Framework overlap

Does ISO 27018 cover ISO 27701:2019?

You hold ISO 27018 and have been told to do ISO 27701:2019. Here is how much overlaps, control by control.

24% of ISO 27701:2019 you already have

ISO 27018 already covers about 24% of ISO 27701:2019, leaving 99 of 130 controls as genuinely new work.

Already covered 13 Likely covered 18 New work 99

What is genuinely new work

Nothing in ISO 27018 reaches these. This is the list to scope.

4.1
Structure of this document
4.2
Application of ISO/IEC 27001:2013 requirements
4.3
Application of ISO/IEC 27002:2013 guidelines
4.4
Customer
5.2.2
Understanding the needs and expectations of interested parties
5.2.3
Determining the scope of the information security management system
5.3
Leadership
5.3.1
Leadership and commitment
5.3.3
Organizational roles, responsibilities and authorities
5.5.2
Competence
5.5.3
Awareness
5.5.4
Communication
5.5.5
Documented information
5.6
Operation
5.7
Performance evaluation
5.7.1
Monitoring, measurement, analysis and evaluation
5.7.2
Internal audit
5.8.1
Nonconformity and corrective action
5.8.2
Continual improvement
6.10.2
Information transfer
6.11.2
Security in development and support processes
6.11.3
Test data
6.12
Supplier relationships
6.12.1
Information security in supplier 0d0997ee1127/iso-iec-27701-2019 relationships
6.12.2
Supplier service delivery management
6.13.1
Management of information security incidents and improvements
6.14
Information security aspects of business continuity management
6.14.2
Redundancies
6.15
Compliance
6.15.1
Compliance with legal and contractual requirements
6.2.1
Management direction for information security
6.3.1
Internal organization
6.3.2
Mobile devices and teleworking
6.4
Human resource security
6.4.1
Prior to employment
6.4.2
During employment
6.4.3
Termination and change of employment
6.5
Asset management
6.5.1
Responsibility for assets
6.5.3
Media handling
6.6.1
Business requirements of access control
6.6.3
User responsibilities
6.6.4
System and application access control
6.7.1
Cryptographic controls
6.8.1
Secure areas
6.8.2
Equipment
6.9
Operations security
6.9.1
Operational procedures and responsibilities
6.9.2
Protection from malware
6.9.3
Backup
6.9.5
Control of operational software
6.9.7
Information systems audit considerations
7.2
Conditions for collection and processing
7.2.1
Identify and document purpose
7.2.2
Identify lawful basis
7.2.3
Determine when and how consent is to be obtained
7.2.4
Obtain and record consent
7.2.5
Privacy impact assessment
7.2.6
Contracts with PII processors
7.2.7
Joint PII controller
7.2.8
Records related to processing PII
7.3
Obligations to PII principals
7.3.1
Determining and fulfilling obligations to PII principals
7.3.10
Automated decision making
7.3.2
Determining information for PII principals
7.3.3
Providing information to PII principals
7.3.4
Providing mechanism to modify or withdraw consent
7.3.5
Providing mechanism to object to PII processing
7.3.6
Access, correction and/or erasure
7.3.7
PII controllers' obligations to inform third parties
7.3.8
Providing copy of PII processed
7.3.9
Handling requests
7.4
Privacy by design and privacy by default
7.4.1
Limit collection
7.4.2
Limit processing
7.4.4
PII minimization objectives
7.4.5
PII de-identification and deletion at the end of processing
7.4.7
Retention
7.4.8
Disposal
7.5
PII sharing, transfer, and disclosure
7.5.1
Identify basis for PII transfer between jurisdictions
7.5.2
Countries and international organizations to which PII can be transferred
7.5.3
Records of transfer of PII
7.5.4
Records of PII disclosure to third parties
8.2.1
Customer agreement
8.2.2
Organization’s purposes
8.2.4
Infringing instruction
8.2.6
Records related to processing PII
8.3.1
Obligations to PII principals
8.4
Privacy by design and privacy by default
8.5
PII sharing, transfer, and disclosure
8.5.1
Basis for PII transfer between jurisdictions
8.5.2
Countries and international organizations to which PII can be transferred
8.5.3
Records of PII disclosure to third parties
8.5.4
Notification of PII disclosure requests
8.5.5
Legally binding PII disclosures
8.5.6
Disclosure of subcontractors used to process PII
8.5.7
Engagement of a subcontractor to process PII
8.5.8
Change of subcontractor to process PII
Show the 31 you already have
5.2.4
Information security management system
5.6.2
Information security risk assessment
5.6.3
Information security risk treatment
6.13
Information security incident management
6.14.1
Information security continuity
6.15.2
Information security reviews
6.2
Information security policies
7.4.3
Accuracy and quality
7.4.6
Temporary files
7.4.9
PII transmission controls
8.4.1
Temporary files
8.4.2
Return, transfer or disposal of PII
8.4.3
PII transmission controls
5.2
Context of the organization
5.2.1
Understanding the organization and its context
5.4.1
Actions to address risks and opportunities
5.6.1
Operational planning and control
5.7.3
Management review
5.8
Improvement
6.10
Communications security
6.10.1
Network security management
6.11.1
Security requirements of information systems
6.3
Organization of information security
6.5.2
Information classification
6.6
Access control
6.6.2
User access management
6.7
Cryptography
6.8
Physical and environmental security
6.9.4
Logging and monitoring
6.9.6
Technical vulnerability management
8.2
Conditions for collection and processing

How this is calculated

Already covered means a mapping runs from a control in ISO 27018 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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