ISO 27001 for GDPR and CCPA: Informational Overview for SMEs and Startups (2026 Edition)

For SMEs and startups exploring international markets in 2026, ISO 27001 may serve as a foundational security framework that complements privacy management objectives. The GDPR (General Data Protection Regulation) is a European Union law that sets rules for collecting, processing, and safeguarding personal data, while the CCPA (California Consumer Privacy Act) grants privacy rights and data protection for California residents.

This guide outlines commonly referenced practices and illustrative examples to help organisations identify potential privacy gaps, map relevant security controls, and adopt data protection practices that are consistent with international expectations. It also highlights common scenarios and artefacts that SMEs and startups may consider when aligning security measures with global privacy frameworks.

ISO 27001 for International Privacy Compliance

Expanding into EU or US markets can introduce additional compliance requirements that may slow growth. Many SMEs find it challenging to address GDPR and CCPA obligations separately.

A structured ISO 27001 Information Security Management System (ISMS) may address certain privacy-related security considerations across both jurisdictions.

For example, certain Annex A controls – such as A.5.34 (Privacy and Protection of PII) and A.5.31 (Legal, statutory, regulatory and contractual requirements) – support alignment with GDPR and CCPA expectations by helping organisations identify and document the legal and regulatory themes relevant to personal data. Implementing such ISO 27001 controls may help support organisations in organising privacy-related security activities as a core part of their security framework, rather than as a separate, manual task.

Why ISO 27001 Supports GDPR and CCPA

ISO 27001 focuses on securing information, while privacy laws regulate how personal data is collected, processed, and protected. For SMEs and startups, combining these frameworks may support a structured approach to managing personal data across multiple jurisdictions.

• GDPR (Article 32): Refers to “appropriate technical and organisational measures” to protect personal data. ISO 27001 is widely recognised as a framework that may help organisations demonstrate these security practices in the context of information security management.
• CCPA / CPRA: Outlines privacy rights for California residents and refers to potential damages in certain instances where personal data is exposed due to inadequate security (Civil Code s1798.81.5). Implementing ISO 27001 alongside controls such as the CIS Critical Security Controls may assist organisations in documenting security practices that are often referenced in reasonable security discussions.
  

Annex A (2022) Controls: Privacy Mapping Table

The following table illustrates how selected ISO/IEC 27001:2022 controls may align with GDPR and CCPA considerations, along with practical tips and example artefacts that SMEs and startups can reference.

5 Practical Steps to Build Your Privacy Framework

To help SMEs and startups align their information security practices with GDPR and CCPA, the following five steps describe common organisational practices observed in SMEs and startups. Note that these steps are may not be exhaustive or universally applicable.

Step 1: Expand Your Data Map

• Track where data exists and what types of data are collected.
• Add a “Data Category” column to indicate PII and whether it relates to EU or California residents. This helps organisations understand jurisdictional privacy considerations.
  

Step 2: Reference the Statement of Applicability (SoA)

• For enterprise clients, your SoA may demonstrate how ISO 27001 controls relate to privacy requirements.
• Example Mapping:
  • Control A.8.10 – Information Deletion: Commonly referenced in relation to data erasure workflows. Relevant for:
    • GDPR “Right to be Forgotten”
    • CCPA s1798.105 – Deletion of Personal Information.
  • Control A.5.34 – Privacy and Protection of PII: Supports principles relating to processing of personal data. Relevant for:
    • GDPR Article 5 – Principles relating to processing of personal data
    • CCPA s1798.100 – Consumer Rights regarding Personal Information.

Step 3: Establish an Incident Response Approach

• Global frameworks often feature strict notification windows, such as the 72-hours benchmark seen in European regulations; CCPA includes notification obligations in certain data breach scenarios.
• Consider a unified Incident Management Policy that includes a privacy impact check to identify when legal notifications may be relevant.
  

Step 4: Review Supplier Management (A.5.21)

• When evaluating vendors, consider including DPAs and relevant data processing considerations to align third-party handling with internal privacy and security practices.
  

Step 5: Implement Continuous Improvement (PDCA Cycle)

• Periodically review your ISMS and privacy framework to reflect evolving laws (e.g. the CCPA as amended by the CPRA).
• This iterative process may help organisations identify gaps or updates needed in their controls and procedures.
  

Privacy Considerations Beyond ISO 27001

While ISO 27001 provides a structured security framework, privacy requirements may need additional measures:

• Cookie Consent and Preference Centres: GDPR and CCPA may require consent, notice, or opt-out mechanisms depending on business model, data types, and jurisdictional interpretation before collecting or processing personal data.
• DSAR Workflow: Organisations may handle “Export my data” or “Delete my account” requests within commonly referenced statutory response windows (typically an initial 30 or 45 days, subject to extensions).
• Data Processing Agreements (DPAs): Linking ISO 27001 controls to sub-processors (e.g. AWS, Stripe) may support compliance with privacy obligations.

Tip: The data mapping already captured for Annex A.5.34 may also feed your GDPR Record of Processing Activities (ROPA), reducing duplicated effort.

Understanding "Reasonable Security" Under CCPA

California regulatory framework discusses the concept of “reasonable security” for personal information without providing a prescriptive checklist. In many jurisdictions, “reasonable security” is an evolving standard often informed by established frameworks like ISO 27001. Organisations may use ISO 27001 controls as a structured reference to help document security governance alongside other technical, organisational, and legal considerations.

• A.5.1 Policies: Board-level directives may demonstrate intentional governance of information security.
• A.8.8 Technical Vulnerabilities: Documenting patch management and risk awareness may support compliance with reasonable security expectations.
• A.8.24 Cryptography: Implementing encryption for sensitive data may be a factor in demonstrating the use of security measures that are relevant in the event of a data exposure.
• Risk Treatment Plan (Clause 6.1.3): Recording risk assessment and mitigation decisions may provide evidence of deliberate security considerations.

Practical Guidance: Adopting ISO 27001 controls alongside self-certifying to the EU-U.S. Data Privacy Framework may be considered as one possible cross-border data transfer mechanism.

Additional Note: CIS Critical Security Controls are frequently referenced by California regulators alongside ISO standards to define baseline technical security expectations.

Common SME Pitfall: Shadow IT

Unapproved or unmanaged SaaS tools used by marketing, operations, or other teams may increase the likelihood of gaps in ISO 27001 and CCPA / CPRA alignment. Such tools can unintentionally collect, store, or transmit personal data outside an organisation’s defined governance, consent, and security processes.

A.5.9 – Inventory of Information and other associated assets:

• Maintaining a comprehensive information and asset inventory may help organisations identify where personal data is collected or processed, including through Shadow IT applications.
• Supporting artefacts may include asset registers, SaaS approval logs, or periodic usage reviews.

Risk Insight: In recent enforcement trends, Shadow IT has been cited in various enforcement context to have contributed to unexpected CCPA / CPRA exposure. For example, a marketing team might deploy advertising or analytics pixels from platforms (such as Meta, TikTok, or LinkedIn) to measure campaign ROI without aligning the website’s consent banner or "Do Not Sell or Share" mechanisms. California regulators have, in some cases, characterised similar data sharing as an unauthorised disclosure of personal information rather than a simple technical oversight, which can increase the risk of regulatory scrutiny.

Practical Tip:

• Periodic reviews of the information inventory, combined with clear communication of approved tools and data-handling expectations, may help reduce unintentional privacy and security exposures.
• Conducting a "SaaS Discovery" audit (using network logs or financial records) is an effective way to populate your ISO asset register while closing privacy gaps.
  

Visual Compliance Stack

This layered approach may help SMEs and startups visualise how information security and privacy controls interact across jurisdictions.

Key Evidence Artefacts for ISO 27001, GDPR, and CCPA Compliance

The following artefacts may help organisations demonstrate alignment between their ISO 27001 ISMS and GDPR / CCPA considerations.

• Data Map and Asset Inventory (A.5.34, A.5.9): May help identify where personal data resides and how it is classified.
• Privacy-related Design Review Logs: May assist in documenting security and privacy considerations during system or process development.
• DSAR Ticket Logs and Data Deletion Records (A.8.10): May support evidence of handling “Right to be Forgotten” and consumer data requests.
• Supplier Audit Reports and Signed DPAs (A.5.21): May help demonstrate oversight of third-party processing and contractual privacy obligations.
• Incident Response and Breach Notification Records: May provide evidence of how potential security incidents or breaches are tracked and managed in line with legal expectations.
  

Practical Takeaways for SMEs Using ISO 27001 with GDPR and CCPA

Using ISO 27001 may help organisations streamline privacy and security efforts across multiple jurisdictions from an internal governance perspective. While it does not replace legal advice or guarantee compliance, it provides a structured framework for managing information security and privacy considerations.

• One Framework for Multiple Privacy Laws: ISO 27001 controls may help align internal processes with GDPR and CCPA considerations.
• Documented Evidence for Enterprise Reviews: Records from your ISMS may be used to document internal assessments or buyer due diligence.
• Structured Internal Evidence: Organised controls and mapped documentation may help teams quickly locate information for audits, internal reviews, or enterprise due diligence.
  

Summary: Using ISO 27001 as a Supporting Framework

This article explains how ISO 27001 can be used as a structured foundation for managing privacy-related obligations such as GDPR and CCPA. Rather than replacing legal compliance, an ISMS may help organisations organise controls, evidence, and responsibilities in a way that supports privacy risk management, enterprise due diligence, and evolving regulatory expectations.

Next Step: Review ISO 27001 templates examples that may help structure documentation and supporting evidence over time.

Next Article: In Exploring the Hybrid ISO 27001 Compliance Stack (2026), we examine how structured documentation and cloud-native tooling may work together to support internal governance and external reviews.

Related Guides

Explore these ISO 27001 resources to help your SME build a practical, lean ISMS: 

Start Here: Complete Guide

• ISO 27001 for SMEs and Startups: The Chill Implementation Guide (2026 Edition) – Full roadmap covering all clauses and Annex A controls, with practical steps, examples, and guidance.
  

Scaling and The Future of Compliance – Detailed Guides by Topic

• ISO 27001 to SOC 2 Mapping: Evidence Comparison Guide for SMEs – A practical comparison of how ISO 27001 controls and evidence may align with SOC 2 Security criteria, highlighting common overlaps and gaps.
• AI and Information Security: Practical Controls for Startups – Guidance on managing AI as a traceable operational asset, linking ISO 27001 practices to model training, inference, logging, and third-party AI services.
• The ISO 27001 Surveillance Audit: Maintain Your ISMS in Year 2 and Beyond – Practical guidance for SMEs on keeping an ISMS active through Year 2 and 3 audits, reviews, and change management.
  
• Exploring the Hybrid ISO 27001 Compliance Stack (2026) – A conceptual guide to how startups combine governance, cloud-native tools, and people for structured evidence management.

Please Note: This article provides general information only and does not constitute legal, regulatory, or compliance advice. Using our products or following this guidance cannot guarantee certification, improved business outcomes, or regulatory compliance. Organisations remain responsible for ensuring all actions meet certification and compliance requirements.

This article also mentions examples of commonly used tools. Chill Compliance does not endorse any vendor and has no commercial or affiliate relationship with the providers listed. These examples are for general information only, and readers may wish to evaluate each tool independently, as features and pricing can vary.