Framework overlap

Does Australian Privacy Principles (APPs) cover Australia Consumer Data Right?

You hold Australian Privacy Principles (APPs) and have been told to do Australia Consumer Data Right. Here is how much overlaps, control by control.

71% of Australia Consumer Data Right you already have

Australian Privacy Principles (APPs) already covers about 71% of Australia Consumer Data Right, leaving 8 of 28 controls as genuinely new work.

Already covered 18 Likely covered 2 New work 8

What is genuinely new work

Nothing in Australian Privacy Principles (APPs) reaches these. This is the list to scope.

AUCDR-IS-1
Limit risk of unauthorised access to the CDR data environment
AUCDR-IS-2
Secure the network and systems within the data environment
AUCDR-IS-3
Securely manage information assets over their lifecycle
AUCDR-IS-4
Formal vulnerability management program
AUCDR-IS-5
Limit, prevent, detect and remove malware
AUCDR-IS-6
Information security training and awareness program
AUCDR-OB-1
Accreditation as an accredited data recipient
AUCDR-OB-7
Reporting to ACCC and OAIC
Show the 20 you already have
AUCDR-OB-2
Consent requirements
AUCDR-OB-3
Data minimisation
AUCDR-OB-4
CDR policy publication
AUCDR-OB-5
Deletion or de-identification of redundant data
AUCDR-OB-8
Complaints handling
AUCDR-PS-1
Privacy Safeguard 1 - Open and transparent management of CDR data
AUCDR-PS-10
Privacy Safeguard 10 - Notifying of the disclosure of CDR data
AUCDR-PS-11
Privacy Safeguard 11 - Quality of CDR data
AUCDR-PS-12
Privacy Safeguard 12 - Security of CDR data and destruction or de-identification of redundant CDR data
AUCDR-PS-13
Privacy Safeguard 13 - Correction of CDR data
AUCDR-PS-2
Privacy Safeguard 2 - Anonymity and pseudonymity
AUCDR-PS-3
Privacy Safeguard 3 - Seeking to collect CDR data from CDR participants
AUCDR-PS-4
Privacy Safeguard 4 - Dealing with unsolicited CDR data
AUCDR-PS-5
Privacy Safeguard 5 - Notifying of the collection of CDR data
AUCDR-PS-6
Privacy Safeguard 6 - Use or disclosure of CDR data
AUCDR-PS-7
Privacy Safeguard 7 - Use or disclosure of CDR data for direct marketing
AUCDR-PS-8
Privacy Safeguard 8 - Overseas disclosure of CDR data
AUCDR-PS-9
Privacy Safeguard 9 - Adoption or disclosure of government related identifiers
AUCDR-OB-6
Records of CDR data
AUCDR-OB-9
Outsourced service provider and representative arrangements

How this is calculated

Already covered means a mapping runs from a control in Australian Privacy Principles (APPs) 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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