Framework overlap

Does Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap 486) cover NIST SP 800-171A Rev 3?

You hold Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap 486) and have been told to do NIST SP 800-171A Rev 3. Here is how much overlaps, control by control.

43% of NIST SP 800-171A Rev 3 you already have

Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap 486) already covers about 43% of NIST SP 800-171A Rev 3, leaving 20 of 35 controls as genuinely new work.

Already covered 0 Likely covered 15 New work 20

No control in Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap 486) maps directly to one in NIST SP 800-171A Rev 3. 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 Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap 486) reaches these. This is the list to scope.

3.1
Physical Security
3.1.1
Authorized Access Control
3.1.2
Transaction and Function Control
3.13
Deploy a Data Loss Prevention Solution
3.13.1
Boundary Protection Assessment
3.14
Log Sensitive Data Access
3.15
Planning
3.2
Establish and Maintain a Data Inventory
3.2.1
Account data storage minimised
3.3.1
Audit Record Creation
3.4
Enforce Data Retention
3.5
Securely Dispose of Data
3.8
Document Data Flows
3.9
Encrypt Data on Removable Media
3.9.1
Personnel Screening Assessment
FEDRAMP-CM-1
Configuration Management Policy
FEDRAMP-CM-2
Baseline Configuration
FEDRAMP-SC-1
System and Communications Protection Policy
FEDRAMP-SC-12
Cryptographic Key Establishment and Management
FEDRAMP-SC-7
Boundary Protection
Show the 15 you already have
3.10
Encrypt Sensitive Data in Transit
3.11
Encrypt Sensitive Data at Rest
3.12
Segment Data Processing and Storage Based on Sensitivity
3.16
System and Services Acquisition
3.17
Supply Chain Risk Management
3.3
Configure Data Access Control Lists
3.6
Encrypt Data on End-User Devices
3.6.1
Incident Response Capability
3.7
Establish and Maintain a Data Classification Scheme
3.7.1
Key generation procedures
FEDRAMP-CM-6
Configuration Settings
FEDRAMP-CP-9
System Backup
FEDRAMP-SC-13
Cryptographic Protection
FEDRAMP-SC-28
Protection of Information at Rest
FEDRAMP-SC-8
Transmission Confidentiality and Integrity

How this is calculated

Already covered means a mapping runs from a control in Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap 486) 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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