ISO/IEC 27018
ISO/IEC 27018 public-cloud personal data protection implementation
ISO/IEC 27018 consulting helps personal data processors in public cloud services organise protection measures. Vosurein reviews data uses, processing agreements and service workflows to clarify responsibilities and evidence for access, subprocessors and service termination.
Discuss ISO/IEC 27018 public cloud personal data protection consulting
For Your Business
Who this service is for and when to start
For public cloud providers that process personal data on behalf of customers, and corporate teams assessing those services. Review responsibilities and controls before new service designs, contract renewals or changes to data flows or subprocessors.
The Challenge
Common challenges faced by businesses
The same organization may play different roles in different activities and should not hand over all personal data responsibilities to the platform just because it uses the cloud. If processing instructions and data usage are unclear, it is also difficult to determine whether the control measures are appropriate.
After the service ends, whether data return and deletion include backups, subcontractors, and records is a practical issue that needs to be discussed in advance.
Our Approach
Methods and applicable requirements
ISO/IEC 27018:2025 provides guidelines for public cloud service personal data protection for personal data processors, aligned with ISO/IEC 27002:2022. Personal data controllers may still have additional legal obligations and cannot claim full compliance solely based on the implementation of this standard.
The priorities below depend on the organisation’s context. Confirm the scope and level of supporting evidence at the start.
Processing Responsibility
Confirm the purpose, instructions, and contractual division of various types of data, clearly distinguish different roles, and retain the processing approach when going beyond the scope of commissioning.
Personal Data Control
Check whether personnel access, disclosure, and processing records can support traceability; data protection measures should align with actual processes.
External Cooperation
Organize subcontracting targets, information provision, and audit arrangements, and confirm how new or changed supplier relationships are notified and handled.
Service Termination
Plan data return, deletion, and related evidence, clearly explain preservation conditions and technical limitations, avoiding vague promises of immediate total deletion.
Process
Consulting scope and process
Confirm Data and Roles
Review the service scope, data categories and contractual relationships to distinguish processing responsibilities.
Review Protection Gaps
Compare contracts, processes, and access arrangements, and organize the controls and evidence that need to be supplemented.
Pilot operational handovers
Test departmental handover through data requests or service termination scenarios, checking whether processing can be done according to the agreement.
Establish Continuous Review
Review changes to subprocessors, services and standard editions, and track unresolved issues.
Preparation
What documents do companies need to prepare?
- Data and flows: Summary of personal data categories, processing activities, and flow directions.
- Data processing agreement: Handling instructions, responsibilities, and storage conditions.
- Access and collaboration: Access permissions, subprocessors and related control records.
- Service termination process: Methods for return, deletion, and proof.
An index or summary is enough for an initial discussion. Before sharing personal data, confidential contract information or system records, agree on access authorisation, redaction and retention.
Project Planning
Estimating time and cost
We assess scope by service numbers, data flows, subprocessor tiers and the depth of control review. Final legal drafting, system modifications and performing deletions require separate agreement; they are not included in management system consulting by default.
FAQ
Frequently asked questions
Does it cover all personal data activities of the enterprise?
No. This section focuses on public cloud personal data processors; other roles and legal obligations still need to be confirmed separately.
Can customers using the cloud also refer to this?
Yes. It can help customers understand a provider’s safeguards. They still need to review their own responsibilities as a controller or in other roles.
How should we move from an earlier edition to the 2025 edition?
First, confirm the original controls, services, and records, then check for differences based on the official version. Don't just change the document cover year.
Can data deletion be guaranteed to be completed immediately?
Confirm feasibility of the arrangement based on actual system and backup and storage conditions, and truthfully explain the scope of application.
Is this equivalent to legal compliance?
It cannot be directly equated. Legal application and contract terms must be determined separately based on the data, region, and role.
Can it be integrated with ISO/IEC 27701?
Appropriate data and processes can be shared, but it is important to confirm each standard and actual management scope; do not let one replace all work.
Related
Related services and enquiries
Tell us your industry, the activities you want to improve, your existing system and your target completion date so we can define the scope together.
Content checked: . Applicable versions and requirements depend on the company’s circumstances.
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