C5 (Germany) covers 23.7% of APEC Cross-Border Privacy Rules (CBPR) System
14 of the 59 controls in APEC Cross-Border Privacy Rules (CBPR) System are already satisfied by evidence you collected for C5 (Germany). 45 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.
This number is directional. It says how much of APEC Cross-Border Privacy Rules (CBPR) System your C5 (Germany) 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.
47 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.
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.
Authentication and multi-factor access to production is the core technical safeguard.
Physical and environmental safeguards derive from risk and identified protection needs.
Likelihood and impact analysis with acceptance criteria makes safeguards proportionate.
Procedures confine the agency to the data covered, anonymising where it cannot be delimited.
Disclosure occurs only once the assessment confirms a valid and applicable legal basis.
Affected customers are told of the request unless the legal basis forbids disclosure.
Every government investigation request goes to specialists to test the legal basis.
Every provider risk assessed before contributing, weighing the protection needs of the data handled.
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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