Privacy information management governance

“Governance” is where privacy programs either become durable operations or stay as policy binders no one can defend in an audit. Under ISO/IEC 27701, the privacy information management governance requirement expects you to establish oversight for privacy objectives: who sets them, who approves risk decisions, who tracks progress, and how leadership reviews performance ¹.

For a CCO, Compliance Officer, or GRC lead, the fastest path is to treat this as a management system requirement, not a documentation exercise. Auditors will test two things: (1) can you show defined accountability and oversight mechanisms for the PIMS, and (2) can you prove those mechanisms operate in practice through records and outcomes. If you can answer “who decides?” and “show me the last time you reviewed it” without scrambling, you’re close.

This page gives requirement-level implementation guidance you can execute quickly: a practical interpretation, applicability, step-by-step build instructions, artifacts to retain, common audit hangups, and a concrete execution plan. It stays within the publicly available ISO/IEC 27701 overview information and does not reproduce licensed ISO text ¹.

Privacy information management governance requirement (ISO/IEC 27701): plain-English meaning

Requirement intent: establish governance for privacy information management objectives ¹.

In practice, you must be able to show:

• A defined PIMS scope (what parts of the organization, products, systems, and processing activities are in or out).
• Named ownership and accountability (who is responsible for privacy outcomes, who runs the PIMS day-to-day, and who provides independent oversight).
• Decision-making processes (how privacy risk is accepted/treated, how exceptions are approved, and how priorities are set).
• Oversight and review (a repeatable way leadership reviews privacy objectives, performance, and issues, then assigns actions and tracks completion).

If your privacy program is run by “good people doing their best” but you cannot produce governance artifacts and operating records, you will struggle to demonstrate conformance to the privacy information management governance requirement.

Who it applies to (entity and operational context)

ISO/IEC 27701 is relevant to organizations acting as:

• Data Controllers (entities determining purposes/means of processing), and
• Data Processors (entities processing on behalf of a controller) ¹.

Operationally, this requirement applies wherever you:

• collect, use, share, store, or delete personal data;
• design products or services that process personal data;
• rely on third parties for hosting, analytics, customer support, payments, HR services, marketing platforms, or other processing.

A common boundary mistake: treating governance as only a privacy office concern. For ISO/IEC 27701, governance must connect the privacy function to business owners, security, legal, engineering, HR, and procurement so decisions are made by the people who control systems and processes.

Regulatory text

Provided excerpt: “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” ¹

Operator interpretation: You are expected to establish governance for privacy information management objectives ¹. Concretely, that means you must define the PIMS scope, ownership, and oversight procedures, then operate them with evidence ¹.

What you actually need to do (step-by-step)

Use this build sequence to operationalize governance quickly while staying audit-ready.

Step 1: Set and document the PIMS scope

Create a one-page scope statement that answers:

• Legal entities included
• Business units, products/services included
• Systems and data stores included (at least by category)
• Processing contexts (employee, customer, B2B contacts, users, etc.)
• Material exclusions and why they are excluded

Execution tip: Don’t boil the ocean. Start with the systems/processes that support your highest-risk processing and your highest-revenue products. Expand scope through a controlled change process.

Step 2: Assign ownership, accountability, and oversight (RACI)

Document a RACI that includes, at minimum:

• Executive sponsor (accountable for resourcing and management review)
• PIMS / privacy program owner (responsible for operating the system)
• Security owner (interfaces with ISMS and technical controls)
• Legal/privacy counsel (interpretation, contracting position, claims)
• Engineering/product owner(s) (build and change control)
• Procurement/TPRM (third-party due diligence for processors/sub-processors)
• Internal audit or compliance monitoring (independent challenge)

Make decision rights explicit:

• Who can accept privacy risk?
• Who can approve exceptions to privacy requirements?
• Who can change PIMS scope?

Step 3: Create a governance forum with a charter

Stand up a Privacy Governance Committee (or fold it into an existing risk committee) with a written charter:

• Purpose and authority (what it can decide vs recommend)
• Membership and quorum rules
• Inputs (risk register, incidents, DPIA/PIA outcomes, third-party issues)
• Outputs (approved objectives, risk decisions, action items)
• Escalation path to senior management

Keep it practical: Governance fails when meetings become status theater. Require every meeting to end with a short, dated action log with owners.

Step 4: Define privacy objectives and how you measure them

Create a privacy objectives register:

• Objective statement (e.g., reduce unresolved privacy risks, increase completion of assessments, improve third-party controls)
• Owner
• Measurement method (what evidence proves progress)
• Target state and timeline (your internal target, not a mandated number)
• Dependencies and budget/resource notes

Tie objectives to operational mechanisms:

• PIAs/DPIAs
• Data inventory and data lifecycle management
• Training and awareness
• Third-party due diligence and contract controls
• Incident response coordination

Step 5: Establish a management review process

Set a documented management review agenda that covers:

• Status of privacy objectives
• Significant risks and accepted risks
• Privacy incidents and near misses
• Third-party processing issues
• Audit/internal assessment results and corrective actions
• Resource constraints and planned program changes

Audit reality: Auditors commonly ask for evidence of “review” and “improvement.” Meeting minutes plus a tracked corrective action plan is the fastest way to prove operation.

Step 6: Integrate governance into change and procurement workflows

Governance is weak if it is detached from delivery. Add triggers:

• Product change intake includes privacy review questions
• New third party onboarding requires privacy/security due diligence and contract review
• Material data processing changes require a documented assessment and approval

If you use Daydream, map these triggers to workflow tasks so governance artifacts (approvals, decisions, evidence) are captured as part of how work gets done, not after the fact.

Required evidence and artifacts to retain

Auditors want “say, show, prove.” Keep these artifacts centralized and version-controlled:

Foundational documents

• PIMS scope statement and scope change log
• Governance charter(s) and committee membership list
• RACI / responsibility matrix for privacy management
• Privacy objectives register (with owners and measurement approach)

Operational records

• Meeting agendas, minutes, and attendance for governance and management reviews
• Action-item register with owners, due dates, and closure evidence
• Risk decisions and exception approvals (including rationale)
• Internal review or audit reports and corrective action plans

Supporting cross-functional artifacts

• Third-party due diligence checklist outputs for processors/sub-processors (where applicable)
• Procurement workflow evidence showing privacy sign-off for applicable third parties
• Change management tickets showing privacy review steps occurred

Common exam/audit questions and hangups

Expect questions like:

• “Show me the defined scope of your PIMS and why exclusions are justified.”
• “Who is accountable for privacy objectives? Show me a RACI.”
• “How do you set and approve privacy objectives? Show me the last management review.”
• “How are privacy risks escalated and accepted? Who can approve exceptions?”
• “How do you ensure third parties processing personal data are governed under your PIMS?”

Hangups that slow teams down:

• Objectives are aspirational but not measurable.
• Committees exist but have no decision authority.
• Minutes exist but no action tracking or closure evidence.
• Scope is vague (“company-wide”) without boundaries.

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Treating governance as policy-only.
Fix: require operating records (minutes, action logs, risk decisions) and store them with the program evidence.

Mistake 2: Unclear decision rights for risk acceptance and exceptions.
Fix: add explicit approval authority levels in the governance charter and exception procedure, then test it with a real exception.

Mistake 3: Scope that doesn’t match reality.
Fix: reconcile scope against your system inventory, third-party list, and key processing activities. If you cannot support “in scope,” narrow it and document the plan to expand.

Mistake 4: Privacy objectives disconnected from delivery teams.
Fix: assign at least some objectives to product/engineering/procurement owners and track progress in the same systems they use.

Enforcement context and risk implications

No public enforcement cases are provided in the source catalog for this requirement, so this page does not list enforcement examples.

Risk-wise, weak governance creates predictable failure modes: privacy decisions are inconsistent, third-party processing expands without oversight, and leadership cannot demonstrate control effectiveness. Even where ISO/IEC 27701 is voluntary, customers and auditors use governance evidence to judge whether privacy commitments are credible ¹.

Practical 30/60/90-day execution plan

This plan assumes you’re building governance from scratch or formalizing an informal program.

Days 1–30: Define the system and decision rights

• Draft and approve PIMS scope statement.
• Build privacy governance RACI across compliance, legal, security, engineering, procurement.
• Write governance committee charter and schedule recurring meetings.
• Stand up a single evidence repository (GRC tool or controlled document store).
• Publish a privacy objectives template and draft initial objectives with owners.

Days 31–60: Operate governance and generate evidence

• Hold the first governance committee meeting; produce minutes and action log.
• Hold the first management review with leadership; document decisions and assigned actions.
• Create a risk/exception intake and approval workflow (even if simple).
• Add privacy review gates to (a) procurement/third-party onboarding and (b) change management.

Days 61–90: Stabilize, test, and prepare for audit

• Run a second governance cycle and show progress against objectives.
• Close initial action items and retain closure evidence.
• Perform an internal “audit-style” check: can you produce scope, RACI, objectives, meeting records, and risk decisions quickly?
• If using Daydream, configure control-to-evidence mapping so every governance activity auto-collects the right artifacts for ISO/IEC 27701 audits.

Frequently Asked Questions

Do we need a separate privacy committee, or can we use an existing risk committee?

Either can work if the forum has written authority, defined inputs/outputs, and produces records that show privacy objectives and decisions are reviewed ¹. Auditors care more about evidence of operation than the committee name.

How specific does PIMS scope need to be?

Specific enough that a reviewer can tell what processing is covered and what is excluded, and you can defend those boundaries with a rationale. A vague “enterprise-wide” scope is hard to evidence unless your artifacts truly span the enterprise.

What’s the minimum evidence set to pass an ISO/IEC 27701 governance review?

Scope statement, governance charter, RACI, objectives register, and management review records (minutes plus action tracking) typically form the core package ¹. Add risk/exception approvals if you have them.

Who should own privacy objectives, the DPO/privacy officer or the business?

The privacy function should coordinate, but objectives should have owners in the teams that can execute change (product, engineering, HR, procurement). Keep a single accountability point for the PIMS, but distribute responsibility.

How do we connect third-party risk to privacy governance?

Put procurement/TPRM in the RACI, define privacy review triggers for third-party onboarding, and route high-risk processors to the governance forum for decisions. Retain due diligence outputs and approvals as governance evidence.

We’re pursuing ISO 27001 and 27701 together. Can we share governance artifacts?

Yes, as long as privacy objectives and privacy-specific decisions are visible and reviewed under the PIMS governance model ¹. Shared committees and minutes are fine if privacy topics are explicitly covered and tracked.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. ISO/IEC 27701 overview