Framework overlap

Does Code of Conduct on Data Protection for Research (GDPR Article 40) cover Cambodia Sub-Decree on Personal Data Protection (Sub-Decree No. 134)?

You hold Code of Conduct on Data Protection for Research (GDPR Article 40) and have been told to do Cambodia Sub-Decree on Personal Data Protection (Sub-Decree No. 134). Here is how much overlaps, control by control.

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

Code of Conduct on Data Protection for Research (GDPR Article 40) 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 Code of Conduct on Data Protection for Research (GDPR Article 40) 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 Code of Conduct on Data Protection for Research (GDPR Article 40) reaches these. This is the list to scope.

SD134-1
Scope and Application
SD134-11
Secure Disposal
SD134-12
Third-Party Disclosure
SD134-15
Subscriber Rights
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
SD134-13
Cross-Border Transfer
SD134-14
Processor Oversight
SD134-16
Complaint Handling
SD134-17
Incident Notification
SD134-18
Training and Awareness
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 Code of Conduct on Data Protection for Research (GDPR Article 40) 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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