TheArtOfService
GDPRCloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

GDPR covers 7.6% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

15 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for GDPR. 182 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.

7.6%
of the target already covered
15
controls evidenced
182
genuine gaps
0
claims rejected in review

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

49 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.

DSP - Data Security & Privacy Lifecycle Management12 of 19 evidenced, 7 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics1 of 8 evidenced, 7 to do
HRS - Human Resources Security1 of 13 evidenced, 12 to do
STA - Supply Chain Management, Transparency & Accountability1 of 14 evidenced, 13 to do
A&A - Audit & Assurance0 of 6 evidenced, 6 to do
AIS - Application & Interface Security0 of 7 evidenced, 7 to do
BCR - Business Continuity Management & Operational Resilience0 of 11 evidenced, 11 to do
CCC - Change Control & Configuration Management0 of 9 evidenced, 9 to do
CEK - Cryptography, Encryption & Key Management0 of 21 evidenced, 21 to do
DCS - Datacenter Security0 of 15 evidenced, 15 to do
GRC - Governance, Risk & Compliance0 of 8 evidenced, 8 to do
IAM - Identity & Access Management0 of 16 evidenced, 16 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 to do
IVS - Infrastructure & Virtualization Security0 of 9 evidenced, 9 to do
LOG - Logging & Monitoring0 of 13 evidenced, 13 to do
TVM - Threat & Vulnerability Management0 of 10 evidenced, 10 to do
UEM - Universal Endpoint Management0 of 14 evidenced, 14 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.30CCM-DSP-03argued against and upheld
Data Inventory

The processing register is an inventory of personal data categories and holdings.

GDPR-Art.25CCM-DSP-07argued against and upheld
Data Protection by Design and Default

Safeguards must be built in when the means of processing are determined.

GDPR-Art.25CCM-DSP-08argued against and upheld
Data Privacy by Design and Default

By default only data necessary for each purpose is processed or made accessible.

GDPR-Art.35CCM-DSP-09argued against and upheld
Data Protection Impact Assessment

Impact assessment of high risk processing with prescribed risk and severity content.

GDPR-Art.5CCM-DSP-10argued against and upheld
Sensitive Data Transfer

Purpose limitation confines processing after transfer to permitted purposes.

GDPR-Art.32CCM-DSP-10argued against and upheld
Sensitive Data Transfer

Personal data transmitted must be secured, with encryption named as a measure.

GDPR-Art.15CCM-DSP-11argued against and upheld
Personal Data Access, Reversal, Rectification and Deletion

Access right delivers confirmation, particulars and a copy of the data.

GDPR-Art.16CCM-DSP-11argued against and upheld
Personal Data Access, Reversal, Rectification and Deletion

Inaccurate data rectified and incomplete data completed on request.

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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