulatory compliance for customer data
🏛
Public Sector
Citizen data protection in cloud services
Utilities & Infrastructure
Customer data in smart grid and IoT systems

Implementation Timeline & Effort

Implementation timeline depends on existing security maturity and cloud architecture complexity.

Typical Project Duration

Already ISO 27001 Certified:
6–12 weeks to implement privacy deltas and evidence
Without ISO 27001:
12–20 weeks if building ISMS privacy processes in parallel
1

Gap Assessment & Planning

Assess current controls against 27018 requirements. Map data flows, processing activities, and sub-processor relationships. Develop implementation roadmap.

2

Policy & Documentation Development

Create PII processing policies, data processing agreements, privacy notices, and sub-processor management procedures.

3

Control Implementation

Implement technical and organizational controls for data lifecycle management, tenant segregation, geographic controls, and rights management.

4

Evidence & Attestation

Document control implementation, prepare evidence packages, and coordinate with certification body for conformity assessment.

Common Implementation Challenges

• Shared-responsibility gaps
• Incomplete PII inventory
• Sub-processor management
• Timely deletion/return
• Breach communication SLAs
• Geographic residency controls

What AEC Provides for ISO/IEC 27018

Comprehensive consulting and implementation support to achieve 27018 conformity and attestation.

Gap Assessment & Control Mapping FOUNDATION

  • Comprehensive gap assessment against 27018 controls
  • Statement of Applicability (SoA) for 27018
  • Control matrix mapped to 27002/27701 standards
  • Risk assessment for privacy controls
  • Implementation priority roadmap

Policy & Legal Framework GOVERNANCE

  • PII processing policy suite
  • Customer-facing privacy disclosures
  • Data processing agreement (DPA) templates
  • Sub-processor register and management procedures
  • Data retention and deletion policies

Cloud Control Implementation TECHNICAL

  • Data lifecycle management procedures
  • Logging and monitoring configurations
  • Key management and encryption controls
  • Multi-tenant segregation controls
  • Geographic residency and transfer controls

Rights & Incident Management OPERATIONAL

  • Data Subject Access Request (DSAR) workflows
  • Breach notification playbooks
  • Rights fulfillment procedures
  • Incident response integration
  • Customer communication templates

Evidence & Attestation Support COMPLIANCE

  • Control implementation documentation
  • Process records and automation evidence
  • Sampling and testing plans
  • Certification body coordination
  • 27001 + 27018 integrated assessment support

Training & Workshops CAPABILITY

  • 27018 Practitioner workshop for cloud teams
  • 27001 + 27018 integrated implementer training
  • 27701 PIMS add-on for privacy roles
  • Custom workshops for your environment
  • Ongoing competency development
Request Detailed Proposal   Get Implementation Quote

Frequently Asked Questions

What's the difference between ISO/IEC 27018 and 27701? +

ISO/IEC 27018 is specifically for public cloud service providers acting as PII processors, focusing on cloud-specific privacy controls. ISO/IEC 27701 is a broader Privacy Information Management System (PIMS) that extends 27001 for any organization handling personal data. Cloud providers often implement both: 27701 for overall privacy governance and 27018 for processor-specific obligations.

Do we need ISO 27001 certification first? +

While not legally required, ISO 27001 is strongly recommended as 27018 extends the 27002 security controls framework. Most organizations implement 27018 as part of their existing 27001 ISMS. This integrated approach is more cost-effective and provides better governance than standalone 27018 implementation.

How do auditors assess data deletion and sub-processor controls? +

Auditors review deletion procedures, retention policies, and technical implementation through documentation review, staff interviews, and technical testing. For sub-processors, they examine due diligence processes, contracts, monitoring procedures, and cascade requirements. Evidence typically includes automated deletion logs, sub-processor assessments, and contractual flow-downs of 27018 obligations.

How does this differ from ISO/IEC 27017 cloud security guidance? +

ISO/IEC 27017 focuses on cloud security controls for both providers and customers, while 27018 specifically addresses privacy and PII protection for cloud processors. 27017 covers infrastructure security, while 27018 covers data subject rights, consent management, and processor obligations under privacy laws. Many cloud providers implement both standards together.

Can we get certified to ISO/IEC 27018? +

ISO/IEC 27018 is a code of practice (guidance document), not a certifiable management system standard like 27001. However, organizations can pursue conformity assessment and attestation to demonstrate compliance with 27018 controls. Major cloud providers like AWS, Microsoft Azure, and Google Cloud publish 27018 compliance reports and attestations that customers can reference.

How does 27018 help with GDPR Article 28 processor requirements? +

ISO/IEC 27018 operationalizes many GDPR Article 28 processor obligations through specific controls for purpose limitation, data subject rights support, breach notification, sub-processor management, and international transfers. While 27018 compliance doesn't guarantee GDPR compliance, it provides a structured framework for implementing processor obligations and demonstrating accountability to data controllers.

Ready to Implement ISO/IEC 27018?

Expert guidance from gap assessment to attestation. Whether you're a cloud service provider or evaluating cloud privacy controls, our specialists can help you achieve 27018 conformity efficiently.