CCPA/CPRAISO 27701:2019

CCPA/CPRA covers 23.1% of ISO 27701:2019

25 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for CCPA/CPRA. 83 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.

23.1%
of the target already covered
25
controls evidenced
83
genuine gaps
0
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your CCPA/CPRA 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.

48 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 27701:201920 of 31 evidenced, 11 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20193 of 18 evidenced, 15 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20192 of 23 evidenced, 21 to do
PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:20190 of 36 evidenced, 36 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.

§1798.185(a)(15)5.4.1argued against and upheld
Actions to address risks and opportunities

Risk assessment must weigh business benefit against risk to consumer rights.

§1798.185(a)(15)5.6.2argued against and upheld
Information security risk assessment

Risk assessments must be submitted on a regular basis, not once at design time.

CCR §70127.2.1argued against and upheld
Identify and document purpose

Notice must identify the categories collected and the purposes each will be used for.

§1798.1007.2.1argued against and upheld
Identify and document purpose

Purposes must be disclosed and no incompatible additional purpose used without notice.

§1798.185(a)(15)7.2.5argued against and upheld
Privacy impact assessment

Risk assessment required where processing presents significant risk to privacy or security.

§1798.100(d)7.2.6argued against and upheld
Contracts with PII processors

Written contract must specify purposes, bar other uses, require equal protection and audit rights.

§1798.130(a)(3)7.2.8argued against and upheld
Records related to processing PII

Requires a maintained record of categories collected, sources, purposes and recipients.

§1798.130(a)(2)7.3.1argued against and upheld
Determining and fulfilling obligations to PII principals

Requests answered free of charge within a defined 45 day period.

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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