Scope and role decisions
Identify included entities, services and controller or processor responsibilities, with exclusions and dependencies explained.
Privacy governance across entities and services
ISO 27701 consulting for European organisations.
A privacy programme becomes difficult to manage when responsibility changes between entities, products and suppliers. CyberVantage360 helps turn those interfaces into an operating privacy information management system. Define the scope, establish accountable decisions and prepare evidence for an independent certification assessment.
Start with the operating decision
Define what the privacy management system will cover.
ISO identifies ISO/IEC 27701:2025 as the current independent privacy information management-system standard. Begin with the services, entities and processing roles you intend to manage.
A European group should avoid a scope that lists a headquarters but leaves responsibility for subsidiary processing unclear. Record the decisions retained centrally and the activities owned locally, including supplier interfaces and shared systems.
Europe context
Manage common processes without flattening legal differences.
The PIMS should connect legal advice with operational decisions. Use a common factual record for information use, recipients and retention, while preserving the conclusions that differ by entity or jurisdiction.
For acquisitions and shared-service changes, decide how new processing enters the system. A signed group policy will not reveal whether the acquired team uses a separate recruitment platform or maintains its own customer exports.
Agreed outputs
Create a system that can be operated and assessed.
Agree the implementation boundary and the evidence expected at each milestone.
Privacy risk and treatment records
Organise risks, selected actions, owners and management decisions around the processing in scope.
Operating controls and records
Develop practical change, supplier, request and incident workflows with evidence that teams can maintain.
Evaluation and certification preparation
Support internal evaluation, management review and closure of findings before an independent body's assessment.
Practical implementation
Follow a decision from policy to evidence.
Select a proposed new use of information and trace how it is assessed, approved, communicated and checked after implementation. Confirm that the decision reaches the product configuration and the staff who handle the information.
Agree measures that show whether the system is operating: overdue decisions, unresolved exceptions or incomplete closure evidence can be more useful than counting published policies. Choose measures that management can act on.
Illustrative operating decisions
Two European management-system boundaries.
Hypothetical examples, not client case studies or claims of completed engagements.
A group combines recruitment services
A hypothetical European group consolidates recruitment administration but leaves hiring decisions with national businesses. The PIMS scope records who controls each purpose and which shared team performs the work.
The implementation reviews access, candidate-request routing and local retention decisions. The evidence shows how central procedures accommodate approved differences rather than treating every subsidiary as identical.
A software supplier acquires another product
A hypothetical supplier buys a product with a different analytics stack and support model. Its existing privacy system does not automatically cover the acquired service.
The integration plan identifies new processing, suppliers and accountable owners. Management can then approve a bounded scope extension supported by operating evidence rather than simply adding a product name to the policy.
Our service commitment
100% successful ISO certification guaranteed.
Our guarantee applies to the agreed ISO certification engagement. Confirm its scope and terms in your proposal. The independent certification body conducts the audit and makes the certification decision.
Confirm the assessment scope, current edition and certification-body arrangements before committing to a date. Certification of the PIMS does not decide every GDPR or national-law question; those decisions remain separately documented.
Before you commission the work
Questions before a European PIMS programme.
Is ISO 27001 certification a universal prerequisite?
No. The 2025 edition is independent; existing security governance may still be useful.
Does ISO 27701 certify GDPR compliance?
It assesses the management system within its scope. It does not replace a legal assessment or guarantee regulatory conformity.
Can several entities share one system?
They can use common processes, but the scope, authority and local responsibilities must be clear and workable.
Can an existing 2019 programme be reused?
Assess its current evidence against the agreed edition and certification route. Confirm transition arrangements with the certification body rather than assuming a universal deadline.
Who makes the certification decision?
The independent certification body. Consulting prepares and supports implementation without taking over that decision.
What should we bring to the first discussion?
The proposed entities and services, current privacy and security arrangements, major suppliers and the reason for seeking certification.
Reference basis
Sources and scope of this guidance
ISO: ISO/IEC 27701:2025 overview; ISO: independent certification.
Official references checked 13 October 2026. The implementation examples are practical recommendations; legal applicability and the agreed certification scope need their own review.
Plan the engagement
Define the system before setting the audit date.
Share the organisational boundary and the decisions your privacy programme needs to control. We can scope implementation and certification preparation around that operating model.