Does AICPA Privacy Management Framework (PMF) cover Cambodia Sub-Decree on Personal Data Protection (Sub-Decree No. 134)?

65% of Cambodia Sub-Decree on Personal Data Protection (Sub-Decree No. 134) you already have

AICPA Privacy Management Framework (PMF) already covers about 65% of Cambodia Sub-Decree on Personal Data Protection (Sub-Decree No. 134), leaving 7 of 20 controls as genuinely new work.

Already covered 0 Likely covered 13 New work 7

No control in AICPA Privacy Management Framework (PMF) maps directly to one in Cambodia Sub-Decree on Personal Data Protection (Sub-Decree No. 134). Everything counted as covered is covered because both map to the same third standard, which is what a crosswalk is, but it is an inference rather than a lookup.

What is genuinely new work

Nothing in AICPA Privacy Management Framework (PMF) reaches these. This is the list to scope.

SD134-1

Scope and Application

SD134-12

Third-Party Disclosure

SD134-15

Subscriber Rights

SD134-18

Training and Awareness

SD134-19

MPTC Reporting

SD134-2

Definitions of Personal Data

SD134-20

Penalties and Enforcement

Show the 13 you already have

SD134-10

Retention Limitation

SD134-11

Secure Disposal

SD134-13

Cross-Border Transfer

SD134-14

Processor Oversight

SD134-16

Complaint Handling

SD134-17

Incident Notification

SD134-3

Lawful Collection

SD134-4

Consent Requirements

SD134-5

Purpose Limitation

SD134-6

Data Minimisation

SD134-7

Accuracy and Quality

SD134-8

Security Safeguards

SD134-9

Access Control

How this is calculated

Already covered means a mapping runs from a control in AICPA Privacy Management Framework (PMF) to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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