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
225
claims rejected in review

What this leaves you to do

ISO 27701:2019 has 108 controls. Holding ISO 27001:2022 already evidences 47 of them, so the work in front of you is 61 controls, not 108, which is 56% of the standard rather than all of it.

That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.

In money, using only our numbers. The full report is $299 and names 47 controls of ISO 27701:2019 you do not have to implement again, which is $6.36 per control identified. That arithmetic uses our price and our count and assumes nothing about you.

In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.

If a control takes you4 hours8 hours16 hours
the 47 already evidenced are188 hours376 hours752 hours
and the 61 remaining are244 hours488 hours976 hours

Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.

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.

316 candidate mappings were examined and 227 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

225 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.

5.15.1
General

did not survive the adversarial verification pass run by claude-heuristic-2026-05-31. No per-edge rationale was recorded at the time, so the process is stated rather than a reason invented.

Claimed at high confidence before it was rejected.

5.365.1
General

did not survive the adversarial verification pass run by qwen3-235b-a22b-2507 via openrouter. No per-edge rationale was recorded at the time, so the process is stated rather than a reason invented.

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.

5.315.2.2
Understanding the needs and expectations of interested parties

did not survive the adversarial verification pass run by qwen3-235b-a22b-2507 via openrouter. No per-edge rationale was recorded at the time, so the process is stated rather than a reason invented.

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.

5.45.3
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.

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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