APEC Cross-Border Privacy Rules (CBPR) SystemISO 27701:2019

APEC Cross-Border Privacy Rules (CBPR) System covers 26.9% of ISO 27701:2019

29 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for APEC Cross-Border Privacy Rules (CBPR) System. 79 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

26.9%
of the target already covered
29
controls evidenced
79
genuine gaps
0
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your APEC Cross-Border Privacy Rules (CBPR) System evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

62 candidate mappings were examined and 0 were removed. Signed off 2026-08-20, review level machine verified. 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.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:201921 of 31 evidenced, 10 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20198 of 23 evidenced, 15 to do
PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:20190 of 36 evidenced, 36 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20190 of 18 evidenced, 18 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

Program Requirements, Accountability, question 395.2.4argued against and upheld
Information security management system

Requires maintained compliance measures and the arrangements that implement them.

Principle IX, Accountability5.2.4argued against and upheld
Information security management system

Accountability for complying with the measures giving effect to the privacy principles.

Program Requirements, Accountability, question 395.3.2argued against and upheld
Policy

Internal guidelines and policies giving effect to the principles must be maintained.

Program Requirements, Security Safeguards, question 265.3.2argued against and upheld
Policy

An information security policy covering the personal information held must be implemented.

Program Requirements, Accountability, question 405.3.3argued against and upheld
Organizational roles, responsibilities and authorities

A named individual must be appointed as responsible for overall privacy compliance.

Program Requirements, Security Safeguards, question 345.4.1argued against and upheld
Actions to address risks and opportunities

Risk assessments must be used in support of the safeguards selected.

Program Requirements, Security Safeguards, question 285.4.1argued against and upheld
Actions to address risks and opportunities

Safeguards must be shown proportional to likelihood, severity, sensitivity and context.

Principle I, Preventing Harm5.4.1argued against and upheld
Actions to address risks and opportunities

Protections must be designed against the risks of harm to individuals.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

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