TheArtOfService
Australia Consumer Data Right - Banking (CDR)Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

Australia Consumer Data Right - Banking (CDR) covers 17.3% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

34 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for Australia Consumer Data Right - Banking (CDR). 163 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.

17.3%
of the target already covered
34
controls evidenced
163
genuine gaps
0
claims rejected in review

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 your Australia Consumer Data Right - Banking (CDR) 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.

50 candidate mappings were examined and 0 were removed. Signed off 2026-08-19, 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.

GRC - Governance, Risk & Compliance4 of 8 evidenced, 4 to do
TVM - Threat & Vulnerability Management4 of 10 evidenced, 6 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics3 of 8 evidenced, 5 to do
DSP - Data Security & Privacy Lifecycle Management7 of 19 evidenced, 12 to do
IVS - Infrastructure & Virtualization Security3 of 9 evidenced, 6 to do
A&A - Audit & Assurance2 of 6 evidenced, 4 to do
HRS - Human Resources Security3 of 13 evidenced, 10 to do
UEM - Universal Endpoint Management3 of 14 evidenced, 11 to do
IAM - Identity & Access Management3 of 16 evidenced, 13 to do
STA - Supply Chain Management, Transparency & Accountability1 of 14 evidenced, 13 to do
CEK - Cryptography, Encryption & Key Management1 of 21 evidenced, 20 to do
AIS - Application & Interface Security0 of 7 evidenced, 7 to do
BCR - Business Continuity Management & Operational Resilience0 of 11 evidenced, 11 to do
CCC - Change Control & Configuration Management0 of 9 evidenced, 9 to do
DCS - Datacenter Security0 of 15 evidenced, 15 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 to do
LOG - Logging & Monitoring0 of 13 evidenced, 13 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.

AUCDR-IS-STEP4CCM-A&A-02argued against and upheld
Independent Assessments

Step 4 requires effectiveness testing by independent skilled testers.

AUCDR-IS-STEP4CCM-A&A-06argued against and upheld
Remediation

Step 4 requires deficiencies be escalated to senior management for remediation.

AUCDR-IS-2CCM-CEK-03argued against and upheld
Data Encryption

Control 2 requires encryption of CDR data in the data environment.

AUCDR-IS-3CCM-DSP-01argued against and upheld
Security and Privacy Policy and Procedures

Control 3 requires information assets be securely managed across their whole lifecycle.

AUCDR-IS-STEP2CCM-DSP-03argued against and upheld
Data Inventory

Step 2 requires CDR data holdings and their boundary be documented and reviewed annually.

AUCDR-PS-8CCM-DSP-10argued against and upheld
Sensitive Data Transfer

Privacy Safeguard 8 conditions overseas disclosure on the recipient meeting the safeguards.

AUCDR-PS-13CCM-DSP-11argued against and upheld
Personal Data Access, Reversal, Rectification and Deletion

Privacy Safeguard 13 requires correction of inaccurate or misleading CDR data on request.

AUCDR-PS-6CCM-DSP-12argued against and upheld
Limitation of Purpose in Personal Data Processing

Privacy Safeguard 6 confines use and disclosure to the consented purposes.

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.

Buy this crosswalk