GDPRISO 27701:2019

GDPR covers 34.3% of ISO 27701:2019

37 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for GDPR. 71 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.

34.3%
of the target already covered
37
controls evidenced
71
genuine gaps
0
claims rejected in review

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

75 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.

Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:201925 of 31 evidenced, 6 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20198 of 18 evidenced, 10 to do
PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:20194 of 36 evidenced, 32 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.

GDPR-Art.346.13.1argued against and upheld
Management of information security incidents and improvements

Requires notifying affected individuals, which is the other party this control names.

GDPR-Art.336.13.1argued against and upheld
Management of information security incidents and improvements

Requires documenting every breach, its effects and remedial action, with notification timings.

GDPR-Art.246.2.1argued against and upheld
Management direction for information security

Requires implementing appropriate data protection policies committing the organisation to the law.

GDPR-Art.376.3.1argued against and upheld
Internal organization

Requires a published contact point reachable by individuals and by the supervisory authority.

GDPR-Art.326.9.3argued against and upheld
Backup

Requires ability to restore availability and access to personal data after an incident.

GDPR-Art.57.2.1argued against and upheld
Identify and document purpose

Purposes must be specified, explicit and legitimate, and the controller must demonstrate it.

GDPR-Art.137.2.1argued against and upheld
Identify and document purpose

Purposes must be documented well enough to state to the individual at collection.

GDPR-Art.97.2.2argued against and upheld
Identify lawful basis

Requires an additional condition for special categories, which is the classification element.

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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