Framework overlap

Does OCC Heightened Standards (12 CFR Part 30, Appendix D) cover Bahrain PDPL?

You hold OCC Heightened Standards (12 CFR Part 30, Appendix D) and have been told to do Bahrain PDPL. Here is how much overlaps, control by control.

45% of Bahrain PDPL you already have

OCC Heightened Standards (12 CFR Part 30, Appendix D) already covers about 45% of Bahrain PDPL, leaving 16 of 29 controls as genuinely new work.

Already covered 0 Likely covered 13 New work 16

No control in OCC Heightened Standards (12 CFR Part 30, Appendix D) maps directly to one in Bahrain PDPL. 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 OCC Heightened Standards (12 CFR Part 30, Appendix D) reaches these. This is the list to scope.

BH-PDPL-01
Notice and transparency requirements
BH-PDPL-03
Lawful basis for processing
BH-PDPL-04
Purpose limitation and specification
BH-PDPL-06
Right of access to personal data
BH-PDPL-07
Right to rectification of inaccurate data
BH-PDPL-08
Right to erasure and deletion
BH-PDPL-10
Right to restrict processing
BH-PDPL-11
Right to object to processing
BH-PDPL-12
Automated decision-making protections
BH-PDPL-14
Pseudonymization techniques
BH-PDPL-20
Records of processing activities
BH-PDPL-23
Data processing agreements
BH-PDPL-26
Training and awareness programs
BH-PDPL-27
Regulatory reporting and cooperation
BH-PDPL-28
Complaints handling and resolution
BH-PDPL-29
Enforcement and penalties awareness
Show the 13 you already have
BH-PDPL-02
Consent management and withdrawal
BH-PDPL-05
Data minimization requirements
BH-PDPL-09
Right to data portability
BH-PDPL-13
Encryption of personal data
BH-PDPL-15
Access control for personal data
BH-PDPL-16
Data breach notification requirements
BH-PDPL-17
Security incident response procedures
BH-PDPL-18
Regular security testing and assessment
BH-PDPL-19
Data protection officer designation
BH-PDPL-21
Data protection impact assessments
BH-PDPL-22
Privacy by design and default
BH-PDPL-24
Cross-border transfer safeguards
BH-PDPL-25
Compliance monitoring and auditing

How this is calculated

Already covered means a mapping runs from a control in OCC Heightened Standards (12 CFR Part 30, Appendix D) 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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