Standards Comparison

    ISO 27018

    Voluntary
    2019

    Code of practice for PII protection in public cloud processors.

    VS

    U.S. SEC Cybersecurity Rules

    Mandatory
    2023

    U.S. SEC rules mandating cybersecurity incident and governance disclosures

    Quick Verdict

    ISO 27018 provides voluntary cloud PII processor controls globally, while U.S. SEC rules mandate rapid incident disclosures and governance reporting for public companies. Processors adopt ISO for certification; registrants comply to avoid SEC penalties and inform investors.

    Cloud Privacy

    ISO 27018

    ISO/IEC 27018:2025 Code of practice for PII in public clouds

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

    Key Features

    • Protects PII specifically for public cloud processors
    • Mandates sub-processor transparency and equivalent obligations
    • Requires prompt breach notification to controllers
    • Enforces secure PII deletion and return on termination
    • Extends ISO 27002 with cloud privacy implementation guidance
    Capital Markets

    U.S. SEC Cybersecurity Rules

    Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

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

    Key Features

    • Four-business-day material incident disclosure via Form 8-K Item 1.05
    • Annual cybersecurity risk management and governance in Regulation S-K Item 106
    • Inline XBRL tagging for machine-readable disclosures
    • Board oversight and management expertise disclosures
    • Third-party cybersecurity risk oversight processes

    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 clouds 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, sub-processor management, logging/auditability, breach notification, secure deletion.
    • Aligns with ISO/IEC 29100 privacy principles; adds ~25-30 cloud-PII controls to 93 ISO 27002 controls.
    • Certification via ISO 27001 audits with ISO 27018 extensions; three-year validity with annual surveillance.

    Why Organizations Use It

    • Meets processor obligations under GDPR-like laws; reduces procurement friction via audited transparency.
    • Enhances risk management for multi-tenant clouds; builds customer trust in PII handling.
    • Competitive edge for SaaS/cloud vendors; supports due diligence and contracts.

    Implementation Overview

    • Conduct gap analysis on existing ISO 27001 ISMS; update SoA, policies, controls.
    • Applies to cloud PII processors of all sizes; requires GRC tools, cloud monitoring.
    • External audits by accredited bodies; phased upgrades for 2025 edition.

    U.S. SEC Cybersecurity Rules Details

    What It Is

    U.S. SEC Cybersecurity Rules (Release No. 33-11216) are federal regulations amending Regulation S-K and Forms 8-K/10-K. They mandate standardized disclosures for public companies on cybersecurity incidents, risk management, strategy, and governance. The approach is materiality-based, aligning with securities law principles without bright-line thresholds.

    Key Components

    • **Form 8-K Item 1.05Four-business-day reporting of material incidents.
    • **Regulation S-K Item 106Annual disclosures on processes, impacts, board oversight, and management roles.
    • Inline XBRL tagging for comparability.
    • Applies to all Exchange Act registrants; no certification but ties to disclosure controls.

    Why Organizations Use It

    Public companies comply to meet legal obligations, protect investors via timely information, enhance capital market efficiency, and reduce enforcement risks like fines seen in Yahoo/Meta cases. Builds trust, integrates cyber into ERM, and signals governance maturity.

    Implementation Overview

    Cross-functional gap analysis, playbook development, process integration with IRP/DCP. Applies to domestic/foreign issuers; phased compliance (Dec 2023+). No external certification; SEC exams/enforcement verify.

    Key Differences

    Scope

    ISO 27018
    PII protection in public cloud processors
    U.S. SEC Cybersecurity Rules
    Public company cyber incident/governance disclosures

    Industry

    ISO 27018
    Cloud/SaaS providers processing PII globally
    U.S. SEC Cybersecurity Rules
    All SEC registrants, primarily U.S. public companies

    Nature

    ISO 27018
    Voluntary international code of practice
    U.S. SEC Cybersecurity Rules
    Mandatory SEC reporting regulation

    Testing

    ISO 27018
    ISO 27001 audits with 27018 controls
    U.S. SEC Cybersecurity Rules
    Internal disclosure controls, SEC review

    Penalties

    ISO 27018
    Loss of certification, no legal fines
    U.S. SEC Cybersecurity Rules
    SEC enforcement, civil penalties, injunctions

    Frequently Asked Questions

    Common questions about ISO 27018 and U.S. SEC Cybersecurity Rules

    ISO 27018 FAQ

    U.S. SEC Cybersecurity Rules FAQ

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