Framework overlap

Does AICPA Privacy Management Framework (PMF) cover COPPA?

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

14% of COPPA you already have

AICPA Privacy Management Framework (PMF) already covers about 14% of COPPA, leaving 18 of 21 controls as genuinely new work.

Already covered 0 Likely covered 3 New work 18

No control in AICPA Privacy Management Framework (PMF) maps directly to one in COPPA. 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.

COPPA-312.1
Scope and Coverage of the COPPA Rule
COPPA-312.11
FTC-Approved Safe Harbor Programs
COPPA-312.12
Voluntary Commission Approval Processes
COPPA-312.2-AK
Actual Knowledge Standard for General Audience Services
COPPA-312.2-DTC
Child-Directed and Mixed Audience Determination
COPPA-312.2-OP
Operator Determination and Covered Entities
COPPA-312.2-PI
Personal Information Scope and Inventory
COPPA-312.2-SIO
Support for Internal Operations Exception Definition
COPPA-312.3
General Requirements: Five Core Obligations
COPPA-312.4a
Notice: Clear, Complete, and Understandable
COPPA-312.4c
Direct Notice to the Parent
COPPA-312.4d
Online Notice of Information Practices (Privacy Policy)
COPPA-312.5-SCH
School Authorization in Lieu of Parental Consent
COPPA-312.5b
Approved Methods of Verifiable Parental Consent
COPPA-312.5c
Exceptions to Prior Parental Consent
COPPA-312.6
Right of Parent to Review and Delete Information
COPPA-312.7
Prohibition Against Conditioning Participation
COPPA-312.9
Enforcement as an Unfair or Deceptive Practice
Show the 3 you already have
COPPA-312.10
Data Retention and Deletion (Written Retention Policy)
COPPA-312.5a
Verifiable Parental Consent Requirement
COPPA-312.8
Confidentiality, Security, and Integrity (Written Information Security Program)

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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