Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1ISO 27701:2019

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 covers 47.2% of ISO 27701:2019

51 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1. 57 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.

47.2%
of the target already covered
51
controls evidenced
57
genuine gaps
0
claims rejected in review

What this leaves you to do

ISO 27701:2019 has 108 controls. Holding Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 already evidences 51 of them, so the work in front of you is 57 controls, not 108, which is 53% of the standard rather than all of it.

That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.

In money, using only our numbers. The full report is $299 and names 51 controls of ISO 27701:2019 you do not have to implement again, which is $5.86 per control identified. That arithmetic uses our price and our count and assumes nothing about you.

In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.

If a control takes you4 hours8 hours16 hours
the 51 already evidenced are204 hours408 hours816 hours
and the 57 remaining are228 hours456 hours912 hours

Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.

This number is directional. It says how much of ISO 27701:2019 your Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 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.

157 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.

PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:201930 of 36 evidenced, 6 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20199 of 18 evidenced, 9 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20198 of 31 evidenced, 23 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20194 of 23 evidenced, 19 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.

CCM-GRC-015.3.2argued against and upheld
Policy

Approved governance policy set with leadership sponsorship, reviewed annually.

CCM-DSP-015.3.2argued against and upheld
Policy

Approved data security and privacy policy aligned to applicable law, reviewed annually.

CCM-HRS-095.3.3argued against and upheld
Organizational roles, responsibilities and authorities

Documents and communicates each person's information asset responsibilities.

CCM-GRC-065.3.3argued against and upheld
Organizational roles, responsibilities and authorities

Documents who plans, operates, assesses and improves governance and their accountability.

CCM-HRS-135.5.3argued against and upheld
Awareness

Staff made aware of personal responsibility for policy and legal obligations.

CCM-HRS-125.5.3argued against and upheld
Awareness

Awareness training for staff handling personal data, tuned to function and kept current.

CCM-A&A-055.7.2argued against and upheld
Internal audit

Defined audit process covering planning, control assessment, conclusions and remediation.

CCM-STA-115.7.2argued against and upheld
Internal audit

Annual internal assessment of conformity to standards, policies and procedures.

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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