Framework overlap

Does GDPR cover NIST SP 800-39?

You hold GDPR and have been told to do NIST SP 800-39. Here is how much overlaps, control by control.

38% of NIST SP 800-39 you already have

GDPR already covers about 38% of NIST SP 800-39, leaving 5 of 8 controls as genuinely new work.

Already covered 1 Likely covered 2 New work 5

What is genuinely new work

Nothing in GDPR reaches these. This is the list to scope.

NISTSP39-1
Risk Management Strategy and Three-Tier Hierarchy (Tier 1, 2, 3)
NISTSP39-2
Risk Framing: Risk Frame Components and Trust
NISTSP39-6
Risk Executive Function and Cross-Tier Communication
NISTSP39-7
Risk Management Roles, Responsibilities, and Integration with Governance
NISTSP39-8
Supply Chain Risk Management, Information Sharing, and Risk Management Strategy Maintenance
Show the 3 you already have
NISTSP39-3
Risk Assessing: Organisation, Mission, and System Level Assessments
NISTSP39-4
Risk Responding: Identify, Evaluate, Decide, Implement
NISTSP39-5
Risk Monitoring: Effectiveness, Changes, Compliance, and Reassessment Triggers

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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