ISO/IEC 27018
Audit by an
Independent Audit Firm
CertPro conducts ISO 27018 audits for the protection of Personally Identifiable Information in public cloud environments, in accordance with ISO/IEC 27018:2019. Our assessment evaluates documented controls and supporting evidence across PII processing, data handling, transparency obligations, and privacy safeguards. Certification is issued by an independent certification body upon successful completion of the audit.
A Code of Practice for Protecting PII in Public Cloud Environments
ISO/IEC 27018:2019 is a code of practice for protecting Personally Identifiable Information (PII) in public cloud environments. It applies to cloud service providers acting as PII processors on behalf of controllers. Certification confirms that privacy controls are independently assessed and aligned with ISO 27018 requirements. ISO/IEC 27018 is structured through Clauses 5–18 and Annex A controls, which define specific requirements for protecting PII in public cloud environments.
ISO 27018 extends ISO 27002 with privacy-specific controls for cloud PII processing. Compliance demonstrates that providers apply documented and verifiable safeguards across data handling, transparency, access control, and incident response. CertPro conducts ISO 27018 audits against these requirements.
Clauses 5–6: PIMS Requirements (Controllers & Processors)
Establishes requirements and guidance for a Privacy Information Management System covering accountability, governance, and privacy controls for PII processing.
Transparency and Disclosure
Providers should disclose PII processing practices, including data handling, subprocessors, and relevant processing changes.
Access Controls and Confidentiality
Access to PII should be restricted to authorized personnel. Controls should include provisioning, segregation of duties, and confidentiality obligations.
Privacy Incident Management
Procedures should exist for detecting, responding to, and notifying controllers of privacy incidents. Evidence of incident response execution is assessed.
Subprocessor & Data Transfer Controls
Third-party processing arrangements should be supported by documented agreements, due diligence, and flow-down obligations. Data transfers should be governed by documented controls consistent with applicable requirements.
Control Design and Effectiveness Assessment
Auditors evaluate whether privacy controls are defined in line with ISO/IEC 27018 Clauses 5–18 and Annex A. This includes policies, procedures, and PII processing governance.
Control Design and Documentation Assessment
Auditors evaluate whether privacy controls are defined in line with ISO/IEC 27018 Clauses 5–18 and Annex A. This includes policies, procedures, and PII processing governance.
Control Effectiveness and Operational Testing
Auditors verify that controls operate consistently across the cloud environment using objective evidence and audit testing methods.
A Structured ISO 27018 Audit in Four Phases
Every CertPro ISO/IEC 27018 audit follows a structured four-phase process aligned with the requirements of ISO/IEC 27018:2019 and audit principles defined in ISO 19011.
Kick-off and Audit Scoping
The engagement begins with confirming the scope of PII processing and the cloud environment. Applicable ISO 27018 controls, system boundaries, and timelines are defined. A primary point of contact is assigned.
Evidence Access and Control Review
The client provides access to PII processing records, data handling policies, consent documentation, and subprocessor agreements. Auditors review documented controls to assess alignment with ISO 27018 requirements and identify gaps in control design.
Gap Clarification and Control Testing
Controls are evaluated in operation across the defined scope. Auditors test controls using interview, observation, document and records review. Evidence such as logs, incident records, and data handling activities is reviewed. Nonconformities are documented with severity and management response.
Report Issuance
The audit report is compiled and independently reviewed. It is shared with the client for factual validation. Certification decisions are made by the independent certification body after review of the audit results and closure of applicable nonconformities.
Audit Readiness
Gaps in the below areas are commonly identified during ISO/IEC 27018 audit engagements.
PII Processing Inventory & Scope Documentation
A documented inventory of PII processing activities should cover PII categories, processing purposes, retention periods, data flows, and third-party recipients. The inventory should reflect actual operations across the cloud environment. Incomplete or outdated records are commonly identified during scope and documentation review.
Consent Management & Purpose Limitation Records
Organizations should demonstrate that PII is processed only for approved purposes defined by the controller. This includes documented purpose limitation controls and evidence that the controls are consistently applied. Both documentation and operational records are reviewed across the audit.
Access Control & Confidentiality Documentation
Access to PII should follow defined controls, including provisioning and deprovisioning procedures, MFA enforcement, and least-privilege access. Personnel handling PII should be bound by confidentiality obligations. The control testing phase focuses on verifying that these controls operate consistently across systems and users.
Privacy Incident Response Procedures and Records
A documented incident response process should cover detection, assessment, notification, and corrective action. Auditors review incident logs, breach notifications, and evidence of testing and communication. Missing or incomplete records are treated as audit findings.
Subprocessor Agreements & Third-Party Controls
Where PII processing involves third parties, agreements should define privacy obligations. Due diligence records and data transfer mechanisms should also be documented. Gaps such as missing agreements or outdated records are commonly identified during audit review.
Readiness Score
Based on a review across ISO/IEC 27018:2019 control domains for PII protection in public cloud environments. Three areas require additional evidence prior to audit commencement.
Independent ISO 27018 Audit. Evidence-Based Methodology.
These principles govern how CertPro conducts every ISO 27018 certification audit engagement, from scoping through final report issuance. These commitments are structural, documented in every audit file, and governed by the requirements of ISO 19011 and ISO/IEC 27018:2019 at every stage.
Audit Independence and Impartiality
CertPro does not provide implementation, remediation, or advisory services to organizations it audits. A pre-engagement impartiality check is documented for every engagement. Audit conclusions are based only on objective evidence reviewed during the current audit, in line with ISO 19011 independence requirements.
Evidence-Based PII Control Assessment
All conclusions are supported by objective evidence. Controls are tested through interview, observation, document, and record review. Auditors verify a risk-based sample using logs, processing records, and system data. Assessment focuses on how controls operate in practice — not merely in documentation.
Conducted Under Standard Guidelines
Every ISO 27018 audit follows ISO/IEC 27018:2019 requirements and ISO 19011 guidelines. Our audits use a structured, evidence-based approach aligned with ISO/IEC 27018 controls and certification requirements. Certification is issued by an independent certification body upon successful completion.
Credentialed Audit Team
Each engagement is led by a qualified ISO Lead Auditor with expertise in privacy and cloud controls. The team includes CISA-certified auditors and sector specialists across technology, healthcare, and financial services. CertPro brings over 12+ years of audit experience across 25+ countries.
Structured Communication Throughout
Findings are communicated clearly at every stage. Nonconformities include control reference, severity, evidence, and required action. Clients track progress in real time through Asana, with updates at each milestone. No findings are held for the final report.
Globally Trusted
CertPro ISO 27018 assessments signal trusted protection of personal data in cloud environments. Audit-aligned methodology supports consistent acceptance of our reports by enterprise customers globally.
ISO 27018 Certification: Frequently Asked Questions
ISO/IEC 27018:2019 is a code of practice for protecting Personally Identifiable Information (PII) in public cloud environments. It applies to cloud service providers acting as PII processors on behalf of controllers. ISO 27018 extends ISO 27002 with privacy-specific controls covering data handling, transparency, access control, consent management, and incident response. Certification confirms that these controls have been independently assessed against the standard's requirements. It is relevant for SaaS providers, cloud infrastructure companies, managed service providers, and any organization processing customer or client PII in a public cloud environment.
ISO 27018 extends ISO 27002 with privacy-specific controls for PII protection in cloud environments. It complements ISO 27001 but does not require it as a prerequisite. Organizations with ISO 27001 already have a structured control framework, which supports ISO 27018 implementation. Many providers pursue both to cover security and privacy in a unified audit scope.
A CertPro ISO/IEC 27018 audit evaluates PII privacy controls against the requirements defined in Clauses 5–18 and Annex A. This includes processing scope, purpose limitation, data minimization, access controls, transparency practices, incident response, and third-party management. All conclusions are based on objective evidence obtained through documentation review, interview, observation, and testing.
ISO/IEC 27018 requirements are defined through Clauses 5–18 and Annex A controls, which specify how PII must be protected in public cloud environments. An audit evaluates whether these controls are properly designed, documented, and implemented. This includes PII processing governance, purpose limitation, transparency obligations, access control, incident response, and third-party processing arrangements. Certification decisions are based on conformity to these defined requirements and supporting objective evidence.
Follow-up activities, including periodic reassessment where applicable, are defined by the independent certification body and the specific certification scheme in scope. ISO/IEC 27018 does not prescribe a fixed surveillance or recertification cycle.
ISO/IEC 27018 supports documented governance, transparency, accountability, and control evidence for PII processing in public cloud services. It does not replace legal review or regulatory obligations, but it provides an audit framework for evaluating related controls.
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