Migrating from ISO 27001 to GDPR
ISO 27001 addresses GDPR Article 32 (security of processing) requirements. However, GDPR is primarily a privacy regulation with legal requirements beyond security. If you're ISO 27001 certified, you have the technical foundation—the gaps are legal and procedural.
Critical Compliance Gaps
Legal Basis for Processing
GDPR requires documented legal basis for every processing activity. ISO 27001 is security-focused without addressing processing legality.
Data Subject Rights
GDPR grants extensive rights (access, erasure, portability, objection). These require processes and systems beyond ISO 27001 scope.
Data Protection Officer
GDPR may require a DPO depending on processing activities. ISO 27001 has no equivalent mandatory role.
Consent Management
GDPR has specific consent requirements that must be documented and manageable. ISO 27001 doesn't address consent.
Step-by-Step Migration Roadmap
Follow these 10 steps to achieve GDPR compliance. Estimated timeline: 12 weeks.
Map ISO 27001 controls to GDPR Articles (especially 24, 25, 32)
Create Records of Processing Activities (ROPA)
Document legal basis for each processing activity
Implement Data Subject Rights request handling
Assess DPO requirement and appoint if needed
Establish GDPR-compliant consent mechanisms
Implement 72-hour breach notification procedures
Update Data Processing Agreements with processors
Conduct DPIAs for high-risk processing
Establish cross-border transfer mechanisms
Unique GDPR Requirements
Strategic Use Cases
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ISO 27001 to GDPR Migration FAQs
Does ISO 27001 equal GDPR compliance$12
No. ISO 27001 covers security (GDPR Article 32), but GDPR includes legal requirements like consent, legal basis, data subject rights, and breach notification that are outside ISO 27001's scope.
How does ISO 27001 help with GDPR$13
ISO 27001 directly supports GDPR Article 32 requirements for appropriate security measures. Having ISO 27001 demonstrates technical and organizational measures to protect personal data.
Do I need both ISO 27001 and GDPR compliance$14
If you process EU personal data, you must comply with GDPR regardless of ISO 27001 status. ISO 27001 is voluntary but strongly supports GDPR security requirements and demonstrates accountability.
What GDPR requirements are NOT covered by ISO 27001$15
Legal basis documentation, consent management, data subject rights procedures, DPO appointment, Records of Processing Activities, DPIAs, and cross-border transfer mechanisms.
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