ISO 27001:2022ISO 27701:2019

ISO 27001:2022 covers 43.5% of ISO 27701:2019

47 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for ISO 27001:2022. 61 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.

43.5%
of the target already covered
47
controls evidenced
61
genuine gaps
224
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your ISO 27001:2022 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.

315 candidate mappings were examined and 226 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 27701:201935 of 36 evidenced, 1 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20196 of 31 evidenced, 25 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20193 of 18 evidenced, 15 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20193 of 23 evidenced, 20 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.

5.25.3.3argued against and upheld
Organizational roles, responsibilities and authorities

Roles and responsibilities defined and allocated cover the privacy roles the PIMS assigns.

6.35.5.3argued against and upheld
Awareness

Awareness, education and training is the awareness requirement extended to privacy.

5.355.7.2argued against and upheld
Internal audit

Independent review of information security is the internal audit of the extended system.

8.226.10.1argued against and upheld
Network security management

Segregation of networks is named in this clause.

8.216.10.1argued against and upheld
Network security management

Security of network services is named in this clause.

8.206.10.1argued against and upheld
Network security management

Networks security is the network control element of this clause.

5.146.10.2argued against and upheld
Information transfer

Information transfer rules and agreements are the same control.

8.266.11.1argued against and upheld
Security requirements of information systems

Application security requirements are the security requirements of information systems.

Claims that did not hold

224 proposed mappings for this pair were rejected. They are kept in the graph rather than deleted, so what was thrown out is as inspectable as what survived. A crosswalk that never rejects anything is not being judged.

0.10.1
General

high confidence with no rationale and no framework labels. The product shows its reasoning on every claim, so a mapping that cannot be explained cannot be sold. Refuted 2026-08-19, not deleted.

Claimed at high confidence before it was rejected.

0.20.2
Compatibility with other management system standards

high confidence with no rationale and no framework labels. The product shows its reasoning on every claim, so a mapping that cannot be explained cannot be sold. Refuted 2026-08-19, not deleted.

Claimed at high confidence before it was rejected.

5.25.2
Context of the organization

earlier heuristic pass, high confidence with no rationale recorded. The product shows its reasoning on every claim, so a mapping that cannot be explained cannot be sold. Refuted 2026-08-19, not deleted.

Claimed at high confidence before it was rejected.

5.45.3
Leadership

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

5.35.3
Leadership

earlier heuristic pass, high confidence with no rationale recorded. The product shows its reasoning on every claim, so a mapping that cannot be explained cannot be sold. Refuted 2026-08-19, not deleted.

Claimed at high confidence before it was rejected.

5.15.3
Leadership

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

5.15.3.1
Leadership and commitment

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

5.45.3.1
Leadership and commitment

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

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.

Buy this crosswalk