What is the primary objective of **ISO 27018**?

**ISO 27018 provides a code of practice for protecting **Personally Identifiable Information (PII)** in public clouds acting as PII processors.** It extends **ISO 27001** and **ISO 27002** with ~25–30 privacy-specific controls addressing cloud risks like multi-tenancy, subprocessors, consent, purpose limitation, data minimization, breach notification, and restrictions on secondary PII use (e.g., no advertising without consent). The 2025 edition aligns with **ISO 27002:2022**, emphasizing transparency and accountability for CSPs.

Who is legally or professionally required to comply with **ISO 27018**?

**ISO 27018 targets public cloud service providers (CSPs) acting as PII processors, not controllers.** Applicable to hyperscalers, regional platforms, and government clouds processing customer PII; controllers use it for vendor due diligence. No legal mandate exists, but it's a professional expectation for GDPR Article 28 alignment, procurement, and demonstrating processor obligations like subprocessor transparency.

Does **ISO 27018** require an external audit or third-party certification?

**ISO 27018 does not offer standalone certification; controls are assessed within **ISO 27001** audits by accredited bodies under **ISO/IEC 17021** and **ISO/IEC 27006**.** Auditors review **Statement of Applicability (SoA)** integration during Stage 1/2 audits; certificates reference both standards, valid 3 years with annual surveillance.

How often should an assessment for **ISO 27018** be performed?

**ISO 27018 assessments occur via annual surveillance audits and full recertification every 3 years as part of the **ISO 27001** cycle.** Gap analyses and internal reviews should align with ISMS continual improvement, especially for new services, subprocessors, or regulatory changes.

What are the consequences of non-compliance with **ISO 27018**?

**Non-compliance with ISO 27018 risks loss of market trust, procurement delays, cyber insurance issues, and failure to meet processor obligations under laws like GDPR.** No direct fines from the standard (voluntary code of practice), but gaps expose CSPs to contractual breaches, regulatory scrutiny, and reputational damage from PII incidents.

Can **ISO 27018** be mapped to other international frameworks?

**Yes, ISO 27018 maps directly to **ISO 27001 Annex A** (93 controls), **ISO 27002**, **ISO 27017** (cloud security), and **ISO 27701** (PIMS for controllers/processors).** Controls align with GDPR Article 28, OECD guidelines, and **ISO/IEC 29100** privacy principles, enabling unified SoA documentation.

What is the first step to begin implementing **ISO 27018**?

**Conduct a gap analysis against current ISMS, **ISO 27001/27002** controls, and ISO 27018 privacy requirements.** Engage stakeholders to scope PII processing, review documentation/SoA, identify deficiencies in transparency, subprocessors, and data subject rights support, then prioritize a remediation roadmap.

What is the primary objective of **AS9110C**?

**AS9110C’s primary objective is to enable aviation maintenance organizations to consistently meet customer and applicable statutory/regulatory requirements for safe products and services while enhancing customer satisfaction through effective application of a quality management system.** It follows ISO 9001:2015’s Annex SL structure across Clauses 4–10, incorporating PDCA logic and adding maintenance-specific controls like configuration management, product safety, counterfeit parts prevention, traceability, preservation, and human factors analysis to ensure continuing airworthiness.

Who is legally or professionally required to comply with **AS9110C**?

**AS9110C applies to organizations providing aviation maintenance, repair, overhaul (MRO), and continuing airworthiness services, including repair stations, independent MROs, and OEMs with autonomous MRO operations.** It targets civil and military contexts regardless of size, where primary business involves maintenance on used components with unique risks like uncertain histories and regulatory primacy (e.g., FAA/EASA approvals). Certification is often contractually mandated by OEMs and airlines for OASIS listing and supply-chain access.

Does **AS9110C** require an external audit or third-party certification?

**Yes, AS9110C requires third-party certification through accredited bodies, with initial Stage 1 (documentation) and Stage 2 (implementation) audits, followed by annual surveillance and triennial recertification.** The QMS must be fully operational for at least three months, including a full internal audit cycle and management review, before initial certification to demonstrate effectiveness.

How often should an assessment for **AS9110C** be performed?

**Internal audits for AS9110C must be performed at planned intervals based on process risk, status, and results, with full coverage annually and critical processes (e.g., configuration management, release to service) audited more frequently.** Management reviews occur at least annually, using performance data from monitoring, audits, and nonconformities; external surveillance audits are annual post-certification.

What are the consequences of non-compliance with **AS9110C**?

**Non-compliance with AS9110C risks loss of regulatory approvals (e.g., FAA/EASA Part 145 certificates), contract termination by OEMs/airlines, exclusion from IAQG OASIS, and safety incidents leading to fines, litigation, or shutdowns.** It undermines continuing airworthiness evidence, exposes organizations to rework, AOG events, and reputational damage in high-stakes MRO environments.

Can **AS9110C** be mapped to other international frameworks?

**Yes, AS9110C’s Annex SL high-level structure enables direct mapping to ISO 9001:2015 as its baseline, with aviation-specific extensions aligning to regulatory frameworks like FAA/EASA Part 145.** IAQG correlation matrices support integration, but customer/regulatory requirements override where conflicts arise, ensuring harmonized QMS without exclusions unless justified in scope.

What is the first step to begin implementing **AS9110C**?

**The first step is to define the QMS scope, determine internal/external issues (Clause 4), and conduct a gap analysis against Clauses 4–10 using IAQG checklists.** Secure executive sponsorship, map regulatory approvals and interested parties, and produce a prioritized remediation plan with risk-based thinking (Clause 6.1) to justify any non-applicable requirements.

ISO 27018 vs AS9110C

Standards Comparison

ISO 27018

Voluntary

2019

International code of practice for PII protection in public clouds

AS9110C

Mandatory

2016

International QMS standard for aviation maintenance organizations

Quick Verdict

ISO 27018 provides cloud PII privacy controls for service providers within ISO 27001, while AS9110C is a certifiable QMS for aviation maintenance ensuring airworthiness and traceability. CSPs adopt 27018 for trust; MROs use AS9110C for regulatory compliance and contracts.

Cloud Privacy

ISO 27018

ISO/IEC 27018: Code of practice for PII protection in public clouds

Cost

€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Privacy-specific controls for PII in public clouds
Mandates subprocessor transparency and disclosure
Requires customer breach notification procedures
Prohibits PII use for marketing without consent
Integrates as extension to ISO 27001 audits

Quality Management

AS9110C

AS9110C Quality Management Systems Requirements for Aviation Maintenance Organizations

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Risk-based thinking in strategic and operational planning
Configuration management and traceability controls
Counterfeit and suspect parts prevention program
Human factors integration in root cause analysis
Dedicated safety policy and Accountable Manager role

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 27001 and ISO 27002 for protecting personally identifiable information (PII) processed by public cloud service providers acting as PII processors. Its primary purpose is to provide privacy-specific controls and guidance for cloud environments, focusing on multi-tenancy, cross-border data flows, and processor obligations. It employs a risk-based approach integrated into an Information Security Management System (ISMS).

Key Components

Core domains: transparency, contractual obligations, data subject rights support, breach management, data minimization.
Approximately 25-30 additional privacy controls mapped to ISO 27001 Annex A.
Built on principles like consent, purpose limitation, accuracy, security, accountability.
Assessed via ISO 27001 audits; no standalone certification.

Why Organizations Use It

Enhances customer trust, accelerates procurement, aligns with GDPR Article 28 and similar laws. Reduces risk in cloud outsourcing, supports cyber insurance, differentiates CSPs in regulated markets like healthcare and finance.

Implementation Overview

Conduct gap analysis against existing ISMS, integrate controls into Statement of Applicability, update contracts and processes. Suitable for CSPs of all sizes; requires third-party audits during ISO 27001 certification. Focuses on documentation, training, technical safeguards like encryption and logging.

AS9110C Details

What It Is

AS9110C (AS9110:2016 Rev C) is an international quality management system (QMS) certification standard for aviation maintenance, repair, and overhaul (MRO) organizations. It builds on ISO 9001:2015 with aerospace-specific requirements for continuing airworthiness, using a risk-based thinking approach via Annex SL high-level structure and PDCA cycle.

Key Components

Core clauses 4–10 covering context, leadership, planning, support, operation, evaluation, improvement.
Aviation additions: configuration management, counterfeit parts prevention, human factors, traceability, product safety.
No fixed control count; emphasizes documented information, external provider controls, project management.
Certification via IAQG-accredited bodies with audits.

Why Organizations Use It

Meets customer/OEM contracts and regulatory alignment (e.g., FAA/EASA Part 145).
Mitigates safety risks, ensures traceability for airworthiness.
Enhances market access via OASIS listing, improves on-time delivery, customer satisfaction.
Builds stakeholder trust through demonstrable QMS effectiveness.

Implementation Overview

Phased: gap analysis, process design, training, internal audits, certification (6-12 months typical).
Applies to MROs of all sizes globally; requires operational maturity pre-audit.

Key Differences

Aspect	ISO 27018	AS9110C
Scope	PII protection in public clouds for processors	Quality management for aviation maintenance organizations
Industry	Cloud service providers, all sectors globally	Aerospace MRO, repair stations worldwide
Nature	Code of practice, extension of ISO 27001	Certifiable QMS standard based on ISO 9001
Testing	Assessed in ISO 27001 audits, annual surveillance	ISO 9001-style certification audits, 3-year cycle
Penalties	Loss of alignment claim, no legal penalties	Loss of certification, regulatory/contract risks

Scope

ISO 27018

PII protection in public clouds for processors

AS9110C

Quality management for aviation maintenance organizations

Industry

ISO 27018

Cloud service providers, all sectors globally

AS9110C

Aerospace MRO, repair stations worldwide

Nature

ISO 27018

Code of practice, extension of ISO 27001

AS9110C

Certifiable QMS standard based on ISO 9001

Testing

ISO 27018

Assessed in ISO 27001 audits, annual surveillance

AS9110C

ISO 9001-style certification audits, 3-year cycle

Penalties

ISO 27018

Loss of alignment claim, no legal penalties

AS9110C

Loss of certification, regulatory/contract risks

Frequently Asked Questions

Common questions about ISO 27018 and AS9110C

ISO 27018 FAQ

AS9110C FAQ

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ISO 27018

AS9110C

Quick Verdict

ISO 27018

Key Features

AS9110C

Key Features

Detailed Analysis

ISO 27018 Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

AS9110C Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

ISO 27018 FAQ

What is the primary objective of ISO 27018?

Who is legally or professionally required to comply with ISO 27018?

Does ISO 27018 require an external audit or third-party certification?

How often should an assessment for ISO 27018 be performed?

What are the consequences of non-compliance with ISO 27018?

Can ISO 27018 be mapped to other international frameworks?

What is the first step to begin implementing ISO 27018?

AS9110C FAQ

What is the primary objective of AS9110C?

Who is legally or professionally required to comply with AS9110C?

Does AS9110C require an external audit or third-party certification?

How often should an assessment for AS9110C be performed?

What are the consequences of non-compliance with AS9110C?

Can AS9110C be mapped to other international frameworks?

What is the first step to begin implementing AS9110C?

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Thailand PDPA Implementation Guide: Subordinate Regulations for 72-Hour Breach Reporting and Cross-Border Transfers (2022-2024 Rules)

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Beyond Reactive: Transforming Compliance into Real-Time Threat Prevention

Run Maturity Assessments with GRADUM

Check out these other Gradum.io Standards Comparison Pages

ISO 37001 vs ISO 26000

NIS2 vs PDPA

Basel III vs SAMA CSF