NIST SP 800-161 Rev 1 covers 30.6% of ISO 27701:2019
33 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for NIST SP 800-161 Rev 1. 75 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 ISO 27701:2019 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.
114 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.
Access agreements bind the individuals with access, which is the confidentiality obligation required.
Information flow enforcement controls where data moves, including outside the system to suppliers.
Requires protection of information in transit between the organization and external parties.
Directly prevents real personal data being used for testing, training or research.
Acquisition strategies and contract tools impose supply chain requirements before engagement.
Governs external service providers and allocates the security roles each party holds.
Puts the security and privacy requirements and required evidence into the supplier contract.
Supplier assessments and reviews are conducted at a depth matched to what is supplied.
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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