Cross-Framework Mapping

ISO 27701:2019vsGDPR

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

90
Controls Mapped
18
Gaps Found
60%
Coverage

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

According to the TheArtOfService Compliance Knowledge Graph:

ISO 27701:2019 maps to GDPR with 60% coverage across 65 directly mapped controls. Analysis of 108 ISO 27701:2019 controls identifies 80 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 90 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(12 mappings)

iso-27701-2019::5.2.4Information security management system
GDPR-Art.24Responsibility of the controller
iso-27701-2019::5.3.2Policy
GDPR-Art.24Responsibility of the controller
iso-27701-2019::5.3.3Organizational roles, responsibilities and authorities
GDPR-Art.37Designation of the data protection officer
iso-27701-2019::5.4.1Actions to address risks and opportunities2 targets
GDPR-Art.24Responsibility of the controller
GDPR-Art.35Data protection impact assessment
iso-27701-2019::5.5.1Resources
GDPR-Art.38Position of the data protection officer
iso-27701-2019::5.5.2Competence
GDPR-Art.37Designation of the data protection officer
iso-27701-2019::5.5.3Awareness
GDPR-Art.39Tasks of the data protection officer
iso-27701-2019::5.6.1Operational planning and control
GDPR-Art.24Responsibility of the controller
iso-27701-2019::5.6.2Information security risk assessment
GDPR-Art.35Data protection impact assessment
iso-27701-2019::5.7.1Monitoring, measurement, analysis and evaluation
GDPR-Art.32Security of processing
iso-27701-2019::5.7.2Internal audit
GDPR-Art.39Tasks of the data protection officer

PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019(8 mappings)

iso-27701-2019::6.11.2Security in development and support processes
GDPR-Art.25Data protection by design and by default
iso-27701-2019::6.12.1Information security in supplier relationships
GDPR-Art.28Processor
iso-27701-2019::6.13.1Management of information security incidents and improvements2 targets
GDPR-Art.33Notification of a personal data breach to the supervisory authority
GDPR-Art.34Communication of a personal data breach to the data subject
iso-27701-2019::6.15.1Compliance with legal and contractual requirements
GDPR-Art.24Responsibility of the controller
iso-27701-2019::6.15.2Information security reviews
GDPR-Art.31Cooperation with the supervisory authority
iso-27701-2019::6.2.1Management direction for information security
GDPR-Art.24Responsibility of the controller
iso-27701-2019::6.3.1Internal organization
GDPR-Art.37Designation of the data protection officer

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Coverage crosswalk

The ISO 27701:2019 to GDPR crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which GDPR 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 GDPR lands at 52.5%, while GDPR into ISO 27701:2019 lands at 34.3%, 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 GDPR, the other asks the reverse.

ISO 27701:2019 into GDPR
52.5%

21 of 40 GDPR controls are evidenced by work you have already done for ISO 27701:2019. 19 are genuine gaps.

81.8%Chapter III - Rights of the Data Subject
43.8%Chapter IV - Controller and Processor
42.9%Chapter II - Principles
33.3%Chapter V - Transfers of Personal Data
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-20. 57 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: GDPR-Art.12 Transparent information, communication and modalities for rights

Requires defined response times, notice of delay and fees only for excessive requests.

Grounded in iso-27701-2019::7.3.9 Handling requests. Confidence high, survived the refutation pass.

Gap: GDPR-Art.10 Processing of personal data relating to criminal convictions

Process personal data relating to criminal convictions and offences, or related security measures, only under the control of official authority or where Union or Member State law authorises the processing and provides appropriate...

Every one of the 21 evidenced controls and 19 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

GDPR into ISO 27701:2019
34.3%

37 of 108 ISO 27701:2019 controls are evidenced by work you have already done for GDPR. 71 are genuine gaps.

80.6%Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:2019
44.4%Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:2019
11.1%PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019
0%PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:2019
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-20. 75 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: 6.13.1 Management of information security incidents and improvements

Requires documenting every breach, its effects and remedial action, with notification timings.

Grounded in GDPR-Art.33 Notification of a personal data breach to the supervisory authority. 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 37 evidenced controls and 71 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

ISO 27701:2019 to GDPR
$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 60% 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 GDPR 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 GDPR?

ISO 27701:2019 has 108 controls across its framework, while GDPR covers 40 controls. Direct mapping analysis identifies 65 overlapping controls (60% coverage). The frameworks diverge most significantly in PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019, where 40 ISO 27701:2019 controls have no direct GDPR equivalent.

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

Of 108 total ISO 27701:2019 controls, 65 map directly to GDPR controls, representing 60% coverage. The remaining 80 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 GDPR?

80 ISO 27701:2019 controls have no direct equivalent in GDPR. The highest concentration of gaps is in PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019 with 40 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 GDPR?

The domain with the highest gap count is PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019 (40 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.