APPIISO 27701:2019

APPI covers 19.4% of ISO 27701:2019

21 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for APPI. 87 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.

19.4%
of the target already covered
21
controls evidenced
87
genuine gaps
0
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your APPI 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.

35 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 27701:20190 of 23 evidenced, 23 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.

Article 177.2.1argued against and upheld
Identify and document purpose

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

Article 207.2.2argued against and upheld
Identify lawful basis

Special care required data may not be acquired without consent except where the Act allows.

Article 187.2.2argued against and upheld
Identify lawful basis

Prior consent is the basis required for handling outside the specified purpose.

Article 277.2.3argued against and upheld
Determine when and how consent is to be obtained

Consent is required before provision to a third party unless a listed route applies.

Article 317.2.4argued against and upheld
Obtain and record consent

Consent must be confirmed before personally referable information is passed on.

Article 257.2.6argued against and upheld
Contracts with PII processors

Entrusted handling requires necessary and appropriate supervision of the trustee.

Article 407.3.1argued against and upheld
Determining and fulfilling obligations to PII principals

Complaints must be processed promptly and the system to do so established.

Article 327.3.1argued against and upheld
Determining and fulfilling obligations to PII principals

The response procedure and the complaint contact point must be made accessible.

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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