A control and evidence checklist for public cloud PII processor operations.
Use it for gap assessment, procurement preparation, and internal audit readiness.
Structured answer sets in this page tree.
Cited legal and guidance references.
ISO/IEC 27018 is most useful when each privacy control is tied to a contract commitment, an operating procedure, and a record you can actually produce during a customer review. This checklist focuses on the highest value processor controls and the evidence that proves they are not just policy text.
For every control area, collect three things: the contractual commitment, the operating method, and a live evidence sample. If any one of those is missing, the control will be weak under review.
Run the checklist service by service, because processor boundaries and subprocessor use often vary between products.
Assessment Autopilot can take ISO 27018 Privacy Control Checklist from turning this checklist into an operational workflow to a reusable workflow inside Sorena. Teams working on ISO 27018 can keep owners, evidence, and next steps aligned without copying this guide into separate documents.
Start from ISO 27018 Privacy Control Checklist and turn the guidance into owned tasks, evidence requests, and review checkpoints.
Review your current process, evidence gaps, and next steps for ISO 27018 Privacy Control Checklist.
Verify that the service is operating as a public cloud PII processor and not quietly expanding into controller style reuse of customer data. Confirm that the customer instruction boundary is clear enough to govern purpose, timing, and method.
This is the foundation for every downstream control.
Check that contracted PII is not used for independent purposes. Check separately that marketing or advertising use is either absent or supported by express consent that is not required to receive the service.
This control should be reviewed with product, growth, and analytics teams, not only legal.
Review whether subprocessor use is disclosed before use, whether changes trigger timely notice, and whether the register includes the countries where data can be processed or stored.
Do not forget backup, support, and infrastructure subprocessors.
Check whether the provider can distinguish legally binding requests from informal requests, whether customer consultation is built into the runbook where lawful, and whether all disclosures are recorded with the source of the request and the source of authority.
This is one of the easiest controls to test because the evidence trail should be explicit.
Check whether the contract defines maximum notification delay and required fields, and whether incident records are detailed enough for customer legal assessment.
A simple ticket summary is rarely enough.
Check whether the disposal policy covers return, transfer, deletion, destruction, anonymization, and archiving. Check whether the policy and contract explain how PII is erased from backup and business continuity environments.
Deletion claims should always name the mechanism or standard used.
The standard expects criteria for how logs can be made available to customers, deletion of logged information within a specified and documented period, and periodic deletion of aged temporary files that are no longer needed.
It also recommends a minimum five year retention period for current and historical policies and procedures when no stricter requirement applies.
Check whether the service can satisfy customer review without unsafe direct inspection of multi-tenant systems. The standard expressly contemplates independent evidence where individual audits are impractical or increase risk.
This evidence model should be prepared before large customers ask for it.