What is the primary objective of ISO 27018?

ISO 27018 provides a code of practice for protecting Personally Identifiable Information (PII) in public clouds where the provider acts as a PII processor. 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 marketing without consent). The 2019 edition aligns with ISO 27002:2013, though organizations map its controls to ISO 27002:2022 for modern cloud architectures.

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

ISO 27018 applies to public cloud service providers (CSPs) acting as PII processors, not controllers. Targeted at hyperscalers, regional CSPs, and sector-specific platforms (e.g., healthcare, finance) processing customer PII. Controllers use it for vendor due diligence; no legal mandate exists, but procurement, insurers, and regulators expect alignment for GDPR Article 28-like obligations in multi-tenant environments.

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

ISO 27018 requires assessment via external audits as an extension of ISO 27001 certification, not standalone. Accredited bodies (under ISO/IEC 17021 and ISO/IEC 27006) evaluate controls in the Statement of Applicability (SoA) during ISO 27001 Stage 1/2 audits. Certificates reference both standards; no independent ISO 27018 certificate exists.

How often should an assessment for ISO 27018 be performed?

ISO 27018 assessments occur via annual surveillance audits and full recertification every three years within the ISO 27001 cycle. Initial certification involves Stage 1 (documentation) and Stage 2 (implementation) audits; ongoing audits verify control effectiveness, changes, and continuous improvement for PII processing.

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

Non-compliance with ISO 27018 results in failed ISO 27001 audits, loss of certification, procurement disadvantages, and heightened regulatory risks. CSPs face rejected contracts, cyber insurance issues, and exposure to privacy laws (e.g., GDPR fines); no direct penalties from the standard, but it evidences due care failures in PII breaches or vendor disputes.

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). Controls align with GDPR Article 28 processor obligations, supporting transparency, subprocessors, and data subject rights across frameworks without replacing legal requirements.

What is the first step to begin implementing ISO 27018?

Conduct a gap analysis against current ISMS to integrate ISO 27018 controls into the Statement of Applicability (SoA). Review policies, contracts, PII flows, and cloud architecture; prioritize transparency, subprocessors, breach notification, and data subject rights support as quick wins before ISO 27001 audit extension.

What is the primary objective of ISO 28000?

ISO 28000 specifies requirements for establishing, implementing, maintaining, and continually improving a security management system (SMS) with explicit relevance to supply chain security. It operationalizes a Plan-Do-Check-Act (PDCA) cycle across Clauses 4–10, requiring organizations to assess security risks (malicious acts, disruptions, interdependencies), define scope including external processes, embed top management leadership, and ensure performance evaluation through audits and reviews. The standard is sector-agnostic, applicable to all organization sizes, focusing on holistic governance rather than prescriptive controls.

Who is legally or professionally required to comply with ISO 28000?

No organizations are legally mandated to comply with ISO 28000, as it is a voluntary international standard. Professionally, it applies to any entity influencing supply chain security—logistics providers, manufacturers, retailers, ports, and government agencies—particularly where customer contracts, insurer requirements, or trade facilitation programs demand demonstrable SMS maturity. Clause 4 requires determining relevant interested parties and their requirements, tailoring applicability to context without thresholds like employee count or revenue.

Does ISO 28000 require an external audit or third-party certification?

ISO 28000 does not require external audit or third-party certification; conformity may be verified internally or externally. Clause 9 mandates a risk-based internal audit program at planned intervals, with management review ensuring effectiveness. Certification follows ISO 28003 guidelines via accredited bodies, typically involving Stage 1 (design review) and Stage 2 (implementation) audits, plus surveillance, but remains optional for assurance to stakeholders.

How often should an assessment for ISO 28000 be performed?

ISO 28000 requires risk assessments to be maintained continuously, with internal audits conducted at planned intervals per a risk-based program (Clause 9.2). Frequency considers process importance, prior results, and changes; management reviews occur at planned intervals (Clause 9.3), typically annually. Security risk treatment (Clause 8.3, aligned with ISO 31000) and monitoring (Clause 9.1) demand ongoing evaluation, not fixed schedules.

What are the consequences of non-compliance with ISO 28000?

Non-compliance with ISO 28000 carries no direct legal penalties, as it is voluntary. Consequences include lost contracts, heightened insurance premiums, market exclusion from security-sensitive tenders, reputational damage from incidents, and failed stakeholder assurance. Without SMS discipline, organizations face unmitigated supply chain risks like theft or disruptions, per Clauses 6 and 8 requirements.

Can ISO 28000 be mapped to other international frameworks?

Yes, ISO 28000 aligns structurally with ISO management system standards via its PDCA cycle and Clause 4–10 framework. It references ISO 31000 for risk processes (Clause 8.3), ISO 22300 vocabulary normatively, and encourages consistency with business continuity via security plans (Clause 8.6), enabling integrated audits and shared governance without duplication.

What is the first step to begin implementing ISO 28000?

The first step is determining the organization's context, interested parties, and SMS scope per Clause 4. This involves mapping internal/external issues, supply chain interdependencies, legal requirements, and boundaries for externally provided processes, producing documented scope as foundational input to leadership policy (Clause 5) and planning (Clause 6).

Standards Comparison

ISO 27018 vs ISO 28000

ISO 27018

Voluntary

2019

Code of practice for PII protection in public clouds

ISO 28000

Voluntary

2022

International standard for supply chain security management systems

Quick Verdict

ISO 27018 protects PII in public clouds as a 27001 extension for CSPs, while ISO 28000 builds supply chain security management systems. Companies adopt 27018 for privacy trust in cloud procurement; 28000 for resilience against theft and disruptions.

Cloud Privacy

ISO 27018

ISO/IEC 27018:2019 Code of practice for cloud PII processors

Cost

€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Provides code of practice for PII protection by cloud processors
Requires disclosure of subprocessors and processing locations
Mandates notification of PII breaches to customers
Prohibits using customer PII for marketing without consent
Adds privacy-specific controls to ISO 27001 ISMS

Supply Chain Security

ISO 28000

ISO 28000:2022 Security management systems – Requirements

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

PDCA-based security management system framework
Risk assessment and treatment per ISO 31000
Supply chain interdependencies and external controls
Top management leadership and policy commitment
Operational security plans and response structures

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

ISO 27018 Details

What It Is

ISO/IEC 27018:2019 is a code of practice that extends ISO 27001 and ISO 27002 for protecting personally identifiable information (PII) in public clouds, where providers act as PII processors. Its scope focuses on cloud-specific privacy risks like multi-tenancy and cross-border flows. It employs a risk-based approach within an Information Security Management System (ISMS).

Key Components

Approximately 25-30 additional privacy-specific controls mapped to ISO 27001 Annex A themes (organizational, people, physical, technological).
Core principles: consent/choice, purpose limitation, data minimization, transparency, accountability.
Built on ISO 27002 guidance; assessed during ISO 27001 audits, not standalone certification.

Why Organizations Use It

Cloud service providers (CSPs) adopt it for customer trust, procurement acceleration, and GDPR Article 28 alignment. It mitigates PII risks, supports insurance, and differentiates in competitive markets via audited transparency.

Implementation Overview

Start with gap analysis on existing ISMS, update Statement of Applicability (SoA), policies, and contracts. Implement technical safeguards like encryption and logging. Suitable for CSPs of all sizes; requires accredited audits as ISO 27001 extension with annual surveillance.

ISO 28000 Details

What It Is

ISO 28000:2022 is the international standard titled Security and resilience — Security management systems — Requirements. It is a certifiable management system framework specifying requirements to establish, implement, maintain, and improve a security management system (SMS) focused on supply chain security risks. It employs a risk-based PDCA (Plan-Do-Check-Act) approach aligned with ISO 31000.

Key Components

Clauses 4–10: context, leadership, planning (risks/objectives), support (resources/competence), operation (controls/plans), performance evaluation, improvement.
Emphasizes risk assessment/treatment, supplier controls, security plans (response/recovery).
Built on holistic principles; supports integration with ISO 9001, 22301, 27001.
Certification via accredited bodies per ISO 28003.

Why Organizations Use It

Reduces supply chain disruptions, theft, compliance risks.
Meets contractual/partner demands, lowers insurance costs.
Enhances resilience, market access, stakeholder trust.

Implementation Overview

Phased: gap analysis, risk assessment, controls rollout, audits, certification.
Applicable to all sizes/industries with supply chains; 6–36 months typical.

Key Differences

Aspect	ISO 27018	ISO 28000
Scope	PII protection in public clouds for processors	Supply chain security management system
Industry	Cloud service providers, all sectors	Logistics, manufacturing, any supply chain
Nature	Voluntary code of practice, extends 27001	Voluntary certifiable management system
Testing	Assessed in ISO 27001 audits, annual surveillance	Stage 1/2 certification audits, surveillance
Penalties	Loss of alignment claim, no legal penalties	Loss of certification, no legal penalties

Scope

ISO 27018

PII protection in public clouds for processors

ISO 28000

Supply chain security management system

Industry

ISO 27018

Cloud service providers, all sectors

ISO 28000

Logistics, manufacturing, any supply chain

Nature

ISO 27018

Voluntary code of practice, extends 27001

ISO 28000

Voluntary certifiable management system

Testing

ISO 27018

Assessed in ISO 27001 audits, annual surveillance

ISO 28000

Stage 1/2 certification audits, surveillance

Penalties

ISO 27018

Loss of alignment claim, no legal penalties

ISO 28000

Loss of certification, no legal penalties

Frequently Asked Questions

Common questions about ISO 27018 and ISO 28000

ISO 27018 FAQ

ISO 28000 FAQ

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What It Is

Key Components

Approximately 25-30 additional privacy-specific controls mapped to ISO 27001 Annex A themes (organizational, people, physical, technological).

Core principles: consent/choice, purpose limitation, data minimization, transparency, accountability.

Built on ISO 27002 guidance; assessed during ISO 27001 audits, not standalone certification.

What It Is

Key Components

Clauses 4–10: context, leadership, planning (risks/objectives), support (resources/competence), operation (controls/plans), performance evaluation, improvement.

Emphasizes risk assessment/treatment, supplier controls, security plans (response/recovery).

Built on holistic principles; supports integration with ISO 9001, 22301, 27001.

Certification via accredited bodies per ISO 28003.

Aspect

ISO 27018

ISO 28000

Scope

PII protection in public clouds for processors

Supply chain security management system

Industry

Cloud service providers, all sectors

Logistics, manufacturing, any supply chain

Nature

Voluntary code of practice, extends 27001

Voluntary certifiable management system

Testing

Assessed in ISO 27001 audits, annual surveillance

Stage 1/2 certification audits, surveillance

Penalties

Loss of alignment claim, no legal penalties

Loss of certification, no legal penalties