preparing-iso-31700-certification

Preparing ISO 31700 Certification

Overview

ISO 31700:2023 "Consumer protection — Privacy by design for consumer goods and services" is the first international standard specifically dedicated to privacy by design. Published in February 2023, it provides 30 requirements organized across three lifecycle phases: design, production/deployment, and end-of-life/disposal.

ISO 31700 operationalizes the privacy by design concept originally proposed by Ann Cavoukian and codified in GDPR Article 25(1). While Article 25 establishes the legal obligation, ISO 31700 provides a certifiable framework for demonstrating compliance through structured requirements across the entire product lifecycle.

ISO 31700 Structure

Part 1: High-Level Requirements (ISO 31700-1:2023)

30 requirements organized into three lifecycle phases.

Part 2: Use Cases (ISO 31700-2:2023)

Practical use cases illustrating application of Part 1 requirements across industries including e-commerce, IoT devices, mobile applications, and cloud services.

The 30 Requirements

Phase 1: Design (Requirements 1-16)

Req #	Title	Summary	GDPR Mapping
1	Designing privacy controls	Consumer goods shall include privacy controls that enable consumers to manage collection, use, and disclosure of their PII	Art. 25(1), Art. 25(2)
2	Privacy notice and consent	Privacy information shall be communicated to consumers in a clear and understandable manner	Art. 12-14
3	Consumer PII collection	PII collection shall be limited to what is necessary and proportionate	Art. 5(1)(c)
4	Creating and managing consumer PII	Processes shall be established for the creation, maintenance, and deletion of PII	Art. 5(1)(d), Art. 5(1)(e)
5	Consumer PII use limitation	PII shall be processed only for specified, explicit, and legitimate purposes	Art. 5(1)(b)
6	Consumer PII disclosure to third parties	PII disclosure to third parties shall be limited and controlled	Art. 28, Art. 44-49
7	Consumer PII quality	Measures shall ensure accuracy and currency of PII	Art. 5(1)(d)
8	Consumer PII security	Appropriate security measures shall protect PII	Art. 32
9	Consumer PII retention	PII shall not be retained longer than necessary	Art. 5(1)(e)
10	Organizational commitment	Management shall commit resources and oversight for privacy	Art. 24
11	Privacy risk assessment	Privacy risks shall be identified, assessed, and treated	Art. 35
12	Designing PII processing rights	Consumer rights to access, correct, delete, and port their PII shall be built into the design	Art. 15-20
13	Designing ergonomic privacy controls	Privacy controls shall be usable and accessible to consumers	Art. 25(2)
14	Designing privacy for vulnerable consumers	Design shall consider the needs of children, elderly, and other vulnerable populations	Art. 8, Recital 38
15	Supply chain management	Privacy requirements shall be imposed on suppliers and sub-processors	Art. 28
16	Designing for disposal	Design shall include mechanisms for PII deletion at end of product life	Art. 17

Phase 2: Production and Deployment (Requirements 17-24)

Req #	Title	Summary	GDPR Mapping
17	Privacy awareness and training	Personnel shall receive privacy training appropriate to their role	Art. 39(1)(b)
18	Privacy operations	Operational procedures shall implement designed privacy controls	Art. 24, Art. 25(1)
19	Privacy breach management	Incident response procedures for privacy breaches shall be established	Art. 33, Art. 34
20	Communication with consumers	Channels for consumer privacy inquiries and complaints shall be maintained	Art. 12(2)
21	Third-party management	Third parties processing PII shall be managed and monitored	Art. 28
22	Consumer PII use	PII processing in production shall align with designed purposes and controls	Art. 5(1)(b)
23	Managing privacy inquiries and complaints	Consumer inquiries and complaints shall be handled within specified timeframes	Art. 12(3)
24	Privacy performance monitoring	Privacy controls shall be monitored for effectiveness	Art. 24(1)

Phase 3: End-of-Life and Disposal (Requirements 25-30)

Req #	Title	Summary	GDPR Mapping
25	End-of-life PII management	PII shall be managed when a product reaches end of life	Art. 17
26	Consumer notification of disposal	Consumers shall be informed about PII handling during disposal	Art. 13
27	PII disposal	PII shall be securely deleted or anonymized at end of life	Art. 5(1)(e), Art. 17
28	Data portability at end of life	Consumers shall be able to retrieve their data before disposal	Art. 20
29	Supply chain disposal	Suppliers and sub-processors shall delete PII upon product disposal	Art. 28(3)(g)
30	Disposal documentation	Disposal activities shall be documented and verifiable	Art. 5(2)

Gap Assessment Methodology

Assessment Scoring

For each of the 30 requirements, assess the current state:

Score	Level	Description
0	Non-existent	No awareness of the requirement
1	Initial	Awareness exists but no formal implementation
2	Developing	Partial implementation, ad hoc processes
3	Defined	Formal processes documented and communicated
4	Managed	Processes monitored, measured, and consistently applied
5	Optimizing	Continuous improvement based on metrics and feedback

Certification readiness: All requirements must be at Level 3 or above. Level 4 or above is recommended for high-risk processing.

Gap Assessment Process

1. Document current state — For each requirement, document what controls, processes, and evidence currently exist.
2. Score maturity — Apply the 0-5 scoring scale based on documented evidence.
3. Identify gaps — Requirements scoring below 3 are certification gaps.
4. Prioritize remediation — Rank gaps by: risk impact (high-risk processing first), dependency (foundational requirements first), and effort.
5. Create remediation plan — Define specific actions, responsible parties, and target dates for each gap.
6. Execute and verify — Implement remediations and verify through evidence collection.
7. Pre-certification audit — Conduct internal audit using ISO 31700 checklist before engaging certification body.

Prism Data Systems AG Gap Assessment Summary

Phase	Requirements	Avg Score	Gaps (< 3)	Critical Gaps (< 2)
Design (1-16)	16	3.8	2	0
Production (17-24)	8	3.5	1	0
Disposal (25-30)	6	2.7	3	1
Total	30	3.4	6	1

Critical gap: Requirement 27 (PII disposal) scored 1 — while Prism Data Systems AG has automated deletion for database records, physical media disposal procedures for decommissioned hardware lack documented verification.

Remediation Roadmap

Priority	Req #	Gap Description	Remediation Action	Owner	Target
1	27	Physical media disposal lacks verification	Implement NIST SP 800-88 media sanitization with certificate of destruction	IT Operations	2026-05-01
2	25	End-of-life PII management incomplete	Define end-of-life procedures for each product line; assign lifecycle owners	Product Management	2026-05-15
3	29	Supplier disposal obligations not enforced	Add disposal audit clause to supplier contracts; annual verification	Procurement	2026-06-01
4	14	Vulnerable consumer design considerations informal	Document accessibility and child safety review as design stage gate	UX Engineering	2026-06-15
5	16	Disposal design mechanisms incomplete	Add data wipe functionality to all IoT device firmware	Firmware Engineering	2026-07-01
6	24	Privacy monitoring metrics not formalized	Define KPIs for each privacy control; implement dashboard	Privacy Engineering	2026-06-01

Implementation Workflow

1. Executive sponsorship — Secure management commitment (Requirement 10) with budget allocation and executive sponsor assignment.

2. Gap assessment — Conduct full assessment of all 30 requirements using the scoring methodology above.

3. Remediation planning — Create prioritized remediation roadmap addressing all gaps below Level 3.

4. Implementation — Execute remediations in priority order, documenting evidence of implementation for each requirement.

5. Internal audit — Conduct pre-certification internal audit using the ISO 31700 checklist to verify all requirements are at Level 3+.

6. Certification body engagement — Select an accredited certification body and schedule the Stage 1 (documentation review) and Stage 2 (implementation audit) assessments.

7. Continuous improvement — After certification, maintain a continuous improvement cycle with annual surveillance audits and periodic internal reviews.

Key Regulatory References

• ISO 31700-1:2023 — Consumer protection — Privacy by design for consumer goods and services — Part 1: High-level requirements
• ISO 31700-2:2023 — Part 2: Use cases
• GDPR Article 25 — Data protection by design and by default
• GDPR Article 42 — Certification
• GDPR Article 43 — Certification bodies
• EDPB Guidelines 4/2019 on Article 25 Data Protection by Design and by Default
• NIST SP 800-88 Rev. 1 — Guidelines for Media Sanitization