Does ISO 27701:2019 cover ISO 37301:2021?

95% of ISO 37301:2021 you already have

ISO 27701:2019 already covers about 95% of ISO 37301:2021, leaving 2 of 42 controls as genuinely new work.

Already covered 36 Likely covered 4 New work 2

What is genuinely new work

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

9.1.3

Development of indicators

9.1.5

Record-keeping

Show the 40 you already have

10.1

Continual improvement

10.2

Nonconformity and corrective action

4.1

Understanding the organization and its context

4.2

Understanding the needs and expectations of interested parties

4.3

Determining the scope of the compliance management system

4.4

Compliance management system

4.5

Compliance obligations

4.6

Compliance risk assessment

5.1

Leadership and commitment

5.1.2

Compliance culture

5.1.3

Compliance governance

5.2

Compliance policy

5.3

Roles, responsibilities and authorities

5.3.2

Compliance function

6.1

Actions to address risks and opportunities

6.2

Compliance objectives and planning to achieve them

6.3

Planning of changes

7.1

Resources

7.2

Competence

7.2.2

Employment process

7.2.3

Training

7.3

Awareness

7.4

Communication

7.5

Documented information

7.5.2

Creating and updating documented information

7.5.3

Control of documented information

8.1

Operational planning and control

8.2

Establishing controls and procedures

8.4

Investigation processes

9.1

Monitoring, measurement, analysis and evaluation

9.1.4

Compliance reporting

9.2

Internal audit

9.2.2

Internal audit programme

9.3

Management review

9.3.2

Management review inputs

9.3.3

Management review results

5.1.1

Governing body and top management

5.3.4

Personnel

8.3

Raising concerns

9.1.2

Sources of feedback on compliance performance

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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