Training Module
Training Module
Operational Privacy Controls
Understand role-based operational privacy controls and data subject rights handling within an ISO/IEC 27701:2025 PIMS
Understand
Implement
Manage
Audit
Training module overview
ISO/IEC 27701:2025 defines a Privacy Information Management System (PIMS) as a stand-alone management system standard and includes role-based privacy controls and guidance for PII controllers and PII processors. Operationally, the recurring challenge is not “having controls”, but making them run: controls mapped to workflows, clear handoffs between functions, reliable records, and consistent handling of requests from data subjects.
This module focuses on implementing and sustaining operational privacy controls and data subject rights processes aligned to ISO/IEC 27701:2025. It assumes privacy fundamentals, processing context/roles/scope, and DPIA logic are handled elsewhere. It does not re-teach generic management-system methods (governance design, risk methodology, KPI design, audit craft); those remain owned by the relevant foundation modules.
ISO/IEC 27701:2025 defines a Privacy Information Management System (PIMS) as a stand-alone management system standard and includes role-based privacy controls and guidance for PII controllers and PII processors. Operationally, the recurring challenge is not “having controls”, but making them run: controls mapped to workflows, clear handoffs between functions, reliable records, and consistent handling of requests from data subjects.
This module focuses on implementing and sustaining operational privacy controls and data subject rights processes aligned to ISO/IEC 27701:2025. It assumes privacy fundamentals, processing context/roles/scope, and DPIA logic are handled elsewhere. It does not re-teach generic management-system methods (governance design, risk methodology, KPI design, audit craft); those remain owned by the relevant foundation modules.
Target audience
PIMS managers and implementers responsible for operationalising privacy controls
Service/process owners running PII-handling workflows (HR, marketing, sales, customer support, product, IT/ops)
Supplier and outsourcing managers coordinating privacy requirements with vendors and sub-processors
Internal auditors who need implementer-side clarity on what “operationally in place” looks like (optional)
PIMS managers and implementers responsible for operationalising privacy controls
Service/process owners running PII-handling workflows (HR, marketing, sales, customer support, product, IT/ops)
Supplier and outsourcing managers coordinating privacy requirements with vendors and sub-processors
Internal auditors who need implementer-side clarity on what “operationally in place” looks like (optional)
Agenda
Operationalising ISO/IEC 27701:2025 controls in a stand-alone PIMS
Role-based control intent (controller vs processor) and what “operational” means in practice
Control ownership patterns across functions (privacy, legal, security, product, operations)
From control statements to workflows and evidence
Mapping controls to lifecycle touchpoints (collect → use → share → retain/delete)
Defining “minimum viable evidence” without building an audit bureaucracy
Controller controls: operating patterns
Managing transparency, purpose alignment, retention, and disclosure in day-to-day processes
Handling internal exceptions and non-standard processing requests (approval paths, documentation)
Processor controls: operating patterns
Working to instructions, handling sub-processors, and assistance obligations as an operational service
Managing multi-client environments and shared platforms without role confusion
Supplier and sub-processor interfaces
What must be operationalised inside the organisation vs enforced via supplier requirements
Handoffs: onboarding, change notifications, assurance inputs, and exit/transition
Data subject rights handling as a managed process
Intake, triage, identity/authority checks, and routing to data owners
Response coordination, recordkeeping, and consistent decision rationales (without legal advice)
Special cases and failure modes
Requests involving multiple systems, distributed data, backups/archives, and shared identifiers
Common breakdowns: missed deadlines, incomplete search, inconsistent answers, unmanaged third parties
Sustaining operational controls over time
Change triggers: new products, new data uses, new vendors, new regions, new tooling
Lightweight maintenance routines and ownership (keeping workflows and registers current)
Technology as an enabler
Tooling patterns: ticketing/workflow, records, linkages to inventories and contracts
AI-assisted summarisation for request triage and evidence drafting (supporting judgement, not replacing it)
Workshop (case-based)
Design a DSAR operating model and control-to-workflow map for a multi-system scenario
Stress-test the model against supplier dependencies and change events
Operationalising ISO/IEC 27701:2025 controls in a stand-alone PIMS
Role-based control intent (controller vs processor) and what “operational” means in practice
Control ownership patterns across functions (privacy, legal, security, product, operations)
From control statements to workflows and evidence
Mapping controls to lifecycle touchpoints (collect → use → share → retain/delete)
Defining “minimum viable evidence” without building an audit bureaucracy
Controller controls: operating patterns
Managing transparency, purpose alignment, retention, and disclosure in day-to-day processes
Handling internal exceptions and non-standard processing requests (approval paths, documentation)
Processor controls: operating patterns
Working to instructions, handling sub-processors, and assistance obligations as an operational service
Managing multi-client environments and shared platforms without role confusion
Supplier and sub-processor interfaces
What must be operationalised inside the organisation vs enforced via supplier requirements
Handoffs: onboarding, change notifications, assurance inputs, and exit/transition
Data subject rights handling as a managed process
Intake, triage, identity/authority checks, and routing to data owners
Response coordination, recordkeeping, and consistent decision rationales (without legal advice)
Special cases and failure modes
Requests involving multiple systems, distributed data, backups/archives, and shared identifiers
Common breakdowns: missed deadlines, incomplete search, inconsistent answers, unmanaged third parties
Sustaining operational controls over time
Change triggers: new products, new data uses, new vendors, new regions, new tooling
Lightweight maintenance routines and ownership (keeping workflows and registers current)
Technology as an enabler
Tooling patterns: ticketing/workflow, records, linkages to inventories and contracts
AI-assisted summarisation for request triage and evidence drafting (supporting judgement, not replacing it)
Workshop (case-based)
Design a DSAR operating model and control-to-workflow map for a multi-system scenario
Stress-test the model against supplier dependencies and change events
Course ID:
HAM-OPC-1
Audience:
Manager
Auditor
Domain:
Data Protection
Available in:
English
Duration:
7 h
List price:
CHF 550
Excl. VAT. VAT may apply depending on customer location and status.
What you get
Learning outcomes
Explain how ISO/IEC 27701:2025 control expectations translate into operational workflows for controllers and processors
Map privacy control requirements to concrete process steps, ownership, and maintainable evidence
Design a practical data subject rights handling process from intake through closure, including routing and recordkeeping
Define workable internal and supplier interfaces for operational privacy controls (handoffs, escalation, change notifications)
Identify and prevent common operational failure modes in DSAR handling and privacy control execution
Set up review triggers and maintenance routines so operational privacy controls stay current as processing changes
Explain how ISO/IEC 27701:2025 control expectations translate into operational workflows for controllers and processors
Map privacy control requirements to concrete process steps, ownership, and maintainable evidence
Design a practical data subject rights handling process from intake through closure, including routing and recordkeeping
Define workable internal and supplier interfaces for operational privacy controls (handoffs, escalation, change notifications)
Identify and prevent common operational failure modes in DSAR handling and privacy control execution
Set up review triggers and maintenance routines so operational privacy controls stay current as processing changes
Learning materials
Slide deck
Participant workbook
Certificate of completion
Slide deck
Participant workbook
Certificate of completion
Templates & tools
Operational Privacy Control-to-Workflow Mapping Sheet (role-based)
Control Ownership & Evidence Map (RACI-style, evidence minimal set)
Data Subject Rights Intake & Triage Checklist
DSAR Workflow Template (routing, timers, handoffs, closure criteria)
Request Record Pack (decision notes, search notes, response summary)
Supplier Interface & Assistance Checklist (processor support, sub-processor handoffs)
Change Trigger Checklist for operational controls and DSAR process updates
Optional AI prompt set for summarising requests and drafting evidence notes
Operational Privacy Control-to-Workflow Mapping Sheet (role-based)
Control Ownership & Evidence Map (RACI-style, evidence minimal set)
Data Subject Rights Intake & Triage Checklist
DSAR Workflow Template (routing, timers, handoffs, closure criteria)
Request Record Pack (decision notes, search notes, response summary)
Supplier Interface & Assistance Checklist (processor support, sub-processor handoffs)
Change Trigger Checklist for operational controls and DSAR process updates
Optional AI prompt set for summarising requests and drafting evidence notes
Prerequisites
This module assumes participants can already work with core privacy concepts and can navigate their organisation’s processing reality.
Helpful background includes:
Basic privacy / data protection concepts and terminology (PII, processing, recipients, retention, disclosure)
Clarity on processing context, roles, and scope artefacts (at least at a high level)
Familiarity with internal workflows and systems where PII is handled (ticketing, CRM, HRIS, support tooling, shared drives)
This module assumes participants can already work with core privacy concepts and can navigate their organisation’s processing reality.
Helpful background includes:
Basic privacy / data protection concepts and terminology (PII, processing, recipients, retention, disclosure)
Clarity on processing context, roles, and scope artefacts (at least at a high level)
Familiarity with internal workflows and systems where PII is handled (ticketing, CRM, HRIS, support tooling, shared drives)
Strongly recommended preparatory modules
Privacy & Data Protection Fundamentals: Mapping the Data Protection Domain
A helicopter view of privacy roles, obligations, and mechanisms in organisations
7 h
Privacy & Data Protection Fundamentals: Mapping the Data Protection Domain
A helicopter view of privacy roles, obligations, and mechanisms in organisations
7 h
Privacy & Data Protection Fundamentals: Mapping the Data Protection Domain
A helicopter view of privacy roles, obligations, and mechanisms in organisations
7 h
Operational Control Foundations: Translating Plans into Controlled, Repeatable Processes
Learn the fundamentals of designing and running controlled operational processes with clear roles, controls, records, and change handling.
7 h
Operational Control Foundations: Translating Plans into Controlled, Repeatable Processes
Learn the fundamentals of designing and running controlled operational processes with clear roles, controls, records, and change handling.
7 h
Operational Control Foundations: Translating Plans into Controlled, Repeatable Processes
Learn the fundamentals of designing and running controlled operational processes with clear roles, controls, records, and change handling.
7 h
Helpful preparatory modules
The modules below prepare for an optimal learning experience – but are not strictly necessary for participants to follow.
PII Processing Context, Roles & Scope (ISO/IEC 27701:2025)
Understand PII processing context, controller/processor roles, and practical PIMS scope boundaries under ISO/IEC 27701:2025
7 h
PII Processing Context, Roles & Scope (ISO/IEC 27701:2025)
Understand PII processing context, controller/processor roles, and practical PIMS scope boundaries under ISO/IEC 27701:2025
7 h
PII Processing Context, Roles & Scope (ISO/IEC 27701:2025)
Understand PII processing context, controller/processor roles, and practical PIMS scope boundaries under ISO/IEC 27701:2025
7 h
Governance Foundations: Role Design, Decision Rights, and Escalation in Management Systems
Learn the fundamentals of role design, decision rights, governance mechanisms, and escalation paths in management systems
7 h
Governance Foundations: Role Design, Decision Rights, and Escalation in Management Systems
Learn the fundamentals of role design, decision rights, governance mechanisms, and escalation paths in management systems
7 h
Governance Foundations: Role Design, Decision Rights, and Escalation in Management Systems
Learn the fundamentals of role design, decision rights, governance mechanisms, and escalation paths in management systems
7 h
Continuous learning
Follow-up modules
Follow-up modules
After completion of this module, the following modules are ideal to further deepen the participant's competence.
After completion of this module, the following modules are ideal to further deepen the participant's competence.
Ready to achieve mastery?
Bring ISO requirements into everyday practice to reduce avoidable issues and strengthen the trust of your customers and stakeholders.
Ready to achieve mastery?
Bring ISO requirements into everyday practice to reduce avoidable issues and strengthen the trust of your customers and stakeholders.
Ready to achieve mastery?
Bring ISO requirements into everyday practice to reduce avoidable issues and strengthen the trust of your customers and stakeholders.