ISO 27001 != GDPR compliance

alt text

ISO 27001 is not sufficient for full GDPR compliance because it focuses on information security management (the CIA triad) rather than the legal, data privacy rights mandated by GDPR. While ISO 27001 provides a robust framework for technical safeguards and risk management, it lacks GDPR-specific requirements like consent management, data subject access requests (DSARs), and strict legal bases for processing.

Key Differences and Missing Components

Data Rights: ISO 27001 does not cover the “right to be forgotten” (erasure), data portability, or the right to object to processing.
Legal Basis & Transparency: GDPR requires a documented legal basis (e.g., consent or legitimate interest) for processing, which is not a core component of ISO 27001.
Data Protection Officer (DPO): GDPR mandates a DPO for certain organizations, while ISO 27001 does not specifically require one.
DPIA Requirement: Data Protection Impact Assessments (DPIAs) are explicitly required under GDPR, which are broader than ISO 27001 risk assessments.
Breach Notification: ISO 27001 focuses on notifying authorities, while GDPR demands strict reporting timelines to both authorities and affected individuals.

How They Work Together

Although not identical, ISO 27001 is a strong foundation for GDPR compliance. It covers technical security requirements (like encryption and access control) that align with Article 32 of the GDPR regarding the security of processing.

Recommendation

To achieve full compliance, organizations should implement ISO 27001 as a foundation and supplement it with a tailored GDPR privacy framework—such as ISO 27701—to address legal and rights-based requirements.

© dbj@dbj.org , CC BY SA 4.0