ISO Regulations and Data Security, Privacy

ISO standards do not typically mandate specific legal disclosures of third parties with whom companies exchange end-user and sensitive data. However, ISO standards provide frameworks for information security management and data protection, and some sections can be interpreted to imply the need for third-party risk management and disclosure practices.

Here are key ISO standards related to third-party data exchange:

1. ISO/IEC 27001: Information Security Management Systems (ISMS)

- Clause 6.1.4: Information security risk assessment: Requires companies to identify risks related to third-party data exchanges and ensure appropriate controls are in place.

- Clause 8.2: Information security risk treatment: Involves implementing measures for handling risks, including those related to third-party vendors.

- Annex A.15: Supplier Relationships:

- A.15.1.1: Information security policy for supplier relationships: Requires companies to establish policies to ensure the protection of sensitive information when shared with third parties.

- A.15.2.1: Monitoring and review of supplier services: Calls for organizations to monitor third-party services and ensure they meet security requirements.

2. ISO/IEC 27002: Code of Practice for Information Security Controls

- Clause 15: Supplier Relationships: Offers guidance on managing supplier agreements and ensuring data exchanged with third parties remains secure, which indirectly implies keeping a catalog of such data exchanges.

3. ISO/IEC 27701: Privacy Information Management System (PIMS)

- Built on top of ISO/IEC 27001, this standard is focused on privacy management.

- Clause 7.2.1: Communication of privacy information: Requires organizations to communicate with data subjects about how their data is processed, including whether third parties are involved.

- Clause 6.2: Processor obligations: Relates to how companies using third parties (data processors) handle personal data, including potential disclosure of which third parties are involved in processing the data.

4. ISO 37301: Compliance Management Systems

- This standard outlines general compliance management, which may include policies for regulatory compliance regarding third-party data exchanges.

- Clause 8.5.2: Third-party due diligence: Requires companies to perform due diligence on third parties involved in sensitive data processing, which could involve disclosure requirements as part of compliance activities.

While ISO standards do not explicitly require disclosures to external parties, they provide a framework for managing third-party risks and ensuring compliance with relevant data protection laws (e.g., GDPR, CCPA) that may mandate such disclosures.

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