ISO 27701 Becomes a Standalone Standard — How CBPR and PRP Fill the Gaps
Leah Smyle, Privacy Compliance Coordinator, BBB National Programs
In October 2025, the International Organization for Standardization (ISO) released a key update to ISO 27701, transforming it into a standalone Privacy Information Management System (PIMS) standard. Previously, organizations were required to hold ISO 27001 certification for information security before pursuing ISO 27701. With this change, that prerequisite is gone.
This update marks a turning point in global privacy management. Privacy is no longer being recognized as just a subset of cybersecurity but as a discipline in its own right. For privacy and security professionals, this shift raises important questions about how ISO 27701’s new independence will impact the credibility and maturity of privacy programs.
The update may lower the barrier for more organizations to pursue ISO 27701 certification, but there are new challenges. While the standard helps establish strong internal privacy management systems, certification alone does not guarantee a complete or compliant privacy program. As highlighted by the International Association of Privacy Professionals (IAPP), ISO 27701 certification is a meaningful milestone—but it leaves gaps in areas such as cross-border data transfers, vendor accountability, and external verification.
To achieve a globally trusted, accountable privacy posture, organizations may look to complementary frameworks such as the Global Cross-Border Privacy Rules (CBPR) and Privacy Recognition for Processors (PRP) to fill critical operational and verification gaps.
Key benefits:
The Tradeoff
Without the information security foundation that ISO 27001 provides, organizations may overlook key elements of risk management, governance, and vendor oversight. Certification offers structure—but not necessarily operational accountability or interoperability across jurisdictions. A standalone Privacy Information Management System still depends on the strength of the organization’s security posture.
In short, ISO 27701 defines what to build; it does not ensure that the program operates with sustained trust and transparency, nor does it ensure that eligible organizations are held accountable.
The Global CBPR System:
The PRP Program:
Together, CBPR and PRP provide the external validation that ISO 27701 lacks. An organization certified under ISO 27701 can leverage CBPR and PRP to extend that credibility across borders, partners, and vendors—transforming certification from a static milestone into a dynamic, interoperable trust model.
The latest update to ISO 27701 marks an important moment for privacy management, emphasizing privacy as a distinct and equal discipline within the risk landscape. But certification is only the beginning. True privacy maturity requires continuous accountability, transparency, cross-border interoperability, and stronger partnerships.
By pairing ISO 27701 with the Global CBPR and PRP frameworks, organizations can move beyond compliance to build globally trusted privacy ecosystems—systems that not only comply with the law but also earn stakeholder confidence through measurable accountability.
Learn more about BBB National Programs’ Global CBPR Certification and PRP Certification to see how these frameworks can enhance your ISO 27701-based privacy strategy: bridging governance, cybersecurity, and global accountability.
In October 2025, the International Organization for Standardization (ISO) released a key update to ISO 27701, transforming it into a standalone Privacy Information Management System (PIMS) standard. Previously, organizations were required to hold ISO 27001 certification for information security before pursuing ISO 27701. With this change, that prerequisite is gone.
This update marks a turning point in global privacy management. Privacy is no longer being recognized as just a subset of cybersecurity but as a discipline in its own right. For privacy and security professionals, this shift raises important questions about how ISO 27701’s new independence will impact the credibility and maturity of privacy programs.
The update may lower the barrier for more organizations to pursue ISO 27701 certification, but there are new challenges. While the standard helps establish strong internal privacy management systems, certification alone does not guarantee a complete or compliant privacy program. As highlighted by the International Association of Privacy Professionals (IAPP), ISO 27701 certification is a meaningful milestone—but it leaves gaps in areas such as cross-border data transfers, vendor accountability, and external verification.
To achieve a globally trusted, accountable privacy posture, organizations may look to complementary frameworks such as the Global Cross-Border Privacy Rules (CBPR) and Privacy Recognition for Processors (PRP) to fill critical operational and verification gaps.
What ISO 27701’s Independence Signifies
By separating ISO 27701 from ISO 27001, ISO has formally acknowledged that privacy risk requires its own management system. This transcends administrative change and is an intentional shift toward treating privacy as a strategic, enterprise-level discipline and not just an extension of security controls.Key benefits:
- Accessibility: Organizations without an existing information security management system can pursue privacy certification without having to build a foundation through ISO 27001.
- Recognition: The update affirms that privacy governance is truly a global area of professional practice.
- Structure: The update also provides a clear framework for building and maintaining a Privacy Information Management System.
The Tradeoff
Without the information security foundation that ISO 27001 provides, organizations may overlook key elements of risk management, governance, and vendor oversight. Certification offers structure—but not necessarily operational accountability or interoperability across jurisdictions. A standalone Privacy Information Management System still depends on the strength of the organization’s security posture.
Where the ISO 27701 Certification Could Fall Short
Even with ISO 27701 certification, organizations may not achieve complete privacy maturity. Common gaps include:- Cross-Border Data Transfers: ISO 27701 certification focuses on internal processes but does not address mechanisms for lawful international data flows. This is an area increasingly scrutinized under frameworks such as GDPR and Global APEC as a result of the complexities of cross-border data flows, where multiple jurisdictions and regulatory frameworks overlap.
- Vendor and Processor Oversight: While ISO 27701 distinguishes between data controllers and processors, it does not provide a mechanism for verifying third-party compliance or managing sub-processors at scale.
- Independent Accountability: Certification confirms that policies and controls are in place but does not verify that they are consistently applied or externally validated over time. Ongoing third-party accountability mechanisms—such as independent dispute resolution and monitoring—help close that gap.
- Consumer Transparency: ISO 27701 provides a strong internal governance framework but offers limited guidance on how to communicate privacy practices in clear, trusted ways to consumers and stakeholders.
In short, ISO 27701 defines what to build; it does not ensure that the program operates with sustained trust and transparency, nor does it ensure that eligible organizations are held accountable.
How CBPR and PRP Strengthen Privacy Programs
The Global CBPR and PRP frameworks were designed to strengthen interoperability, ongoing verification, and accountability.The Global CBPR System:
- Provides a recognized mechanism for managing cross-border data flows in compliance with global privacy principles.
- Establishes independent verification and dispute resolution processes that reinforce accountability.
- Demonstrates to partners, consumers, and regulators that an organization meets internationally recognized standards for privacy protection.
The PRP Program:
- Tailored for data processors, this certification helps service providers and vendors demonstrate their adherence to strong privacy and security practices.
- Supply-chain accountability is strengthened by allowing organizations to verify trust throughout their data ecosystem.
- Complements ISO 27701 by providing continuous third-party review and recognition.
Together, CBPR and PRP provide the external validation that ISO 27701 lacks. An organization certified under ISO 27701 can leverage CBPR and PRP to extend that credibility across borders, partners, and vendors—transforming certification from a static milestone into a dynamic, interoperable trust model.
The latest update to ISO 27701 marks an important moment for privacy management, emphasizing privacy as a distinct and equal discipline within the risk landscape. But certification is only the beginning. True privacy maturity requires continuous accountability, transparency, cross-border interoperability, and stronger partnerships.
By pairing ISO 27701 with the Global CBPR and PRP frameworks, organizations can move beyond compliance to build globally trusted privacy ecosystems—systems that not only comply with the law but also earn stakeholder confidence through measurable accountability.
Learn more about BBB National Programs’ Global CBPR Certification and PRP Certification to see how these frameworks can enhance your ISO 27701-based privacy strategy: bridging governance, cybersecurity, and global accountability.