Framework overlap

Does PCI SSF cover AICPA Privacy Management Framework (PMF)?

You hold PCI SSF and have been told to do AICPA Privacy Management Framework (PMF). Here is how much overlaps, control by control.

31% of AICPA Privacy Management Framework (PMF) you already have

PCI SSF already covers about 31% of AICPA Privacy Management Framework (PMF), leaving 18 of 26 controls as genuinely new work.

Already covered 4 Likely covered 4 New work 18

What is genuinely new work

Nothing in PCI SSF reaches these. This is the list to scope.

PMF-A.1
Individual Access Rights
PMF-A.2
Access Request Process
PMF-AN.1
Privacy Notice
PMF-AN.2
Purpose Specification
PMF-AN.3
Privacy Agreements
PMF-CC.1
Lawful and Fair Collection
PMF-CC.2
Collection Limitation
PMF-CC.3
Consent Mechanisms
PMF-D.1
Third-Party Disclosure Controls
PMF-D.2
Third-Party Agreements
PMF-D.3
Onward Transfer Accountability
PMF-M.2
Privacy Policies and Procedures
PMF-ME.1
Privacy Program Monitoring
PMF-SP.1
Information Security Program
PMF-SP.2
Security Safeguards
PMF-URD.1
Use Limitation
PMF-URD.2
Retention Periods
PMF-URD.3
Secure Disposal
Show the 8 you already have
PMF-M.1
Privacy Program Governance
PMF-M.4
Privacy Incident Management
PMF-ME.3
Enforcement and Remediation
PMF-SP.3
Security Testing and Monitoring
PMF-DI.1
Data Accuracy
PMF-DI.2
Data Quality Processes
PMF-M.3
Privacy Risk Assessment
PMF-ME.2
Complaint Handling

How this is calculated

Already covered means a mapping runs from a control in PCI SSF 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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