FedRAMP ModerateISO 27701:2019

FedRAMP Moderate covers 30.6% of ISO 27701:2019

33 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for FedRAMP Moderate. 75 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.

30.6%
of the target already covered
33
controls evidenced
75
genuine gaps
0
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your FedRAMP Moderate 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.

127 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 27701:201931 of 36 evidenced, 5 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20191 of 18 evidenced, 17 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20191 of 31 evidenced, 30 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.

SC-76.10.1argued against and upheld
Network security management

Communications monitored and controlled at external and key internal boundaries with subnetworks.

SC-7(3)6.10.1argued against and upheld
Network security management

External network connections limited in number, which is network segregation.

SC-86.10.1argued against and upheld
Network security management

Confidentiality and integrity of transmitted information protected cryptographically.

AC-46.10.1argued against and upheld
Network security management

Approved information flow control policies enforced within and between systems.

PS-66.10.2argued against and upheld
Information transfer

Signed access agreements impose confidentiality obligations before access.

CA-36.10.2argued against and upheld
Information transfer

Information exchange with external systems approved and managed under agreements, reviewed annually.

AC-46.10.2argued against and upheld
Information transfer

Flow control enforces the rules governing data as it moves.

SC-8(1)6.11.1argued against and upheld
Security requirements of information systems

FIPS validated cryptography protects data transmitted over untrusted networks.

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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