ISO 27018
Code of practice for PII protection in public clouds.
23 NYCRR 500
NY regulation for financial services cybersecurity compliance
Quick Verdict
ISO 27018 provides voluntary cloud PII privacy controls globally for processors, while 23 NYCRR 500 mandates comprehensive cybersecurity for NY financial entities with strict enforcement. Companies adopt ISO 27018 for certification trust; Part 500 to avoid multimillion fines.
ISO 27018
ISO/IEC 27018:2025 PII protection in public clouds
Key Features
- Protects PII processed by public cloud processors
- Mandates transparency on data locations and subprocessors
- Enforces purpose limitation and consent requirements
- Requires secure PII deletion and return on termination
- Specifies breach notification to PII controllers
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Annual CISO/CEO dual-signature compliance certification
- Phishing-resistant MFA for high-risk access
- 72-hour cybersecurity incident notification to NYDFS
- Risk-based third-party service provider oversight
- Annual penetration testing and vulnerability management
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
ISO 27018 Details
What It Is
ISO/IEC 27018:2025 is a code of practice extending ISO/IEC 27002 for protecting personally identifiable information (PII) in public cloud environments where providers act as PII processors. Its primary scope targets cloud service providers handling customer PII under contract, using a risk-based approach layered on an ISO 27001 ISMS.
Key Components
- Core themes: consent/purpose limitation, transparency, data minimization, subcontractor management, logging/auditability, breach notification, secure deletion.
- Builds on ISO/IEC 27002:2022's 93 controls with ~25-30 additional privacy-specific cloud controls.
- Aligned with ISO/IEC 29100 privacy principles.
- Certification via extension of ISO 27001 audits, with Statements of Applicability including 27018 controls.
Why Organizations Use It
Enhances trust in cloud PII processing, supports GDPR Article 28 processor obligations, reduces procurement friction via audited transparency, mitigates privacy risks in multi-tenant clouds, and differentiates CSPs/SaaS vendors in regulated markets.
Implementation Overview
Conduct gap analysis on existing ISO 27001 ISMS, map 27018 controls, update policies/contracts, integrate monitoring tools. Applies to CSPs/SaaS of all sizes; requires accredited third-party audits with annual surveillance.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate for financial entities. It establishes minimum risk-based cybersecurity requirements to protect nonpublic information (NPI) and information systems, applying to Covered Entities like banks, insurers, and licensees operating in New York.
Key Components
- 14 core requirements including cybersecurity program, CISO appointment, MFA, encryption, risk assessments, TPSP oversight, penetration testing, and 72-hour incident reporting.
- Built on risk-assessment-centric architecture with annual CISO/CEO certification and five-year record retention.
- Phased compliance for Class A companies with enhanced audits and controls.
Why Organizations Use It
- Mandatory for NY-regulated financial services to avoid multimillion-dollar fines (e.g., Robinhood $30M).
- Enhances resilience, vendor management, and executive accountability.
- Builds stakeholder trust and reduces incident risks.
Implementation Overview
- Risk-based roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts, IR playbooks.
- Applies to NY-licensed entities regardless of size/location; limited exemptions for small firms.
- No external certification but annual filing and DFS examinations require evidence repository. (178 words)
Key Differences
| Aspect | ISO 27018 | 23 NYCRR 500 |
|---|---|---|
| Scope | PII protection in public cloud processors | Cybersecurity for NY financial services entities |
| Industry | All sectors, global cloud processors | NY financial services, state-specific |
| Nature | Voluntary ISO code of practice | Mandatory state regulation with enforcement |
| Testing | ISO 27001 audits with 27018 controls | Annual pen testing, vulnerability assessments |
| Penalties | Loss of certification, no legal fines | Multi-million dollar fines, consent orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about ISO 27018 and 23 NYCRR 500
ISO 27018 FAQ
23 NYCRR 500 FAQ
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