CIS Controls v8ISO 27701:2019

CIS Controls v8 covers 25% of ISO 27701:2019

27 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for CIS Controls v8. 81 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.

25%
of the target already covered
27
controls evidenced
81
genuine gaps
84
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your CIS Controls v8 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.

200 candidate mappings were examined and 84 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.

PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:201922 of 36 evidenced, 14 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20194 of 31 evidenced, 27 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20191 of 18 evidenced, 17 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20190 of 23 evidenced, 23 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.

CIS-12.26.10argued against and upheld
Communications security

Secure network architecture addressing segmentation is the network control limb.

CIS-13.46.10argued against and upheld
Communications security

Traffic filtering between segments is segregation in networks.

CIS-12.26.10.1argued against and upheld
Network security management

A maintained secure network architecture is network security management.

CIS-13.46.10.1argued against and upheld
Network security management

Filtering between segments delivers segregation in networks.

CIS-3.106.10.2argued against and upheld
Information transfer

Encrypting sensitive data in transit is the technical core of information transfer.

CIS-16.16.11argued against and upheld
Systems acquisition, development and maintenance

A secure application development process with design standards is this clause.

CIS-16.106.11argued against and upheld
Systems acquisition, development and maintenance

Applying secure design principles in architectures is security and privacy by design.

CIS-16.16.11.1argued against and upheld
Security requirements of information systems

Secure application design standards are the security requirements specification.

Claims that did not hold

84 proposed mappings for this pair were rejected. They are kept in the graph rather than deleted, so what was thrown out is as inspectable as what survived. A crosswalk that never rejects anything is not being judged.

CIS-14.95.5.2
Competence

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

CIS-14.95.5.3
Awareness

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-14.25.5.3
Awareness

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-14.65.5.3
Awareness

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-14.15.5.3
Awareness

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

CIS-13.65.7.1
Monitoring, measurement, analysis and evaluation

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-8.115.7.1
Monitoring, measurement, analysis and evaluation

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-8.25.7.1
Monitoring, measurement, analysis and evaluation

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

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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