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Module 7 of 9 · ISO 27701 · Clause 10

Improvement and nonconformities

A request answered late or an expired processor contract is a nonconformity (10.2): it is corrected, its cause is investigated and effectiveness is verified.

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Nonconformity and corrective action (10.2)

The standard asks you to react, analyse the cause, act where needed and review effectiveness, keeping evidence of all of it. A breach is an incident; if it reveals that a control was not working, it is also a nonconformity.

Continual improvement (10.1)

Improvement is demonstrated through trends: fewer overdue requests, less time to decide whether to notify a breach, more processors reviewed on schedule.

Example

A fictitious accountancy firm finds during an internal audit that three access requests were answered after 40 days. The cause: they arrived in a generic inbox with no owner. The action: a single form with a deadline and an alert. Six months later, all were on time.

What an auditor usually asks for

  • A nonconformity log with cause and action
  • Dated verification of effectiveness
  • Links between breaches, findings and actions
  • Indicator trends in the management review

How to cover improvement in Kimobox

  1. 1Open the nonconformity from the breach, the audit or the overdue request.
  2. 2Require the root cause before moving on to corrective action.
  3. 3Schedule the effectiveness check for a later date.

The root cause is mandatory: a nonconformity is never closed with the correction alone.

See the Kimobox quality portal

Where each figure comes from

References to the official text in force. If a standard is revised, this page is updated and the review date says so.

  1. ISO/IEC 27701:2025 — Privacy information management systems. Requirements and guidance ISO/IEC · Second edition, October 2025
  2. ISO/IEC 27701:2019 — Extension to ISO/IEC 27001 and ISO/IEC 27002 for privacy information management ISO/IEC · First edition, August 2019; withdrawn in October 2025
  3. Regulation (EU) 2016/679, General Data Protection Regulation (GDPR) EUR-Lex · 27 April 2016; applicable since 25 May 2018
  4. ISO/IEC 27001:2022 — Information security management systems ISO/IEC · 25 October 2022