ISO 27018 Compliance Checklist

A comprehensive pre-certification checklist to verify your readiness for ISO 27018 audit and ongoing compliance.

HOW TO USE THIS CHECKLIST

Rating System:

✓ = Fully Implemented
◐ = Partially Implemented
✗ = Not Implemented
N/A = Not Applicable

Complete Score: _____ / Total Applicable

Target: 95%+ for certification readiness

SECTION 1: GOVERNANCE & MANAGEMENT

Leadership and Commitment

Executive sponsorship secured
Privacy Officer / DPO appointed
Roles and responsibilities defined
Resources allocated
Privacy objectives established
Regular management reviews conducted (quarterly)

Policies

Privacy Policy published and accessible
Information Security Policy approved
Data Protection Policy documented
All policies reviewed annually
All policies signed by management
All policies communicated to staff

Scope Definition

Certification scope clearly defined
Services in scope identified
Data types in scope documented
Geographic locations specified
Exclusions justified

Section 1 Score: _____ / _____

SECTION 2: DATA PROCESSING

Data Processing Register (ROPA)

Complete register of processing activities
Processing purposes documented
Legal basis identified for each purpose
PII categories listed
Data subjects identified
Recipients/sub-processors listed
Retention periods specified
Cross-border transfers documented
Security measures described
Register updated quarterly

Purpose Legitimacy

All processing purposes documented
Purposes specific and granular
Purposes communicated to data subjects
No processing beyond stated purposes
Purpose review conducted annually

Data Minimization

Only necessary PII collected
Anonymization used where possible
Pseudonymization implemented
Data masking in non-production
Storage minimization practices
Regular review of collection forms

Section 2 Score: _____ / _____

SECTION 3: CONSENT & CHOICE

Consent Management

Consent management system implemented
Explicit consent for marketing
Consent freely given (not coerced)
Consent specific to purpose
Consent granular (not bundled)
Consent records maintained with timestamps
Easy withdrawal mechanism
Withdrawal processed immediately

Marketing Controls

No marketing without explicit consent
Pre-checked boxes eliminated
Easy opt-out in all communications
Marketing list sources documented
Consent verification before campaigns

Section 3 Score: _____ / _____

SECTION 4: DATA SUBJECT RIGHTS

Rights Implementation

Access request process (DSAR)
Correction/rectification process
Deletion process (right to be forgotten)
Data portability process
Objection process
Restriction of processing
Complaint handling

Response Timeframes

30-day response SLA defined
SLA monitoring in place
Tracking system for requests
Escalation procedures
Request records maintained (3 years)

Request Verification

Identity verification process
Fraud prevention measures
Security balance with accessibility

Section 4 Score: _____ / _____

SECTION 5: ENCRYPTION & SECURITY

Encryption at Rest

AES-256 (or stronger) for all PII
Database encryption enabled (TDE)
File system encryption
Application-level encryption
Cloud storage encryption
Backup encryption
Encryption verified and tested

Encryption in Transit

TLS 1.3 (minimum 1.2) enforced
Strong cipher suites only
Valid certificates from trusted CAs
Perfect Forward Secrecy enabled
HSTS configured
Internal mTLS for services
Database connections encrypted

Key Management

HSM or KMS for key storage
Automated key rotation (annual minimum)
Key access logging
Key backup and recovery procedures
Cryptographic erasure capability
Separation of duties

Section 5 Score: _____ / _____

SECTION 6: ACCESS CONTROL

Authentication

MFA required for PII access
Strong password policy enforced
Password complexity requirements
Account lockout after failed attempts
Session timeout configured (30 min max)
Re-authentication for sensitive operations

Authorization

Role-based access control (RBAC)
Least privilege principle
Need-to-know access only
Field-level access control
Database row-level security
Separation of duties

Access Monitoring

All PII access logged
Real-time anomaly detection
Failed access monitoring
Privileged access monitoring
Access logs retained (12 months minimum)
Quarterly access reviews

Section 6 Score: _____ / _____

SECTION 7: DATA RETENTION & DELETION

Retention Management

Retention schedule documented
Business justification for each period
Legal requirements identified
Retention policy published
Automated deletion implemented
Legal hold process defined

Deletion Procedures

Soft delete with grace period
Hard delete (permanent removal)
Cryptographic erasure option
All storage locations included
Backup purge procedures
Deletion verification process
Deletion certificates generated

Deletion Scope

Primary database deletion
Replica deletion
Backup deletion/marking
Cache clearing
Search index deletion
Sub-processor deletion requests

Section 7 Score: _____ / _____

SECTION 8: SUB-PROCESSORS

Sub-processor Management

Public sub-processor registry
Registry kept current
30-day advance notification process
Customer objection process
DPAs with all sub-processors
Equivalent protection verified
Sub-processor security assessments

Monitoring

Annual sub-processor audits
Certification tracking
Incident notification process
Performance monitoring
Regular reviews
Removal procedures documented

Section 8 Score: _____ / _____

SECTION 9: CROSS-BORDER TRANSFERS

Transfer Documentation

All transfers identified and documented
Transfer Impact Assessments conducted
Appropriate transfer mechanisms (SCCs, BCRs)
Customer notification and approval
Transfer register maintained
Annual transfer review

Transfer Controls

Data location transparency
Encryption for all transfers
Transfer monitoring
Incident response for transfers
Transfer-specific DPAs

Section 9 Score: _____ / _____

SECTION 10: INCIDENT RESPONSE

Preparedness

Incident response plan documented
Incident response team defined
24/7 response capability
Classification procedures
Escalation procedures
Communication templates

Breach Notification

Customer notification process (24 hours)
Regulatory notification procedures
Breach assessment procedures
Notification templates
Breach tracking system

Testing

Annual incident response test
Tabletop exercises conducted
Lessons learned documented
Plan updated based on findings

Section 10 Score: _____ / _____

SECTION 11: LOGGING & MONITORING

Comprehensive Logging

All PII access logged
Authentication events logged
Authorization failures logged
System events logged
Security events logged
Log integrity protected
Centralized log management
Log retention (12 months minimum)

Monitoring

Real-time security monitoring
24/7 monitoring coverage
Automated alerting
SIEM solution deployed
Threat intelligence integration
Security dashboards
Regular log review

Section 11 Score: _____ / _____

SECTION 12: TRAINING & AWARENESS

Training Program

Privacy and security training program
New hire training
Annual refresher training
Role-specific training
Training materials current
Competency assessments

Training Records

Learning management system (LMS)
Attendance records
Completion tracking
Certificate issuance
Training effectiveness evaluation

Awareness

Regular privacy communications
Security awareness campaigns
Privacy champions program
Incident reporting training

Section 12 Score: _____ / _____

SECTION 13: DOCUMENTATION

Required Documents

Privacy Policy
Information Security Policy
Data Protection Policy
All procedures documented
Work instructions available
Templates created
Forms designed

Document Management

Version control system
Review and approval workflow
Distribution control
Archival procedures
Annual review cycle

Records Management

Record retention schedule
Secure storage
Easy retrieval
Protection against loss
Backup procedures

Section 13 Score: _____ / _____

SECTION 14: AUDIT & REVIEW

Internal Audit

Annual internal audit planned
Internal auditors trained
Audit checklist prepared
Audit findings documented
Corrective actions implemented
Follow-up audits conducted

Management Review

Quarterly management reviews
Review agenda defined
Minutes documented
Action items tracked
Decisions recorded
Resource allocation reviewed

External Assessment

Third-party security assessments
Penetration testing (annual)
Vulnerability scanning (monthly)
Certification audits
Findings addressed

Section 14 Score: _____ / _____

SECTION 15: CONTINUOUS IMPROVEMENT

Performance Measurement

KPIs defined
Metrics collected
Reporting dashboard
Trend analysis
Benchmarking

Improvement Initiatives

Improvement opportunities identified
Projects prioritized
Resources allocated
Progress tracked
Results measured

Change Management

Change control process
Privacy impact assessment for changes
Testing before deployment
Communication to stakeholders
Documentation updates

Section 15 Score: _____ / _____

OVERALL COMPLIANCE SCORE

Section Scores:
1. Governance: _____ / _____
2. Data Processing: _____ / _____
3. Consent: _____ / _____
4. Data Subject Rights: _____ / _____
5. Encryption: _____ / _____
6. Access Control: _____ / _____
7. Retention & Deletion: _____ / _____
8. Sub-processors: _____ / _____
9. Cross-border Transfers: _____ / _____
10. Incident Response: _____ / _____
11. Logging & Monitoring: _____ / _____
12. Training: _____ / _____
13. Documentation: _____ / _____
14. Audit & Review: _____ / _____
15. Continuous Improvement: _____ / _____

TOTAL: _____ / _____

PERCENTAGE: _____%

Readiness Assessment

95-100%: Certification Ready - Schedule audit 85-94%: Nearly Ready - Address minor gaps 75-84%: Significant Work Needed - 3-6 months to readiness <75%: Major Implementation Required - 6-12 months to readiness

PRIORITY ACTION PLAN

Critical Gaps (Address Immediately):

High Priority (30 Days):

Medium Priority (90 Days):

CERTIFICATION READINESS

Ready to Proceed with Certification if:

Overall score ≥ 95%
No critical gaps
All high-priority items complete
Documentation complete
Internal audit passed
Management review conducted
Staff trained
Budget approved
Certification body selected

Next Steps:

Address remaining gaps
Conduct final internal audit
Schedule Stage 1 audit
Brief all stakeholders
Prepare audit evidence
Schedule Stage 2 audit
Achieve certification!

Next Lesson: Final assessment quiz - test your ISO 27018 knowledge.