In an era where organizations increasingly rely on the cloud to manage sensitive information, protecting personal data is no longer just a best practice—it’s a business imperative. ISO/IEC 27018 steps in as a purpose-built privacy standard designed to help public cloud service providers handle personally identifiable information (PII) responsibly and transparently. Focused on real-world challenges like data access, consent, and breach notification, this standard extends ISO/IEC 27001 with targeted privacy controls. In this post, we’ll unpack what ISO 27018 is, how it aligns with broader security frameworks, and why it matters for organizations aiming to build trust and meet regulatory demands in the cloud.
What is ISO/IEC 27018?
The goal of ISO/IEC 27018 is to protect cloud-based PII by promoting transparency, accountability, and control over data processing. Specifically, it aims to:
- Help cloud providers implement consistent data protection policies
- Ensure users are informed of how their data is handled and processed
- Address risks unique to cloud environments, such as multi-tenancy and jurisdictional data transfers
- Support compliance with data protection laws like the GDPR and HIPAA
Can You Be Certified to ISO 27018?
Yes, although not independently. ISO/IEC 27018 is a code of practice and is typically audited as an extension of ISO/IEC 27001. Organizations first need to establish and certify an ISO 27001-compliant Information Security Management System (ISMS). Once that’s in place, an accredited auditor can assess the implementation of ISO 27018.
Many cloud providers describe themselves as “ISO/IEC 27018 certified,” which typically means they’ve passed an audit confirming that their privacy controls conform to the standard when layered over ISO 27001.
How ISO 27018 is Different from ISO 27001
While ISO/IEC 27001 establishes the foundation for managing information security, ISO/IEC 27018 builds upon it with privacy-specific enhancements tailored for cloud environments.
Key differences include:
- ISO 27001 covers general information security risks applicable to all organizations.
- ISO 27018 focuses exclusively on PII in public cloud settings.
- ISO 27018 introduces privacy-specific controls such as consent, deletion, transparency, and breach notification.
- ISO 27001 certification is standalone, while ISO 27018 certification is an extension.
How Many Controls Are in ISO 27018?
ISO/IEC 27018 does not replace the 114 Annex A controls found in ISO/IEC 27001. Instead, it adds a focused set of approximately 25–30 privacy-specific controls.
These additional controls cover areas such as:
- Consent for data processing
- Return, transfer, or deletion of data upon contract termination
- Restrictions on using PII for advertising
- Transparency around subcontractor relationships and cross-border data flows
- Logging and breach notification protocols
What Is the Latest Version of ISO 27018?
As of mid-2025, the most recent version of ISO/IEC 27018 is ISO/IEC 27018:2019. This version reflects modern privacy expectations and aligns more closely with global data protection regulations, such as the GDPR. Updates may follow changes to related standards such as ISO 27001:2022, but the 2019 version remains the current authoritative release.
What Are the Requirements of ISO 27018?
To conform with ISO 27018, organizations must demonstrate:
- Clear policies for the collection, use, and deletion of PII
- Processes to obtain and document customer consent
- Mechanisms to notify customers in the event of a data breach
- Transparent documentation regarding where and how data is processed
- Controls that ensure subcontractors meet equivalent data protection standards
- Logging of access to PII to support audits and accountability
What Are the Benefits of ISO 27018?
Organizations that implement ISO/IEC 27018 can expect several strategic advantages:
- Increased customer trust due to demonstrated privacy stewardship
- Competitive differentiation in a crowded cloud services market
- Improved legal compliance, especially with stringent regulations like GDPR
- Enhanced incident response capabilities for managing breaches
- More efficient data lifecycle management and internal governance
What Is the Cost of ISO 27018 Certification?
The cost to achieve ISO 27018 compliance varies based on company size, existing certification status, and the complexity of data handling processes.
Estimated costs include:
- Starting at around $20,000 for small to midsize firms starting from scratch
- Starting at around $10,000 if already ISO 27001 certified
- Ongoing surveillance audits incur annual fees
Combining ISO 27018 with an ISO 27001 certification effort is often more economical and efficient.
Practical Scenarios: Why ISO 27018 Matters
ISO/IEC 27018 becomes most powerful when you look at how it applies in everyday business situations. Below are examples of where certification provides real protection and peace of mind.
Healthcare SaaS Provider
A cloud-based medical records platform needs to comply with HIPAA. ISO 27018 ensures patient data is collected with consent, stored securely, and deleted when no longer needed.
What could happen without it? A breach exposing sensitive health histories could bring lawsuits, fines, and loss of patient trust.
HR & Payroll Platform
A global HR service provider stores sensitive employee details such as bank accounts and tax IDs. ISO 27018 requires clear processes for returning or deleting this data when contracts end.
What could happen without it? Old employee records could linger in the system and be exposed, creating liability for both provider and client.
Marketing Automation Company
A platform analyzing customer buying behavior must avoid reusing PII for its own marketing. ISO 27018 prevents the secondary use of data without consent.
What could happen without it? Clients may discover their customer data was used for unrelated advertising, triggering GDPR penalties and reputational harm.
Cloud Service with EU Customers
A U.S.-based cloud vendor stores European user data. ISO 27018 enforces transparency on subcontractors and international transfers.
What could happen without it? Regulators could fine the client for unlawful data transfers, even if the issue originated with the cloud vendor.
High-Growth SaaS Startup
A young company wants to win contracts with large enterprises. ISO 27018 provides documented assurance of strong privacy controls, which procurement teams look for.
What could happen without it? Deals may be lost to competitors who can demonstrate recognized certifications.
Taking the Next Steps with ISO 27018 Implementation
As organizations increasingly migrate operations to the cloud, protecting personal data becomes a defining factor in maintaining customer loyalty and meeting legal obligations. ISO/IEC 27018 provides a structured, internationally recognized approach to cloud privacy. It empowers cloud service providers to demonstrate trustworthiness while aligning with evolving global data protection standards.
Whether you’re beginning your compliance journey or extending your existing ISO 27001 certification, implementing ISO 27018 is a strategic investment in both security and transparency. If you are interested in learning more, reach out to our knowledgeable partners here at Linford & Company, as Linford & Co LLP is an accredited firm, and its partners working on ISO engagement are certified and trained to handle your certification desires efficiently and effectively.
Rhonda is a Partner at Linford & Co. delivering risk services including service organization control (SOC) engagements, and Internal Audit services (IT and Business process audits). Rhonda has her CPA, CISSP, PMP, and CISA certifications and delivers leading-edge client service. Previously, Rhonda was a Managing Director at Deloitte, and brings a wealth of expertise in the areas of risk management and compliance.