Australian Privacy Principles (APPs)APEC Cross-Border Privacy Rules (CBPR) System

Australian Privacy Principles (APPs) covers 47.5% of APEC Cross-Border Privacy Rules (CBPR) System

28 of the 59 controls in APEC Cross-Border Privacy Rules (CBPR) System are already satisfied by evidence you collected for Australian Privacy Principles (APPs). 31 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.

47.5%
of the target already covered
28
controls evidenced
31
genuine gaps
0
claims rejected in review

This number is directional. It says how much of APEC Cross-Border Privacy Rules (CBPR) System your Australian Privacy Principles (APPs) 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.

32 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.

CBPR Program Requirements: Access and Correction3 of 3 evidenced
Transparency1 of 1 evidenced
Data Minimization1 of 1 evidenced
Purpose Limitation1 of 1 evidenced
Governance1 of 1 evidenced
Consent1 of 1 evidenced
Data Quality1 of 1 evidenced
Security1 of 1 evidenced
Individual Rights1 of 1 evidenced
CBPR Program Requirements: Notice3 of 4 evidenced, 1 to do
CBPR Program Requirements: Collection Limitation2 of 3 evidenced, 1 to do
CBPR Program Requirements: Uses of Personal Information3 of 6 evidenced, 3 to do
CBPR Program Requirements: Choice3 of 7 evidenced, 4 to do
CBPR Program Requirements: Integrity of Personal Information2 of 5 evidenced, 3 to do
CBPR Program Requirements: Security Safeguards3 of 10 evidenced, 7 to do
CBPR Program Requirements: Accountability1 of 12 evidenced, 11 to do
Risk0 of 1 evidenced, 1 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.

APP-5Principle II, Noticeargued against and upheld
Notice

Fixes the matters that must be notified at the point of collection.

APP-1Principle II, Noticeargued against and upheld
Notice

Requires a clearly expressed and current privacy policy describing how information is handled.

APP-3Principle III, Collection Limitationargued against and upheld
Collection Limitation

Only information reasonably necessary for the entity functions may be collected.

APP-6Principle IV, Uses of Personal Informationargued against and upheld
Uses of Personal Information

Use or disclosure confined to the primary purpose or a permitted secondary purpose.

APP-1Principle IX, Accountabilityargued against and upheld
Accountability

Personal information must be managed in an open and transparent way by the entity.

APP-7Principle V, Choiceargued against and upheld
Choice

A simple means to opt out must be provided where direct marketing is used.

APP-10Principle VI, Integrity of Personal Informationargued against and upheld
Integrity of Personal Information

Reasonable steps must keep information accurate, up to date and complete.

APP-11Principle VII, Security Safeguardsargued against and upheld
Security Safeguards

Reasonable steps must protect information from misuse, interference, loss and unauthorised access.

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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