TheArtOfService
GDPRNIST SP 800-53 Rev 5

GDPR covers 4.3% of NIST SP 800-53 Rev 5

13 of the 300 controls in NIST SP 800-53 Rev 5 are already satisfied by evidence you collected for GDPR. 287 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.

4.3%
of the target already covered
13
controls evidenced
287
genuine gaps
0
claims rejected in review

This number is directional. It says how much of NIST SP 800-53 Rev 5 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.

53 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.

PT - PII Processing and Transparency5 of 8 evidenced, 3 to do
PM - Program Management5 of 32 evidenced, 27 to do
RA - Risk Assessment1 of 9 evidenced, 8 to do
SA - System and Services Acquisition1 of 17 evidenced, 16 to do
SI - System and Information Integrity1 of 22 evidenced, 21 to do
AC - Access Control0 of 23 evidenced, 23 to do
AT - Awareness and Training0 of 5 evidenced, 5 to do
AU - Audit and Accountability0 of 15 evidenced, 15 to do
CA - Assessment, Authorization, and Monitoring0 of 8 evidenced, 8 to do
CM - Configuration Management0 of 14 evidenced, 14 to do
CP - Contingency Planning0 of 12 evidenced, 12 to do
IA - Identification and Authentication0 of 13 evidenced, 13 to do
IR - Incident Response0 of 9 evidenced, 9 to do
MA - Maintenance0 of 7 evidenced, 7 to do
MP - Media Protection0 of 8 evidenced, 8 to do
PE - Physical and Environmental Protection0 of 22 evidenced, 22 to do
PL - Planning0 of 8 evidenced, 8 to do
PS - Personnel Security0 of 9 evidenced, 9 to do
SC - System and Communications Protection0 of 47 evidenced, 47 to do
SR - Supply Chain Risk Management0 of 12 evidenced, 12 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.38NIST800-PM-19argued against and upheld
Privacy Program Leadership Role. Appoint a senior agency official for privacy with the authority, mission, accountability, and resources to coordinate, develop, and implement, applicable privacy requirements and manage privacy risks through the organization-wide privacy

The officer gets resources, access and a direct line to top management.

GDPR-Art.37NIST800-PM-19argued against and upheld
Privacy Program Leadership Role. Appoint a senior agency official for privacy with the authority, mission, accountability, and resources to coordinate, develop, and implement, applicable privacy requirements and manage privacy risks through the organization-wide privacy

A qualified officer must be designated and their contact details published.

GDPR-Art.15NIST800-PM-21argued against and upheld
Accounting of Disclosures. Develop and maintain an accurate accounting of disclosures of personally identifiable information, including: Date, nature, and purpose of each disclosure; and Name and address, or other contact information of the individual

Recipients of the data must be disclosed to the individual on request.

GDPR-Art.30NIST800-PM-21argued against and upheld
Accounting of Disclosures. Develop and maintain an accurate accounting of disclosures of personally identifiable information, including: Date, nature, and purpose of each disclosure; and Name and address, or other contact information of the individual

The record must capture categories of recipients, transfers and their destinations.

GDPR-Art.5NIST800-PM-22argued against and upheld
Personally Identifiable Information Quality Management. Develop and document organization-wide policies and procedures for: Reviewing for the accuracy, relevance, timeliness, and completeness of personally identifiable information across the information life cycle; Correcting or deleting inaccurate

Data must be accurate, relevant, limited and kept up to date.

GDPR-Art.16NIST800-PM-22argued against and upheld
Personally Identifiable Information Quality Management. Develop and document organization-wide policies and procedures for: Reviewing for the accuracy, relevance, timeliness, and completeness of personally identifiable information across the information life cycle; Correcting or deleting inaccurate

Inaccurate data corrected and incomplete data completed without undue delay.

GDPR-Art.17NIST800-PM-22argued against and upheld
Personally Identifiable Information Quality Management. Develop and document organization-wide policies and procedures for: Reviewing for the accuracy, relevance, timeliness, and completeness of personally identifiable information across the information life cycle; Correcting or deleting inaccurate

Outdated data no longer necessary for its purpose must be erased.

GDPR-Art.5NIST800-PM-25argued against and upheld
Minimization of Personally Identifiable Information Used in Testing, Training, and Research. Develop, document, and implement policies and procedures that address the use of personally identifiable information for internal testing, training, and research; Limit or

Minimisation limits data to what the purpose actually 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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