Cross-Framework Mapping

ISO 27701:2019vsAPPI

See exactly how ISO 27701:2019 controls map to APPI. Pre-computed mappings, identified gaps, and coverage analysis.

65
Controls Mapped
43
Gaps Found
32%
Coverage

A reviewed coverage crosswalk for this pair is available. See which APPI controls you already evidence.

According to the TheArtOfService Compliance Knowledge Graph:

ISO 27701:2019 maps to APPI with 32% coverage across 35 directly mapped controls. Analysis of 108 ISO 27701:2019 controls identifies 110 compliance gaps, primarily concentrated in PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019.

Source: TheArtOfService Knowledge Graph | 108 controls analysed | 686 frameworks | 309K+ cross-framework mappings

Control Mappings

Showing 20 of 65 mapped controls across 4 domains. Sign up to explore all 309K+ mappings across 686 frameworks.

PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:2019(2 mappings)

iso-27701-2019::5.5.2Competence
APPI-A24Supervision of Employees
iso-27701-2019::5.5.3Awareness
APPI-A24Supervision of Employees

PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019(7 mappings)

iso-27701-2019::6.12.1Information security in supplier relationships
APPI-A25Supervision of Trustees
iso-27701-2019::6.12.2Supplier service delivery management
APPI-A25Supervision of Trustees
iso-27701-2019::6.13.1Management of information security incidents and improvements
APPI-A26Report of Leakage to the Commission and Notification to the Person
iso-27701-2019::6.3.1Internal organization2 targets
APPI-A32Matters Concerning Retained Personal Data to Be Made Accessible
APPI-A40Processing of Complaints
iso-27701-2019::6.4.1Prior to employment
APPI-A24Supervision of Employees
iso-27701-2019::6.4.2During employment
APPI-A24Supervision of Employees

Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:2019(11 mappings)

iso-27701-2019::7.2.1Identify and document purpose3 targets
APPI-A17Specification of the Purpose of Use
APPI-A18Restriction on Handling Beyond the Purpose of Use
APPI-A21Notice or Public Announcement of the Purpose of Use
iso-27701-2019::7.2.2Identify lawful basis2 targets
APPI-A18Restriction on Handling Beyond the Purpose of Use
APPI-A20Proper Acquisition and Special Care Required Personal Information
iso-27701-2019::7.2.3Determine when and how consent is to be obtained
APPI-A27Restriction on Provision to Third Parties
iso-27701-2019::7.2.4Obtain and record consent4 targets
APPI-A18Restriction on Handling Beyond the Purpose of Use
APPI-A20Proper Acquisition and Special Care Required Personal Information
APPI-A27Restriction on Provision to Third Parties
APPI-A31Provision of Personally Referable Information
iso-27701-2019::7.2.6Contracts with PII processors
APPI-A25Supervision of Trustees

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Coverage crosswalk

The ISO 27701:2019 to APPI crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which APPI controls your existing ISO 27701:2019 work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

Coverage does not run both ways. ISO 27701:2019 into APPI lands at 53.3%, while APPI into ISO 27701:2019 lands at 19.4%, on the same two control sets. That is not a rounding difference. It is the whole reason these are two separate reports: one asks what your ISO 27701:2019 evidence buys you for APPI, the other asks the reverse.

ISO 27701:2019 into APPI
53.3%

16 of 30 APPI controls are evidenced by work you have already done for ISO 27701:2019. 14 are genuine gaps.

80%APPI: Purpose Specification and Acquisition (Articles 17 to 21)
80%APPI: Security Control and Supervision (Articles 22 to 26)
50%APPI: Rights of Identifiable Persons (Articles 32 to 39)
60%APPI: Third Party Provision and Records (Articles 27 to 31)
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 54 candidate mappings were examined and 0 were removed by a pass whose job was to argue against them.Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

A sample of what the report says

Evidenced: Article 17 Specification of the Purpose of Use

Requires specific purposes of processing to be identified and documented in usable detail.

Grounded in iso-27701-2019::7.2.1 Identify and document purpose. Confidence high, survived the refutation pass.

Gap: Article 19 Prohibition of Improper Use

Do not use personal information by a method that may encourage or induce an unlawful or unjust act.

Every one of the 16 evidenced controls and 14 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

APPI into ISO 27701:2019
19.4%

21 of 108 ISO 27701:2019 controls are evidenced by work you have already done for APPI. 87 are genuine gaps.

67.7%Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:2019
0%PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:2019
0%PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019
0%Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:2019
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-20. 35 candidate mappings were examined and 0 were removed by a pass whose job was to argue against them.Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

A sample of what the report says

Evidenced: 7.2.1 Identify and document purpose

The purpose of use must be specified as far as possible and cannot drift beyond it.

Grounded in APPI-A17 Specification of the Purpose of Use. Confidence high, survived the refutation pass.

Gap: 5.1 General

Every requirement of ISO/IEC 27001 that speaks of information security must be read as extending to the protection of privacy as it may be affected by the processing of personally identifiable information, so the management system is...

Every one of the 21 evidenced controls and 87 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

ISO 27701:2019 to APPI
$299
per framework pair, one time
  • Every evidenced control, with the reasoning behind it
  • Every gap, with what it requires
  • Its level of review stated plainly, not a bare number

Why this page shows two different percentages. The 32% in the header counts how many ISO 27701:2019 controls carry at least one candidate mapping in the graph, before any review. The crosswalk percentage counts something stricter: how many APPI controls are actually evidenced, after a pass that argued against each mapping and kept only what survived. They answer different questions and they are not meant to agree.

A crosswalk narrows the work. It does not replace an audit, and your assessor may take a different view on individual controls. Mappings between frameworks are judgements, not text printed in either standard, which is why every claim in the report shows its reasoning. Questions go to support@theartofservice.com.

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What are the key differences between ISO 27701:2019 and APPI?

ISO 27701:2019 has 108 controls across its framework, while APPI covers 30 controls. Direct mapping analysis identifies 35 overlapping controls (32% coverage). The frameworks diverge most significantly in PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019, where 44 ISO 27701:2019 controls have no direct APPI equivalent.

How many controls map between ISO 27701:2019 and APPI?

Of 108 total ISO 27701:2019 controls, 35 map directly to APPI controls, representing 32% coverage. The remaining 110 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping ISO 27701:2019 to APPI?

110 ISO 27701:2019 controls have no direct equivalent in APPI. The highest concentration of gaps is in PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019 with 44 unmapped controls. These gaps represent areas where additional controls, policies, or documentation must be created to achieve compliance with both frameworks.

Which control domains have the most gaps between ISO 27701:2019 and APPI?

The domain with the highest gap count is PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019 (44 gaps). Export the full domain-by-domain gap breakdown via the Professional tier to generate a prioritised remediation roadmap.

This platform provides educational compliance tools, not legal, regulatory, or professional compliance advice. Cross-framework mappings are AI-assisted interpretations and do not reproduce or replace official standards. Framework names and trademarks belong to their respective owners. Consult qualified professionals for your specific compliance requirements. See our Terms of Service.