NIST SP 800-161 Rev 1 covers 27.1% of APEC Cross-Border Privacy Rules (CBPR) System
16 of the 59 controls in APEC Cross-Border Privacy Rules (CBPR) System are already satisfied by evidence you collected for NIST SP 800-161 Rev 1. 43 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.
This number is directional. It says how much of APEC Cross-Border Privacy Rules (CBPR) System your NIST SP 800-161 Rev 1 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.
57 candidate mappings were examined and 0 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.
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.
External service provider governance is the accountability mechanism for onward transfers to processors.
Enforces the terms under which external parties may hold organizational information.
Sets and verifies the terms under which providers may process organizational information.
The privacy programme plan is the documented measure that gives effect to privacy obligations.
Names the leader accountable for privacy across the organization and its providers.
Complaint management establishes receipt, investigation and routing of privacy complaints.
Complaint management routes complaints to the responsible party so responses are timely.
Governs external service providers across their life cycle and allocates responsibilities.
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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