TheArtOfService
ISO 27701:2019NIST SP 800-53 Rev 5

ISO 27701:2019 covers 3.7% of NIST SP 800-53 Rev 5

11 of the 300 controls in NIST SP 800-53 Rev 5 are already satisfied by evidence you collected for ISO 27701:2019. 289 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.

3.7%
of the target already covered
11
controls evidenced
289
genuine gaps
339
claims rejected in review

This number is directional. It says how much of NIST SP 800-53 Rev 5 your ISO 27701:2019 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.

396 candidate mappings were examined and 339 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.

PT - PII Processing and Transparency4 of 8 evidenced, 4 to do
RA - Risk Assessment1 of 9 evidenced, 8 to do
PM - Program Management3 of 32 evidenced, 29 to do
SI - System and Information Integrity2 of 22 evidenced, 20 to do
CM - Configuration Management1 of 14 evidenced, 13 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
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
SA - System and Services Acquisition0 of 17 evidenced, 17 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.

7.2.8NIST800-CM-13argued against and upheld
Data Action Mapping. Develop and document a map of system data actions

Records of PII processing document the data actions the system performs.

8.5.3NIST800-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

Same disclosure accounting obligation carried on the processor side.

7.5.4NIST800-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

Records what was disclosed, to whom, when, and the authority relied on.

7.3.6NIST800-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

Policies and mechanisms for correcting and erasing data, with defined response times.

7.4.3NIST800-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

Documented policies minimising inaccuracy and responding to inaccurate data across the lifecycle.

7.3.9NIST800-PM-26argued against and upheld
Complaint Management. Implement a process for receiving and responding to complaints, concerns, or questions from individuals about the organizational security and privacy practices that includes: Mechanisms that are easy to use and readily accessible

Documented procedures for handling complaints and requests within defined response times.

7.3.1NIST800-PM-26argued against and upheld
Complaint Management. Implement a process for receiving and responding to complaints, concerns, or questions from individuals about the organizational security and privacy practices that includes: Mechanisms that are easy to use and readily accessible

Accessible timely means of meeting subject obligations with a maintained contact point.

8.2.1NIST800-PT-2argued against and upheld
Authority to Process Personally Identifiable Information. Determine and document the [organization-defined] that permits the [organization-defined] of personally identifiable information; and Restrict the [organization-defined] of personally identifiable information to only that which is authorized

For a processor the customer agreement is the documented authority to process.

Claims that did not hold

339 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.

6.6.3NIST800-AC-11
Device lock

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

6.9.4NIST800-AC-17
Remote access

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.

6.6.2NIST800-AC-17
Remote access

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.

6.3.2NIST800-AC-17
Remote access

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

6.10.1NIST800-AC-18
Wireless access

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

6.6.2NIST800-AC-2
Account management

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

6.6.2NIST800-AC-3
Access enforcement

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

6.10.2NIST800-AC-4
Information flow enforcement

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

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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