PCI DSS 4.0ISO 27701:2019

PCI DSS 4.0 covers 29.6% of ISO 27701:2019

32 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for PCI DSS 4.0. 76 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.

29.6%
of the target already covered
32
controls evidenced
76
genuine gaps
125
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 your PCI DSS 4.0 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.

257 candidate mappings were examined and 125 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 27701:201927 of 36 evidenced, 9 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20194 of 31 evidenced, 27 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20191 of 18 evidenced, 17 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20190 of 23 evidenced, 23 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.

1.4.16.10argued against and upheld
Communications security

Network security controls between trusted and untrusted networks is the network control limb.

1.4.16.10.1argued against and upheld
Network security management

Controls implemented between trusted and untrusted networks is segregation in networks.

1.2.16.10.1argued against and upheld
Network security management

Defined and maintained configuration standards for network security controls is network security management.

4.2.26.10.2argued against and upheld
Information transfer

Securing data whenever sent via end user messaging technologies covers the other transfer channel.

4.2.16.10.2argued against and upheld
Information transfer

Strong cryptography safeguarding data during transmission over open public networks is information transfer.

6.2.16.11argued against and upheld
Systems acquisition, development and maintenance

Developing bespoke and custom software securely to industry standards is this clause.

6.2.46.11argued against and upheld
Systems acquisition, development and maintenance

Defined engineering techniques preventing common attacks is security built into development.

6.2.16.11.1argued against and upheld
Security requirements of information systems

Secure development based on industry standards is the security requirements specification.

Claims that did not hold

125 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.

12.1.15.1
General

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.

12.1.25.1
General

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.

12.1.15.2
Context of the organization

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.

12.1.25.2
Context of the organization

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.

12.1.25.3
Leadership

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.

12.1.15.3
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.

12.1.25.3.1
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.

12.1.15.3.1
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.

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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