Get ISO/IEC 27018 Cloud Privacy Controls in Place
ISO/IEC 27018 is a code of practice for protecting personally identifiable information (PII) in public cloud services when you act as a PII processor. It translates privacy principles into practical cloud controls and customer commitments.
Neutral Partners helps you scope what is in and out, align ISO/IEC 27018 to your ISO/IEC 27001 program, and build the evidence auditors and customers expect.
At a Glance
- Best for: SaaS and cloud service providers that process customer PII in a public cloud environment
- Works with: ISO/IEC 27001 and ISO/IEC 27002 controls, plus privacy programs and contracts
- Outcome: Auditable cloud privacy controls and customer facing commitments you can prove with evidence
- Common failure point: Policies and contract language exist, but teams cannot demonstrate how privacy controls operate day to day
If you need a plan you can execute, start with a short working session.
Schedule a Discovery SessionWhat Is ISO/IEC 27018
ISO/IEC 27018 provides privacy controls for public cloud services that process PII on behalf of customers. It focuses on transparency, limits on processing, secure handling, and clear responsibilities between the cloud provider and the customer.
In practice, ISO/IEC 27018 is less about writing new policy and more about proving how your cloud service prevents unauthorized access, enforces approved processing, and supports customer obligations like deletion and access requests.
How ISO/IEC 27018 Fits with ISO/IEC 27001
Most organizations implement ISO/IEC 27018 as a privacy layer on top of an ISO/IEC 27001 based information security management system. This keeps security and privacy controls aligned and reduces duplicate work.
What ISO/IEC 27018 Adds
- Cloud privacy commitments: Customer transparency, limits on use, and subprocessor control
- PII processor focus: Controls tailored to service providers handling customer PII
- Operational proof: Evidence that privacy controls are enforced in real workflows
What You Reuse from ISO/IEC 27001
- Risk and governance: Scope, roles, risk treatment, internal audit, management review
- Security controls: Access control, logging, cryptography, change management
- Continuous improvement: Corrective actions and monitoring cadence
Who Needs ISO/IEC 27018
ISO/IEC 27018 is most relevant when your organization processes personal data for customers in a public cloud context and needs to prove privacy controls to buyers, regulators, or auditors.
- Cloud service providers: Public cloud, hosting, managed services, and platform operators
- SaaS providers: Applications processing end user or customer employee data
- Data processors: Vendors that handle PII under contract and must show control effectiveness
- Enterprise platforms: Internal shared services that operate like a cloud provider to business units
What ISO/IEC 27018 Covers
ISO/IEC 27018 focuses on privacy control objectives for PII processing in public cloud services. Auditors will look for controls that are consistently implemented across systems, people, and vendor relationships.
- Processing limits: Purpose limitation, approved processing, and customer instruction handling
- Transparency: Clear customer disclosures and support for customer privacy obligations
- Subprocessor controls: Due diligence, contracts, and oversight for downstream providers
- Access safeguards: Least privilege, privileged access management, and access review evidence
- Secure handling: Encryption, segregation, secure deletion, and retention enforcement
- Incident readiness: Notification workflows and tested response playbooks
Evidence Auditors Expect
ISO/IEC 27018 audits move faster when evidence is organized, traceable, and tied to how the service actually operates.
- Governance: Scope statement, roles, privacy policy, risk decisions, and vendor inventory
- Customer commitments: Contract clauses, subprocessor list, and transparency materials
- Operational proof: Access reviews, incident drills, deletion workflows, and ticket records
- Technical artifacts: Configuration exports, logging samples, encryption settings, and access controls
Rule of thumb: If you cannot prove it with repeatable evidence, assume the audit will treat it as not implemented.
ISO/IEC 27018 Roadmap
ISO/IEC 27018 succeeds when you treat it like an operating model and evidence program, not a documentation sprint.
Define Scope and PII Processing Roles
Document what cloud services are in scope, where PII flows, and which parties act as controller and processor. Inventory subprocessors and regions.
Map Controls to Your ISMS
Align ISO/IEC 27018 control objectives to your existing ISO/IEC 27001 and ISO/IEC 27002 controls. Identify gaps, owners, and required evidence.
Implement and Operationalize Privacy Controls
Update procedures and technical configurations. Validate access controls, logging, encryption, retention, and deletion across production systems.
Build an Evidence Library
Create repeatable evidence packets for high impact controls. Standardize screenshots, exports, reports, and tickets so evidence is consistent every audit cycle.
Validate and Support Certification
Run an internal audit style check, fix gaps, and prepare staff for interviews. Support your certification body through audit planning and evidence requests.
Make Cloud Privacy a Trust Signal
Buyers want proof that privacy controls are built into how your cloud service runs. We help you scope, implement, and validate ISO/IEC 27018 controls with evidence that holds up.
Book Your Discovery CallCommon ISO/IEC 27018 Gaps
- Unclear processor scope: Services and regions are not clearly defined, so audit scope drifts.
- Subprocessor blind spots: No consistent oversight, contracts, or inventory for vendors handling PII.
- Deletion not provable: Teams say data is deleted, but lack system level evidence and logs.
- Overbroad access: Privileged access is not restricted or reviewed with consistent cadence.
- Weak transparency: Customer facing disclosures are incomplete or not kept current.
- Evidence drift: Screenshots and exports are one off and not repeatable across audit cycles.
How Neutral Partners Helps
We help you integrate ISO/IEC 27018 into how the cloud service operates, then build evidence that proves it.
What We Deliver
- Scope and role clarity: Processor responsibilities, subprocessors, and in scope services
- Control mapping: ISO/IEC 27018 to ISO/IEC 27001 and ISO/IEC 27002, with owners and due dates
- Procedure updates: Deletion, access requests support, incident handling, and transparency processes
- Evidence library: A repeatable audit binder for high impact privacy controls
- Audit support: Pre audit readiness, interview prep, and evidence request management
Since 2017, we have maintained a 100% audit success rate across more than 700 successful audits and assessments.
ISO/IEC 27018 FAQs
Is ISO/IEC 27018 a certification?
ISO/IEC 27018 is a code of practice. Many certification bodies audit it as an add on to ISO/IEC 27001 when you provide public cloud services and process customer PII.
Do we need ISO/IEC 27001 first?
In most programs, yes. ISO/IEC 27018 aligns to ISO/IEC 27002 style controls and is commonly assessed within an ISO/IEC 27001 management system scope.
Does ISO/IEC 27018 apply to private cloud or on prem?
The standard is written for public cloud PII processors. The control objectives still translate well if you operate shared services or private cloud environments, but auditors will frame scope accordingly.
What is the biggest cost driver?
Scope and evidence. The number of services, regions, and subprocessors determines how much control testing and proof you need to maintain.
How long does an ISO/IEC 27018 readiness effort take?
Timelines vary based on maturity. Many teams can reach audit readiness in 8 to 16 weeks when scope is tight and evidence collection is planned early.