Framework overlap

Does GDPR cover APRA CPS 234?

You hold GDPR and have been told to do APRA CPS 234. Here is how much overlaps, control by control.

60% of APRA CPS 234 you already have

GDPR already covers about 60% of APRA CPS 234, leaving 14 of 35 controls as genuinely new work.

Already covered 0 Likely covered 21 New work 14

No control in GDPR maps directly to one in APRA CPS 234. 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 GDPR reaches these. This is the list to scope.

CPS234-01
Information security program management
CPS234-02
Board and management oversight
CPS234-03
Risk appetite and tolerance for IT risk
CPS234-04
Security policy framework
CPS234-07
Endpoint protection and detection
CPS234-13
Board Responsibility for Information Security
CPS234-19
Information Security Policy Framework
CPS234-22
Control Testing Programme
CPS234-27
Audit of Third Party Information Security
CPS234-28
Documented Reporting of Material Findings
CPS234-30
Incident Response Plans
CPS234-32
Incident Response Testing
CPS234-36
APRA Notification of Control Weaknesses
CPS234-43
Security Awareness Training
Show the 21 you already have
CPS234-05
Roles and responsibilities definition
CPS234-06
Network security and segmentation
CPS234-08
Application security controls
CPS234-09
Encryption and key management
CPS234-10
Secure configuration standards
CPS234-11
Business continuity planning and testing
CPS234-12
Disaster recovery procedures
CPS234-14
Roles and Responsibilities
CPS234-15
Information Security Capability
CPS234-16
Capability of Third Parties
CPS234-17
Contractual security requirements
CPS234-18
Ongoing monitoring and assessment
CPS234-20
Information Asset Identification and Classification
CPS234-21
Implementation of Controls
CPS234-23
Frequency and Methodology of Testing
CPS234-24
Customer notification procedures
CPS234-25
Internal Audit of Information Security
CPS234-35
APRA Notification of Material Incidents
CPS234-37
Access Controls
CPS234-39
Encryption of Sensitive Data
CPS234-41
Vulnerability Management

How this is calculated

Already covered means a mapping runs from a control in GDPR 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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