Framework overlap

Does AICPA Privacy Management Framework (PMF) cover Consumer Data Right (CDR) Framework (Australia)?

You hold AICPA Privacy Management Framework (PMF) and have been told to do Consumer Data Right (CDR) Framework (Australia). Here is how much overlaps, control by control.

36% of Consumer Data Right (CDR) Framework (Australia) you already have

AICPA Privacy Management Framework (PMF) already covers about 36% of Consumer Data Right (CDR) Framework (Australia), leaving 21 of 33 controls as genuinely new work.

Already covered 0 Likely covered 12 New work 21

No control in AICPA Privacy Management Framework (PMF) maps directly to one in Consumer Data Right (CDR) Framework (Australia). 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.

CDR-ACC-1
Unrestricted Accreditation
CDR-ACC-2
Sponsored Accreditation
CDR-ACC-3
Affiliate Accreditation
CDR-ACC-4
CDR Representative Model
CDR-ACC-5
Trusted Adviser and Insight Disclosure
CDR-ACC-6
Accredited Action Initiator
CDR-CON-5
Time-Limited Consent
CDR-PS-10
Privacy Safeguard 10: Notifying of the Disclosure of CDR Data
CDR-PS-13
Privacy Safeguard 13: Correction of CDR Data
CDR-PS-2
Privacy Safeguard 2: Anonymity and Pseudonymity
CDR-PS-4
Privacy Safeguard 4: Dealing with Unsolicited CDR Data
CDR-PS-5
Privacy Safeguard 5: Notifying of the Collection of CDR Data
CDR-PS-7
Privacy Safeguard 7: Use or Disclosure of CDR Data for Direct Marketing
CDR-PS-9
Privacy Safeguard 9: Adoption or Disclosure of Government Related Identifiers
CDR-RULE-BREACH
CDR Data Breach and Notifiable Data Breach
CDR-RULE-COMPLAINTS
Complaints and Internal Dispute Resolution
CDR-RULE-CONFORMANCE
Conformance Testing (CTS)
CDR-RULE-DASHBOARD
Consumer Dashboards and Receipts
CDR-RULE-DESIGNATION
Sector Designation and Scope
CDR-RULE-OSP
Outsourced Service Provider Arrangements
CDR-RULE-OVERSIGHT
Regulator Oversight and Enforcement (ACCC and OAIC)
Show the 12 you already have
CDR-CON-1
Voluntary Consent
CDR-CON-2
Express Consent
CDR-CON-3
Informed Consent
CDR-CON-4
Specific Consent
CDR-CON-6
Withdrawable Consent and Authorisation
CDR-PS-1
Privacy Safeguard 1: Open and Transparent Management of CDR Data
CDR-PS-11
Privacy Safeguard 11: Quality of CDR Data
CDR-PS-12
Privacy Safeguard 12: Security of CDR Data, and Destruction or De-identification
CDR-PS-3
Privacy Safeguard 3: Seeking to Collect CDR Data from CDR Participants
CDR-PS-6
Privacy Safeguard 6: Use or Disclosure of CDR Data
CDR-PS-8
Privacy Safeguard 8: Overseas Disclosure of CDR Data
CDR-RULE-SECURITY
Information Security (CDR Rules Schedule 2)

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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