GDPRAPPI

GDPR covers 50% of APPI

15 of the 30 controls in APPI are already satisfied by evidence you collected for GDPR. 15 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.

50%
of the target already covered
15
controls evidenced
15
genuine gaps
0
claims rejected in review

This number is directional. It says how much of APPI your GDPR 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.

35 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.

APPI: Purpose Specification and Acquisition (Articles 17 to 21)4 of 5 evidenced, 1 to do
APPI: Security Control and Supervision (Articles 22 to 26)4 of 5 evidenced, 1 to do
APPI: Rights of Identifiable Persons (Articles 32 to 39)6 of 8 evidenced, 2 to do
APPI: Third Party Provision and Records (Articles 27 to 31)1 of 5 evidenced, 4 to do
APPI: Complaint Handling (Article 40)0 of 1 evidenced, 1 to do
APPI: Pseudonymized Personal Information (Articles 41 and 42)0 of 2 evidenced, 2 to do
APPI: Anonymized Personal Information (Articles 43 to 46)0 of 4 evidenced, 4 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.

GDPR-Art.5Article 17argued against and upheld
Specification of the Purpose of Use

Requires purposes specified, explicit and legitimate before collection.

GDPR-Art.6Article 17argued against and upheld
Specification of the Purpose of Use

Requires a compatibility assessment before processing beyond the original purpose.

GDPR-Art.6Article 18argued against and upheld
Restriction on Handling Beyond the Purpose of Use

Processing beyond the collected purpose needs consent, a legal mandate or a compatibility test.

GDPR-Art.9Article 20argued against and upheld
Proper Acquisition and Special Care Required Personal Information

Requires explicit consent or another listed condition before sensitive category processing.

GDPR-Art.5Article 20argued against and upheld
Proper Acquisition and Special Care Required Personal Information

Requires processing be lawful and fair, which forbids deceptive acquisition.

GDPR-Art.14Article 21argued against and upheld
Notice or Public Announcement of the Purpose of Use

Requires the purpose given within one month where data came from elsewhere.

GDPR-Art.13Article 21argued against and upheld
Notice or Public Announcement of the Purpose of Use

Requires the purpose given at the time data is obtained from the individual.

GDPR-Art.5Article 22argued against and upheld
Accuracy and Deletion of Personal Data

Requires accuracy kept up to date and identification kept no longer than the purpose needs.

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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