Framework overlap

Does ISO 27701:2019 cover ISO/IEC 27701:2019?

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

50% of ISO/IEC 27701:2019 you already have

ISO 27701:2019 already covers about 50% of ISO/IEC 27701:2019, leaving 19 of 38 controls as genuinely new work.

Already covered 17 Likely covered 2 New work 19

What is genuinely new work

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

5.2.3
Determining the scope of the PIMS
5.2.4
PIMS establishment, implementation, maintenance and continual improvement
5.3.1
Leadership and commitment (PIMS)
5.3.2
Privacy policy
5.4.1.2
Privacy risk assessment
5.4.1.3
Privacy risk treatment
5.4.2
Articulating risk management commitment
5.5.3
Awareness (PIMS)
5.7.2
Internal audit (PIMS)
5.7.3
Management review (PIMS)
6.11.1.2
Inclusion of PII in supplier agreements
6.13.1.1
Privacy incident management
6.15.1.1
Identification of applicable privacy legislation
6.5.3.1
Management of removable media (PII)
6.9.4.1
Event logging (PII access)
7.4.7
Retention (Controller)
7.4.8
Disposal (Controller)
8.5.7
Engagement of a sub-contractor to process PII (Processor)
8.5.8
Change of sub-contractor to process PII (Processor)
Show the 19 you already have
5.2.1
Understanding the organization and its context (PIMS)
5.2.2
Understanding the needs and expectations of interested parties (PIMS)
5.3.3
Organizational roles, responsibilities and authorities (PIMS)
5.5.4
Communication (PIMS)
5.5.5
Documented information (PIMS)
5.7.1
Monitoring, measurement, analysis and evaluation (PIMS)
5.8.1
Nonconformity and corrective action (PIMS)
7.2.4
Obtain and record consent (Controller)
7.2.5
Privacy impact assessment (Controller)
7.2.6
Contracts with PII processors (Controller)
7.2.7
Joint PII controller (Controller)
7.2.8
Records related to processing PII (Controller)
7.3.1
Determining and fulfilling obligations to PII principals (Controller)
7.4.4
PII minimization objectives (Controller)
7.4.5
PII de-identification and deletion at end of processing (Controller)
7.4.6
Temporary files (Controller)
7.4.9
PII transmission controls (Controller)
6.2.1.1
Policies for information security (privacy-extended)
6.5.2.1
Classification of information (PII)

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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