Trust
Control mapping for ISO/IEC 27701 and 27001
This document says which controls of ISO/IEC 27701 and ISO/IEC 27001 an organisation can cite filterit as evidence for, what exactly the product does for each one, where the evidence is, and what remains with the organisation. It is written from what the code and the deployment do, not from a template, and it claims neither compliance nor certification: filterit supports the documentation of the controls, it does not replace it.
Related: the technical and organisational measures (Article 32), pseudonymisation as a supplementary transfer measure, the incident process, the accuracy page and its method, the data processing agreement, the sub-processor list and the AI transparency notice.
1. What this is and what it is not
filterit is one technical measure in one processing activity: the use of external artificial intelligence tools by staff. It detects personal data in text before the text leaves for the model provider, replaces it with placeholders, keeps the mapping encrypted under the organisation's control, and records every send in a log that holds no personal data.
The management system, which is what the two standards are about, belongs to the organisation: policies, roles, training, risk assessment, internal audit and management review. A mapping table shows where a technical measure provides evidence for a control. It does not show that the control is fully implemented.
Three limits, so that an auditor does not have to discover them:
- Detection is probabilistic. What is measured, how, and what is left out is on the accuracy page and in its method. Every row below that says "pseudonymises" means "pseudonymises what it detects".
- The operator of filterit holds no ISO/IEC 27001 or 27701 certification (section 10 of the technical and organisational measures). This document does not change that fact.
- This document is not legal advice and has not been reviewed by a certified auditor (section 6).
2. Which edition of the standards
The tables follow the numbering of ISO/IEC 27701:2019 (clause 7 for PII controllers, clause 8 for PII processors, which correspond to Annexes A and B of the standard) and of ISO/IEC 27001:2022, Annex A.
ISO/IEC 27701:2025 has been certifiable on its own since October 2025 and has a different structure and numbering. The table will be updated in a later version of this document with that numbering. Until then, an organisation working with the 2025 edition uses the control titles, which survive as concepts, rather than the numbers.
Only control numbers and titles are cited. The text of the requirements is the intellectual property of ISO and is not reproduced.
3. For PII controllers (ISO/IEC 27701:2019, clause 7)
For the organisation that uses AI tools for its own purposes. The columns: what filterit does, where the evidence is, what remains with the organisation.
| Control | What filterit does | Where the evidence is | What remains with the organisation |
|---|---|---|---|
| 7.2.5 Privacy impact assessment | Provides the description of the flow, the measures and the measured residual risks an impact assessment needs (Article 35 GDPR). | DPIA template per deployment tier, on request; the accuracy page for the residual. | Whether an assessment is needed, carrying it out, the DPO's opinion. |
| 7.2.8 Records related to processing PII | Provides a filled-in example entry for the record of processing activities (Article 30) for the use of AI tools with pseudonymisation. The Evidence Pack records the categories of data detected in the period, as counts per category. | ROPA entry template, on request; the "GDPR Art. 30" section of the Evidence Pack. | Keeping the record, and the organisation's other activities. |
| 7.3.6 Access, correction and/or erasure | Search of the encrypted vault by a person's name without the query reaching the database in clear text (HMAC digests), export and erasure of every entry about that person, deletion of a conversation, export and deletion of a whole account. | Vault search (POST /api/v1/vault/search), export and erasure per person (/api/v1/vault/subject/export, /erase), conversation deletion, account export and deletion (/api/v1/account). |
Receiving and answering the request, verifying the requester, the deadlines. |
| 7.3.8 Providing copy of PII processed | The per-person export returns the decrypted values and their placeholders in a machine-readable form, only to an owner or administrator of the workspace. | /api/v1/vault/subject/export (Articles 15 and 20). |
Completing it with what the organisation holds outside filterit. |
| 7.3.9 Handling requests | The same tool serves preview (export) and confirmation (erase) for the same query, so the operator sees what will be erased before erasing it. | The same per-person route. | The procedure and the register of requests. |
| 7.4.1 Limit collection | The category catalogue defines what is detected. An organisation sets mandatory categories in its masking policy, which no user can switch off. | The catalogue of 34 categories on the accuracy page; the per-organisation masking policy (mandatory categories, minimum detection level, minimum confidence). | Which categories are mandatory and why. |
| 7.4.2 Limit processing | What leaves for the model provider is the text with placeholders in place of what was detected. When detection is unavailable, the text does not leave (refusal rather than leak). | Section 4 of the technical and organisational measures; the "GDPR Art. 25" section of the Evidence Pack. | The purpose of each use and the instruction to staff. |
| 7.4.4 PII minimization objectives | The model receives the structure and the meaning of the text, not the identity of the persons detected. The mapping stays with the organisation. | The "A.5.34 / Art. 5(1)(c) data minimisation" row of the Evidence Pack's control matrix. | The organisation's measurable minimisation objectives. |
| 7.4.5 PII de-identification and deletion at the end of processing | Pseudonymisation before transfer: placeholders to the provider, the mapping encrypted with AES-256-GCM under a key that does not leave the organisation or the operator. The mapping is deleted automatically 30 days after it is created. | Section 2 of the technical and organisational measures; the "ISO/IEC 27701" section of the Evidence Pack; section 7 of the privacy policy. | Saying that this is pseudonymisation, not anonymisation, and handling the indirect identifiers that remain in free text. |
| 7.4.6 Temporary files | Uploaded files and scans stay in temporary storage for at most 30 minutes (10 minutes for visual-redaction originals) and are never written to the database. | Section 3 of the technical and organisational measures. | Temporary files on its own devices. |
| 7.4.7 Retention | One retention table per kind of data, the same one the data processing agreement refers to: vault 30 days, temporary files 30 minutes, logs 7 and 30 days, backups 14 days. | Section 7 of the privacy policy. | Its own deadlines for the case or client file. |
| 7.4.8 Disposal | Vault deletion is a daily automatic job; account deletion immediately removes the profile, conversations, vault entries, projects and connections. | Section 7 of the privacy policy; section 11 of the data processing agreement. | The deletion confirmation in its own register. |
| 7.4.9 PII transmission controls | TLS on every external connection; pseudonymisation before transmission to the model; the desktop agent opens only the connections to known AI tools and refuses the ones it cannot cover. | Section 2 of the technical and organisational measures; the agent's AI tools catalogue. | Its network and devices. |
| 7.5.1 Identify basis for PII transfer between jurisdictions | Standard contractual clauses with the model provider and pseudonymisation as a supplementary measure (EDPB Recommendations 01/2020, use case 2). | Pseudonymisation as a supplementary transfer measure; section 7 of the data processing agreement; sub-processor list. | Its own transfer impact assessment. |
| 7.5.3 Records of transfer of PII | Every send to an external model leaves one row free of personal data (destination, size, SHA-256 digest, masked preview), linked to the previous row in a hash chain. | Egress log; section 8 of the technical and organisational measures; chain verification inside the Evidence Pack. | Keeping the exports and reviewing them periodically. |
| 7.5.4 Records of PII disclosure to third parties | The public list says which third party receives what; the egress log says when and how much. | Sub-processor list; egress log. | Third parties outside filterit. |
4. For PII processors (ISO/IEC 27701:2019, clause 8)
For the filterit customer that is itself a processor for its own clients (an accounting firm, a law firm, a software vendor) and needs to show the controller what it does with the controller's data when it uses AI tools.
| Control | What filterit does | Where the evidence is | What remains with the processor |
|---|---|---|---|
| 8.2.1 Customer agreement | filterit's data processing agreement is public and hashed on acceptance; the processor can attach it to its own Article 28 contract as the sub-processor's terms. | Data processing agreement; annex of technical and organisational measures for processors, on request. | Its own Article 28 contract with the controller. |
| 8.2.2 Organization's purposes | Content that passes through filterit is used for no purpose other than the service: not for model training, not for advertising. | Section 3 of the data processing agreement; AI transparency notice. | Following the controller's instructions in its own uses. |
| 8.2.6 Records related to processing PII | The Evidence Pack for the period: counts per category, sends, chain integrity, control mapping, signed. | Evidence Pack (JSON and PDF); its "GDPR Art. 30" section. | The record per controller. |
| 8.4.1 Temporary files | As 7.4.6: at most 30 minutes, never in the database. | Section 3 of the technical and organisational measures. | Its own devices. |
| 8.4.2 Return, transfer or disposal of PII | Export of the account's data in a machine-readable form and deletion at the end; account deletion removes immediately. | Section 11 of the data processing agreement; /api/v1/account/export, DELETE /api/v1/account. |
Return to the controller through its own procedure. |
| 8.4.3 PII transmission controls | As 7.4.9. | Section 2 of the technical and organisational measures. | Its network. |
| 8.5.1 Basis for PII transfer between jurisdictions | As 7.5.1, from the processor's side: the model provider receives placeholders, the mapping stays inside the EEA. | Pseudonymisation as a supplementary transfer measure; section 7 of the data processing agreement. | Disclosing the transfer to the controller. |
| 8.5.3 Records of PII disclosure to third parties | Hash-chained egress log, as 7.5.3. | Section 8 of the technical and organisational measures; Evidence Pack. | Making it available to the controller on request. |
| 8.5.6 Disclosure of subcontractors used to process PII | The sub-processor list is public, with each one's role, place of processing and transfer mechanism, and the data processing agreement defines the notice for changes. | Sub-processor list; section 5 of the data processing agreement. | Its own list of subcontractors, with filterit on it. |
5. ISO/IEC 27001:2022, Annex A
The 27001 controls that 27701 inherits. The first four rows are the rows of the control matrix that every Evidence Pack contains (column "What the Evidence Pack says", in the pack's own words), so that the page and the pack say the same thing.
| Control | What filterit does | Where the evidence is | What the Evidence Pack says |
|---|---|---|---|
| A.8.11 Data masking | Pseudonymisation with placeholders before the send, the mapping in an AES-256-GCM vault, an egress log without values. | Section 2 of the technical and organisational measures; accuracy page. | "AES-256-GCM token vault; egress ledger records masked-only, PII-free event rows." |
| A.8.12 Data leakage prevention | Only placeholders reach the AI provider for what was detected; the send is refused when detection is unavailable; on the agent, tools that cannot be covered are denied. | Section 4 of the technical and organisational measures; the "GDPR Art. 25" section of the Evidence Pack. | "PII pseudonymised before egress; only tokens reach the AI provider (zero plaintext)." |
| A.8.15 Logging | A hash-chained egress log, free of personal data, verifiable offline; an administrator action log. | Section 8 of the technical and organisational measures; verification inside the Evidence Pack. | "Hash-chained, PII-free audit ledger, re-verifiable offline against tampering." |
| A.5.34 Privacy and protection of PII | A masking policy per organisation: mandatory categories, minimum detection level, textual and optical strategy. | The organisation's masking policy screen; the "DPIA support" section of the Evidence Pack. | "Per-tenant policy: mandatory entity types, detection-depth floor, optical/textual strategy." |
| A.5.12 Classification of information | The catalogue's 34 categories are a ready classification of the identifiers detected, with the written forms per country. | Accuracy page, categories section. | Not part of the pack. |
| A.5.19 Information security in supplier relationships | filterit is the supplier: public measures, incident process, data processing agreement, sub-processor list, and an AI supplier assessment sheet for the organisation's own providers. | This page and the trust page; assessment sheet, on request. | Not part of the pack. |
| A.5.23 Information security for use of cloud services | The desktop agent's AI tools catalogue: which tools are covered, which ones the organisation switches off, and the "not allowed" choice that refuses the connection instead of leaving it uncovered. | The agent's AI tools catalogue (per-account setting); AI acceptable use policy template, on request. | Not part of the pack. |
| A.8.10 Information deletion | Retention with deadlines and automatic deletion; deletion per person, per conversation, per account. | Section 7 of the privacy policy; 7.3.6 above. | Not part of the pack. |
| A.8.24 Use of cryptography | AES-256-GCM on the vault and on content, independently derived keys, HMAC-SHA256 for search, TLS in transit, encrypted backups. | Section 2 of the technical and organisational measures. | The "GDPR Art. 32" section of the pack. |
The Evidence Pack is the signed pack for a period that an organisation exports from filterit: statistics per category, sends, chain verification, the control matrix and the narrative sections. In the hosted service it is sealed with an HMAC, on the device with an Ed25519 signature, and every pack can be verified again later. A pack exported before this document was published verifies as it did before.
What is not cited as evidence, because it ships switched off in the product: row-level restriction in the database, the policy engine, session-scoped restore and the second version of the encryption envelope. An organisation that turns them on in its own deployment documents them itself.
6. What remains open and who confirms it
- The tables have not been reviewed by a certified auditor or a third-party DPO. Until they are, the mapping is the reading of the standards by the team that wrote the code, and the organisation verifies it with its own auditor. When reviewed, this section will say by whom and when.
- The numbering of the 2025 edition of ISO/IEC 27701 is not included (section 2).
- Our own certification: none, as section 10 of the technical and organisational measures says.
- The templates cited as "on request" (Statement of Applicability excerpt, AI acceptable use policy, AI supplier assessment sheet, ROPA entry, DPIA, annex of measures for processors) are available from contact@filterit.ai, like the operator's legal identity.
7. Review
This document is reviewed at least once a year, after any material change to the product, and when the edition of the standards it uses changes. Its version and date are at the top; the change history is in the repository.
| Version | Date | Change |
|---|---|---|
| 1.0 | 2026-10-14 | First published version, with the numbering of ISO/IEC 27701:2019 and ISO/IEC 27001:2022. |