ISO 27001 & 27701 KVK/GDPR Mapping Guide

Asset Inventory and Data Categories

The foundation of ISO 27001 and ISO 27701 compliance is the accurate preparation of an asset inventory. This includes not only technical assets (servers, applications, network devices) but also data assets. Under KVKK and GDPR, categorizing personal data is critical.

Classification of data categories

• Ordinary personal data: Name, surname, address, email.
• Special categories: Health information, biometric data, religious beliefs.
• Technical data: IP addresses, log records, device identifiers.

Integration

The ISO 27001 asset inventory must be integrated with ISO 27701 data processing registers. This table ensures traceability of each asset from both a security and privacy perspective.

Risk Methodology and Control Selection

Under ISO 27001, identifying and managing risks is essential. ISO 27701 extends this approach to include privacy risks. KVKK and GDPR also require a Data Protection Impact Assessment (DPIA).

Risk assessment steps

• Identify threats: Data leakage, unauthorized access, data deletion.
• Impact: High, medium, low impact levels.
• Likelihood: Probability of recurrence.
• Risk value: Impact × Likelihood.

Control selection

Controls from ISO 27001 Annex A and additional privacy controls from ISO 27701 must be applied to relevant risks. These must be mapped to KVKK/GDPR articles.

Adding PIMS Requirements

ISO 27701 extends ISO 27001 by introducing Privacy Information Management System (PIMS) requirements. This ensures data is managed with a focus on privacy.

Core PIMS components

• Data subject rights: Managing requests for access, rectification, erasure.
• Lawfulness of processing: Documenting legal bases (consent, contract, legal obligation).
• Transparency: Preparing and publishing privacy notices.
• Third-party collaboration: Ensuring privacy obligations are included in contracts.

Mapping with KVKK/GDPR

PIMS requirements from ISO 27701 must be aligned with GDPR provisions and KVKK principles for full compliance.

Supplier/SaaS Contract Clauses

Compliance with ISO 27001 and 27701 must extend beyond internal processes to cover suppliers and SaaS services. Contract clauses must align with GDPR and KVKK.

Mandatory contract clauses

• Processing conditions: Processing must only be done under written instructions.
• Use of sub-processors: Prior approval from the customer is required.
• Security measures: Controls must align with ISO 27001 Annex A.
• Data retention and deletion: Data must be deleted immediately after contract termination.
• Audit rights: The customer must have the right to audit and review.

Incident Response and Notification Periods

An effective incident response plan is essential under ISO 27001 and 27701, and directly aligns with GDPR/KVKK obligations regarding notification deadlines.

Key phases of incident response

• Detection: Identification of suspicious activity via monitoring systems.
• Analysis: Confirming whether personal data has been affected.
• Containment: Limiting the impact of the incident.
• Eradication: Removing root causes such as malware or misconfiguration.
• Recovery: Restoring systems and validating integrity.

Notification periods

• GDPR: Data breaches must be reported to the supervisory authority within 72 hours.
• KVKK: Data breaches must be notified to the Turkish Data Protection Authority and affected individuals without delay.

Recordkeeping and Evidence Management

ISO 27001 and 27701 require that all processes are documented and traceable. GDPR and KVKK also mandate recordkeeping as proof of compliance.

Required records

• Records of processing activities (RoPA).
• Data subject requests and responses.
• Incident logs and corrective actions.
• Training participation and awareness campaigns.

Evidence management

Evidence must be collected in a way that ensures authenticity, integrity, and accessibility. This may include electronic signatures, immutable logs, and secure archiving solutions.

DPO Role and Reporting

Under ISO 27701 and GDPR, the Data Protection Officer (DPO) is the independent role overseeing personal data processing activities. In Turkey, while not mandatory under KVKK, it is considered best practice for large organizations.

DPO responsibilities

• Monitoring compliance with GDPR and KVKK.
• Providing regular reports to top management.
• Handling data subject requests.
• Reviewing Data Protection Impact Assessments (DPIAs).
• Acting as a contact point with supervisory authorities.

Reporting process

• Monthly: Subject access requests, incident reports, training statistics.
• Quarterly: Risk and control status, DPIA results, supplier audits.
• Annually: Overall compliance report and management review.

Audit Trails: Log Requirements

Audit trails are a cornerstone of proving compliance. ISO 27001 and ISO 27701 require logging for both security and privacy-related activities.

Mandatory log types

• Access logs: Who accessed what data and when.
• Authorization logs: Role changes and privilege management.
• System events: Server restarts, patching activities.
• Incident detection logs: IDS/IPS, DLP, SIEM outputs.

Log management principles

• Logs must be stored in a tamper-proof format (e.g., WORM, digital signatures).
• Centralized management should be ensured via SIEM solutions.
• Personal data in logs should be masked or anonymized.
• Logs must be retained for a minimum of 2–3 years.

Gap Analysis Template

A gap analysis allows organizations to compare their current state with the requirements of ISO 27001 & 27701 and GDPR/KVKK, identify deficiencies, and prepare an action plan.

Gap analysis steps

• Identify current state: Policies, procedures, and controls.
• Map requirements: ISO 27001 and ISO 27701 controls.
• Align with GDPR/KVKK: Match to corresponding legal articles.
• Assess compliance: Implemented, partially implemented, or not implemented.
• Action plan: Assign responsibilities and timelines.

Documentation with a table

Training and Awareness Campaign

The sustainability of ISO 27001 & 27701 compliance depends not only on technical controls but also on strengthening the human factor. Therefore, training programs and awareness campaigns are key to building a culture of data protection.

Training program

• Mandatory onboarding: Training new employees on GDPR/KVKK principles and information security.
• Annual refreshers: Reviewing legal updates, emerging risks, and updated policies.
• Role-based training: Specialized modules for DPO, IT, legal, and operations teams.
• Practical exercises: Phishing simulations, incident response drills, data breach scenarios.

Awareness campaigns

Awareness should not be limited to formal training but integrated into daily activities:

• Internal newsletters with quick tips.
• Posters and digital displays.
• Short videos and interactive quizzes.
• Dedicated events such as “Data Privacy Week.”

Measurement and monitoring

The effectiveness of training must be measured through KPIs:

• Training participation rates.
• Knowledge test results.
• Phishing simulation response metrics.

Auditors expect these indicators to be included in compliance reports.