Processor obligations

The processor obligations requirement in ISO/IEC 27701 expects you to prove, with contracts and operating controls, that your organization can act as a reliable personal data processor for customers. Operationalize it by mapping each processor duty to a control, binding it in your data processing agreements (DPAs), and retaining audit-ready assurance evidence for customers and auditors ¹.

Key takeaways:

• Treat processor obligations as “contract terms + day-to-day operations + proof,” not a policy statement.
• Build a processor control-to-contract matrix and keep it current across all customer DPAs and subprocessor arrangements.
• Evidence wins audits: maintain a packaged set of assurance artifacts you can provide on request ¹.

“Processor obligations” is the requirement that separates a paper privacy program from a processor-ready operating model. If you process personal data on behalf of customers (the controller), ISO/IEC 27701 expects you to have controls that support your contractual and operational duties as a processor, and to be able to demonstrate them with evidence ¹. That means two things in practice: (1) your contracts must clearly define what you will do and what you will not do with customer personal data, and (2) your teams must consistently execute those commitments across engineering, security, support, and operations.

This page is written for a Compliance Officer, CCO, or GRC lead who needs to implement the processor obligations requirement quickly. It focuses on how to translate processor duties into a manageable set of controls, how to embed those controls into customer and subprocessor contracts, and how to package assurance evidence so you can respond to customer questionnaires and audit requests without scrambling.

Where helpful, this guidance uses familiar privacy and security program constructs (data mapping, access control, incident response, change management), but stays anchored to ISO/IEC 27701’s intent: implement controls supporting processor contractual and operational duties ¹.

Regulatory text

Provided excerpt (summary): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.”
Implementation intent: “Implement controls supporting processor contractual and operational duties.” ¹

What the operator must do:
You must be able to show (a) processor commitments exist in enforceable agreements (typically DPAs and security exhibits) and (b) your operational controls actually meet those commitments. Auditors and customers will look for traceability: each processor promise should map to an implemented control and to evidence that the control operates ¹.

Plain-English interpretation (what “processor obligations” really means)

If you are a processor, customers delegate processing to you with conditions. This requirement expects you to:

• Take instructions only from the customer (as defined in the contract / documented requests).
• Protect personal data appropriately through security and privacy controls.
• Control onward transfers (subprocessors and other third parties) and flow down obligations.
• Support the customer’s compliance needs (for example, responding to requests for information, audits, or assistance) as agreed.
• Keep proof that you do all of the above, in a format you can provide quickly ¹.

Your goal is operational confidence: no “heroics” when a customer asks, “Show me how you meet your processor obligations.”

Who it applies to (entity + operational context)

Applies to:

• Data processors: organizations processing personal data on behalf of another organization (customer/controller). Common examples include SaaS providers, payroll processors, managed services providers, analytics platforms, and call centers.
• Controllers who also act as processors: many organizations are controllers for their own HR/customer data and processors for customer data in their products ¹.

Operational contexts that trigger this requirement:

• You host, store, transmit, transform, analyze, or otherwise handle customer personal data.
• You engage subprocessors (cloud hosting, support tools, ticketing systems) that can access or store customer personal data.
• You provide support, professional services, or troubleshooting that may involve viewing or exporting customer personal data.

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

Use this as a build plan that produces audit artifacts, not just internal alignment.

Step 1: Confirm your “processor scope”

1. Inventory products/services where you process personal data for customers.
2. Identify data categories and processing activities per service (even a high-level service data map is enough to start).
3. Confirm which legal entity signs DPAs and which teams operate the controls (security, SRE, support, engineering, privacy).

Output: Processor scope statement + service-level data handling overview.

Step 2: Build a processor obligations register (your control-to-duty list)

Create a register of processor duties that your contracts typically include, then map each duty to:

• Control owner
• Control description (what happens, where, and by whom)
• Evidence produced
• Systems in scope
• Customer-facing commitment (contract clause / exhibit reference)

A practical starting structure:

Processor duty area	Operational control you run	Evidence you retain	Contract hook
Follow documented instructions	Intake and approval workflow for customer requests that change processing	Ticket records, approvals, change logs	DPA “instructions” clause
Security of processing	Access control, logging, encryption, vulnerability management	Access reviews, SOC reports/pen test summaries, configs, runbooks	Security exhibit / DPA security clause
Subprocessor controls	Subprocessor due diligence + flow-down terms + monitoring	Subprocessor list, DPAs, assessments	DPA subprocessor clause
Incident handling	Incident response plan + customer notification workflow	IR plan, incident tickets, postmortems, comms templates	DPA breach clause
Assistance and audit support	Customer assurance package + request handling	Questionnaire responses, audit logs, evidence pack index	DPA audit/assistance clause

Output: Processor obligations register (the single best artifact to run this requirement).

Step 3: Standardize your contract positions and fallback options

Work with Legal/Privacy to define:

• Your standard DPA template (or standard addendum).
• Approved alternates for common redlines (audit rights, subprocessor notice, liability tie-ins, security measures).
• A rule for when you accept customer paper vs. insist on your template.

Operator tip: If the business signs custom DPAs without GRC input, your control-to-contract traceability will break quickly.

Output: DPA playbook + clause library + approval workflow.

Step 4: Operationalize subprocessor management end-to-end

Subprocessors are where processor obligations fail in practice. Minimum operating set:

1. Maintain a current subprocessor inventory for services that touch customer personal data.
2. Perform onboarding due diligence proportionate to risk (security, privacy, access model).
3. Ensure written terms flow down relevant processor obligations.
4. Monitor changes (new subprocessors, material scope expansions).
5. Make customer communications consistent with your contractual commitments.

Output: Subprocessor register + due diligence records + executed agreements.

Step 5: Build the “customer assurance evidence pack”

Create a repeatable package you can share under NDA or via a trust portal. Include:

• Control summary aligned to processor obligations register
• Security/privacy policies that support commitments
• Incident response overview and reporting process
• Subprocessor list and notification approach
• Recent audit/assurance reports you are permitted to share
• Evidence index with owners and refresh cadence ¹

If you use Daydream, store the obligations register, DPA clause mappings, and evidence index in one place so renewals and customer requests do not become Slack archaeology.

Output: Versioned evidence pack + distribution process.

Step 6: Prove operation (not design) with testing and reviews

Run periodic checks that show controls are working:

• Sample customer instruction tickets and verify approvals.
• Review support access paths (break-glass, just-in-time access) and confirm logs exist.
• Test incident communications workflow with tabletop exercises.
• Reconcile subprocessor list against procurement/AP and production integrations.

Output: Review logs, test results, remediation tickets.

Required evidence and artifacts to retain (audit-ready checklist)

Keep these artifacts organized by service and legal entity:

1. Processor scope and data handling description (service overview, data categories, systems).
2. Processor obligations register with control mappings and owners.
3. Executed DPAs (or equivalent processor terms) and any negotiated deviations, with approvals.
4. Subprocessor inventory and change history; executed subprocessor agreements.
5. Customer request and instruction records (tickets, approvals, changes implemented).
6. Security control evidence that supports processor promises (access reviews, logging evidence, encryption configurations, vulnerability remediation records).
7. Incident response artifacts (plan, roles, training, tabletop results, incident tickets, notifications when applicable).
8. Assurance evidence pack and an evidence refresh log ¹.

Common exam/audit questions and hangups

Auditors and customer assessors often focus on traceability and subprocessor control.

Questions you should be ready to answer:

• “Show me where processor obligations are defined contractually for Service X.”
• “How do you ensure processing occurs only on customer instructions?”
• “How do you control and approve subprocessors, and how do you flow down obligations?”
• “Show evidence that support access to production data is controlled and logged.”
• “Provide your customer-facing incident notification process and evidence it has been tested.” ¹

Typical hangups:

• Contracts promise capabilities the platform does not enforce.
• Evidence exists but is scattered across teams with no index.
• Subprocessor list is outdated or not aligned to reality (tools with hidden data access).

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating “processor obligations” as a legal-only task.
   Avoidance: Make Legal clauses trace to control owners and evidence. The processor obligations register forces this.

2. Mistake: One generic DPA for all services.
   Avoidance: Attach service-specific security/processing exhibits or a service matrix. Otherwise, you will overpromise.

3. Mistake: Subprocessors managed as procurement only.
   Avoidance: Tie subprocessor onboarding to security/privacy review and to a maintained inventory tied to product architecture.

4. Mistake: Evidence-by-screenshot during audits.
   Avoidance: Build an evidence pack with an index and owners. Refresh it on a set cadence.

5. Mistake: No process for “customer instructions” beyond ad hoc emails.
   Avoidance: Use a ticketed workflow with approval gates and change logs.

Enforcement context and risk implications

ISO/IEC 27701 is a certifiable privacy information management extension to ISO/IEC 27001; the practical risk is failing customer audits, losing deals, or failing certification surveillance if you cannot demonstrate processor duties are controlled and evidenced ¹. Even without citing specific enforcement actions here, the operational exposure is consistent: unclear processor terms and weak subprocessor governance create incident response confusion, uncontrolled access paths, and contractual breach risk.

A practical 30/60/90-day execution plan

Days 1–30: Establish traceability and stop-the-bleeding controls

• Confirm processor services and legal entities in scope.
• Build the first version of the processor obligations register.
• Collect your standard DPA and security exhibit; document current approval flow.
• Start a subprocessor inventory for in-scope services.
• Stand up a simple evidence index (even a spreadsheet) with owners and locations.

Exit criteria: You can answer, “What are our processor obligations for Service X, and where is the evidence?”

Days 31–60: Operationalize workflows and evidence packaging

• Implement or tighten the customer instruction workflow (ticketing + approvals).
• Define subprocessor onboarding steps and minimum due diligence artifacts.
• Draft the customer assurance evidence pack; align to common questionnaires.
• Run an internal mini-audit: pick one service, walk obligations to evidence end-to-end.

Exit criteria: Evidence pack exists and the obligations register maps to controls and artifacts.

Days 61–90: Prove operation and scale across services

• Expand obligations register coverage across remaining services.
• Add monitoring reconciliations (subprocessor list vs. production integrations; support tools vs. data access).
• Run at least one incident notification tabletop and log results.
• Implement a recurring cadence to refresh evidence and review contract deviations.

Exit criteria: Repeatable operating rhythm, measurable remediation pipeline, and audit-ready outputs.

Frequently Asked Questions

Do we need to be ISO 27701 certified to implement the processor obligations requirement?

No. You can implement the controls and evidence model as an internal requirement. Certification mainly changes how formally you document and prove operation to an external auditor ¹.

We are both a controller and a processor. Do we need separate controls?

You need clear scoping and role-based procedures. Many controls overlap (access control, incident response), but contracts, customer instruction handling, and subprocessor terms must reflect your processor role for customer data ¹.

What is the single artifact that makes audits easier for processor obligations?

A processor obligations register that maps contract duties to operational controls and evidence. It prevents gaps between what Legal signs and what engineering/security can prove ¹.

How do we handle customers who demand broad audit rights?

Define a standard audit support position (e.g., questionnaires, shared assurance reports, limited onsite conditions) and route exceptions through a documented approval workflow. Track negotiated deviations and map them to evidence so you do not accept obligations you cannot meet.

What counts as “client assurance evidence” in practice?

Evidence that controls operate, not just policies. Examples include access review records, incident tabletop results, subprocessor due diligence outputs, executed agreements, and a versioned assurance pack index that shows where each artifact lives ¹.

How can Daydream help without turning this into shelfware?

Use Daydream to maintain the obligations register, link each obligation to the latest evidence, and standardize responses for customer assurance requests. The value is reduced cycle time and fewer missed gaps during contract changes or renewals.

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Footnotes

1. ISO/IEC 27701 overview