ISO 27002:2022, Control 5.34 – Privacy and Protection of PII

ISO 27002:2022 Revised Controls

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Personally Identifiable Information (PII) is any piece of information that confirms an individual’s identity.

A person’s PII can include their:

  • Address
  • National Insurance Number or Social Security Number
  • Driver’s licence
  • Financial information, including bank accounts
  • Medical records

PII forms a key part of an organisation’s data governance strategy, and carries a number of unique regulatory, legislative and contractual risks.

Control 5.34 deals with PII in three distinct ways:

  1. Preservation
  2. Privacy
  3. Protection

Purpose of Control 5.34

Control 5.34 is a preventive control that maintains risk by creating guidelines and procedures that fulfil an organisation’s legal, statutory, regulatory and contractual requirements relating to the storage, privacy and protection of PII in all its forms.

Attributes Table

Control TypeInformation Security PropertiesCybersecurity ConceptsOperational CapabilitiesSecurity Domains
#Preventive#Confidentiality
#Integrity
#Availability
#Identify
#Protect
#Information Protection
#Legal and Compliance
#Protection

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Ownership of Control 5.34

Control 5.34 explicitly names an organisation’s delegated Privacy Officer (or organisational equivalent) as the person who should oversee PII adherence.

General Guidance on Control 5.34

Organisations should treat PII as a topic-specific business function, and develop policies that are unique to their organisation, and the categories of PII that are most common to their day-to-day operation.

First and foremost, the organisation should draft, develop and implement a series of policies that cater to the preservation, privacy and protection of PII, and ensure these are communicated to and used by all employees that process PII – not just those who are obligated to deal with it as part of their job roles.

PII needs to be managed in a structured, clear and concise manner. To achieve this, Control 5.34 asks organisations to draft policies that consider individual roles, responsibilities and data controls throughout their organisation.

The easiest and most efficient way to achieve this is to adopt a top-down approach that features a Privacy Officer, whose job it is to provide guidance to employees and third-party organisations on the subject of PII, and offer advice to senior management on how to remain compliant with the organisation’s obligations.

Alongside regulatory, legislative and contractual guidelines, an organisation should also implement technical and operational measures that deal with the practical handling of PII as it’s stored by and flows through the business.

It helps drive our behaviour in a positive way that works for us
& our culture.

Emmie Cooney
Operations Manager, Amigo

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Supplementary Guidance

PII legislation varies from country-to-country, even within territories that contain devolved administrations or non-federal governments.

Organisations should audit their PII processing requirements and consider any cross-border implications emanating from the collection, processing or distribution of PII within separate jurisdictions.

Whilst ISO 27002:2022 doesn’t offer any additional guidance on how to achieve this, a number of ISO documents go into greater detail on the matter, including:

Changes and Differences from ISO 27002:2013

27002:2022-5.34 replaces 27002:2013-18.1.4 (Privacy and protection of personally identifiable information).

27002:2022-5.34 is almost a carbon copy of its 2013 predecessor, with two notable exceptions.

  1. 27002:2022-5.34 asks organisations to consider a topic-specific policy when formulating and implementing PII policies and procedures.
  2. 27002:2022-5.34 places more of an emphasis on the preservation of PII (as noted in the control title), alongside standard privacy and protection guidelines.

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New Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
5.7NewThreat intelligence
5.23NewInformation security for use of cloud services
5.30NewICT readiness for business continuity
7.4NewPhysical security monitoring
8.9NewConfiguration management
8.10NewInformation deletion
8.11NewData masking
8.12NewData leakage prevention
8.16NewMonitoring activities
8.23NewWeb filtering
8.28NewSecure coding

Organisational Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
5.105.1.1, 05.1.2Policies for information security
5.206.1.1Information security roles and responsibilities
5.306.1.2Segregation of duties
5.407.2.1Management responsibilities
5.506.1.3Contact with authorities
5.606.1.4Contact with special interest groups
5.7NewThreat intelligence
5.806.1.5, 14.1.1Information security in project management
5.908.1.1, 08.1.2Inventory of information and other associated assets
5.1008.1.3, 08.2.3Acceptable use of information and other associated assets
5.1108.1.4Return of assets
5.12 08.2.1Classification of information
5.1308.2.2Labelling of information
5.1413.2.1, 13.2.2, 13.2.3Information transfer
5.1509.1.1, 09.1.2Access control
5.1609.2.1Identity management
5.17 09.2.4, 09.3.1, 09.4.3Authentication information
5.1809.2.2, 09.2.5, 09.2.6Access rights
5.1915.1.1Information security in supplier relationships
5.2015.1.2Addressing information security within supplier agreements
5.2115.1.3Managing information security in the ICT supply chain
5.2215.2.1, 15.2.2Monitoring, review and change management of supplier services
5.23NewInformation security for use of cloud services
5.2416.1.1Information security incident management planning and preparation
5.2516.1.4Assessment and decision on information security events
5.2616.1.5Response to information security incidents
5.2716.1.6Learning from information security incidents
5.2816.1.7Collection of evidence
5.2917.1.1, 17.1.2, 17.1.3Information security during disruption
5.30NewICT readiness for business continuity
5.3118.1.1, 18.1.5Legal, statutory, regulatory and contractual requirements
5.3218.1.2Intellectual property rights
5.3318.1.3Protection of records
5.3418.1.4Privacy and protection of PII
5.3518.2.1Independent review of information security
5.3618.2.2, 18.2.3Compliance with policies, rules and standards for information security
5.3712.1.1Documented operating procedures

People Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
6.107.1.1Screening
6.207.1.2Terms and conditions of employment
6.307.2.2Information security awareness, education and training
6.407.2.3Disciplinary process
6.507.3.1Responsibilities after termination or change of employment
6.613.2.4Confidentiality or non-disclosure agreements
6.706.2.2Remote working
6.816.1.2, 16.1.3Information security event reporting

Physical Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
7.111.1.1Physical security perimeters
7.211.1.2, 11.1.6Physical entry
7.311.1.3Securing offices, rooms and facilities
7.4NewPhysical security monitoring
7.511.1.4Protecting against physical and environmental threats
7.611.1.5Working in secure areas
7.711.2.9Clear desk and clear screen
7.811.2.1Equipment siting and protection
7.911.2.6Security of assets off-premises
7.1008.3.1, 08.3.2, 08.3.3, 11.2.5Storage media
7.1111.2.2Supporting utilities
7.1211.2.3Cabling security
7.1311.2.4Equipment maintenance
7.1411.2.7Secure disposal or re-use of equipment

Technological Controls

ISO/IEC 27002:2022 Control IdentifierISO/IEC 27002:2013 Control IdentifierControl Name
8.106.2.1, 11.2.8User endpoint devices
8.209.2.3Privileged access rights
8.309.4.1Information access restriction
8.409.4.5Access to source code
8.509.4.2Secure authentication
8.612.1.3Capacity management
8.712.2.1Protection against malware
8.812.6.1, 18.2.3Management of technical vulnerabilities
8.9NewConfiguration management
8.10NewInformation deletion
8.11NewData masking
8.12NewData leakage prevention
8.1312.3.1Information backup
8.1417.2.1Redundancy of information processing facilities
8.1512.4.1, 12.4.2, 12.4.3Logging
8.16NewMonitoring activities
8.1712.4.4Clock synchronization
8.1809.4.4Use of privileged utility programs
8.1912.5.1, 12.6.2Installation of software on operational systems
8.2013.1.1Networks security
8.2113.1.2Security of network services
8.2213.1.3Segregation of networks
8.23NewWeb filtering
8.2410.1.1, 10.1.2Use of cryptography
8.2514.2.1Secure development life cycle
8.2614.1.2, 14.1.3Application security requirements
8.2714.2.5Secure system architecture and engineering principles
8.28NewSecure coding
8.2914.2.8, 14.2.9Security testing in development and acceptance
8.3014.2.7Outsourced development
8.3112.1.4, 14.2.6Separation of development, test and production environments
8.3212.1.2, 14.2.2, 14.2.3, 14.2.4Change management
8.3314.3.1Test information
8.3412.7.1Protection of information systems during audit testing
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