Framework overlap

Does ISO 27701:2019 cover ISO 27018:2019?

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

46% of ISO 27018:2019 you already have

ISO 27701:2019 already covers about 46% of ISO 27018:2019, leaving 43 of 80 controls as genuinely new work.

Already covered 28 Likely covered 9 New work 43

What is genuinely new work

Nothing in ISO 27701:2019 reaches these. This is the list to scope.

10.1.1
Policy on the use of cryptographic controls
10.1.2
Key management
11.2.2
Supporting utilities
11.2.3
Cabling security
11.2.5
Removal of assets
11.2.6
Security of equipment and assets off-premises
11.2.7
Secure disposal or re-use of equipment
11.2.8
Unattended user equipment
11.2.9
Clear desk and clear screen policy
12.1.1
Documented operating procedures
12.1.3
Capacity management
12.1.4
Separation of development, testing and operational environments
12.3.1
Information backup
12.4.1
Event logging
12.4.2
Protection of log information
12.4.3
Administrator and operator logs
12.4.4
Clock synchronization
13.2.2
Agreements on information transfer
13.2.3
Electronic messaging
13.2.4
Confidentiality or non-disclosure agreements
16.1.1
Responsibilities and procedures
16.1.3
Reporting information security weaknesses
16.1.4
Assessment of and decision on information security events
16.1.5
Response to information security incidents
16.1.6
Learning from information security incidents
16.1.7
Collection of evidence
18.2.1
Independent review of information security
18.2.2
Compliance with security policies and standards
18.2.3
Technical compliance review
4.2
Control categories
6.1.3
Contact with authorities
6.1.4
Contact with special interest groups
7.2.1
Management responsibilities
7.2.2
Informationa8096b2fa1f5/iso-iec-27018-2019
9.2.1
User registration and de-registration
9.2.3
Management of privileged access rights
9.2.4
Management of secret authentication information of users
9.2.5
Review of user access rights
9.2.6
Removal or adjustment of access rights
9.3.1
Use of secret authentication information
9.4.1
Information access restriction
9.4.2
Secure log-on procedures
9.4.3
Password management system
Show the 37 you already have
10.1
Cryptographic controls
11.1
Secure areas
11.2.1
Equipment siting and protection
11.2.4
Equipment maintenance
12.1
Operational procedures and responsibilities
12.2
Protection from malware
12.4
Logging and monitoring
12.5
Control of operational software
12.6
Technical vulnerability management
12.7
Information systems audit considerations ISO/IEC 27018:2019
13.1
Network security management
13.2
Information transfer
13.2.1
Information transfer policies and procedures
16.1
Management of information security incidents and improvements
18.1
Compliance with legal and contractual requirements
18.2
Information security reviews
4.1
Structure of this document
5.1
Management direction for information security
5.1.1
Policies for information security
5.1.2
Review of the policies for information security
6.1
Internal organization
7.1
Prior to employment
7.3
Termination and change of employment
9.1
Business requirements of access control
9.2
User access management
9.3
User responsibilities
9.4
System and application access control
9.4.5
Access control to program source code
11.2
Equipment
12.1.2
Change management
12.3
Backup
16.1.2
Reporting information security events
6.1.1
Information security roles and responsibilities
6.1.2
Segregation of duties
7.2.3
Disciplinary process
9.2.2
User access provisioning
9.4.4
Use of privileged utility programs

How this is calculated

Already covered means a mapping runs from a control in ISO 27701:2019 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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