Standards Comparison

    ISO 27018

    Voluntary
    2019

    Code of practice for PII protection in public clouds

    VS

    MAS TRM

    Mandatory
    2021

    Singapore guidelines for technology risk management in finance.

    Quick Verdict

    ISO 27018 provides voluntary PII privacy controls for global cloud processors, extending ISO 27001. MAS TRM mandates technology risk governance for Singapore FIs, with supervisory enforcement. CSPs adopt 27018 for trust; FIs use TRM to avoid fines and ensure resilience.

    Cloud Privacy

    ISO 27018

    ISO/IEC 27018:2025 Code of practice for cloud PII

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • PII protection code for public cloud processors
    • Extends ISO 27001 with 25-30 privacy controls
    • Mandates subprocessor transparency and disclosure
    • Requires customer breach notification procedures
    • Prohibits PII use for marketing without consent
    Technology Risk Management

    MAS TRM

    MAS Technology Risk Management Guidelines (2021)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Board and senior management accountability for oversight
    • Proportional implementation based on risk profile
    • Third-party services risk assessment and monitoring
    • Defence-in-depth cyber resilience controls
    • Annual penetration testing for internet-facing systems

    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 an international code of practice extending ISO 27001 and ISO 27002 for protecting personally identifiable information (PII) in public clouds where providers act as PII processors. Its primary scope targets cloud-specific privacy risks like multi-tenancy and cross-border flows, using a risk-based approach integrated into an ISMS.

    Key Components

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

    Why Organizations Use It

    Drives procurement acceleration, regulatory alignment (e.g., GDPR Article 28), risk reduction, customer trust, and competitive differentiation for CSPs. Enhances cyber insurance and reduces questionnaire friction.

    Implementation Overview

    Conduct gap analysis against existing ISMS, update Statement of Applicability, implement controls like subprocessor disclosure. Suited for CSPs of all sizes; involves annual audits post-ISO 27001 certification.

    MAS TRM Details

    What It Is

    MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidance issued by the Monetary Authority of Singapore for financial institutions. They provide a principles-based, risk-proportional framework to govern technology and cyber risks, emphasizing governance, controls, and resilience to protect confidentiality, integrity, and availability (CIA).

    Key Components

    • 15 main sections covering governance, risk frameworks, secure development, IT operations, resilience, access controls, cryptography, cyber defense, testing, and audit.
    • Synthesized into 12 core principles like board accountability, asset management, third-party oversight, and layered defenses.
    • No fixed controls; proportional implementation with independent assurance.

    Why Organizations Use It

    • Mandatory for MAS-supervised FIs to avoid enforcement like fines or license actions.
    • Enhances cyber resilience, operational stability, and customer trust.
    • Supports digital transformation while managing ecosystem risks.

    Implementation Overview

    • Phased: governance setup, asset inventory, control design, testing, third-party assurance.
    • Targets Singapore FIs of all sizes; proportional to risk/complexity.
    • No formal certification; demonstrated via audits, metrics, board reporting.

    Key Differences

    Scope

    ISO 27018
    PII protection in public clouds for processors
    MAS TRM
    Technology/cyber risk across financial operations

    Industry

    ISO 27018
    All sectors, global CSPs and enterprises
    MAS TRM
    Singapore financial institutions only

    Nature

    ISO 27018
    Voluntary code of practice, ISO 27001 extension
    MAS TRM
    Supervisory guidelines, enforced via supervision

    Testing

    ISO 27018
    ISO 27001 audits include 27018 controls
    MAS TRM
    Annual PT for internet systems, regular VA/DR

    Penalties

    ISO 27018
    Loss of certification, market disadvantage
    MAS TRM
    Fines, license revocation, executive prohibitions

    Frequently Asked Questions

    Common questions about ISO 27018 and MAS TRM

    ISO 27018 FAQ

    MAS TRM FAQ

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