Framework overlap

Does PCI SSF cover Australian Privacy Principles (APPs)?

You hold PCI SSF and have been told to do Australian Privacy Principles (APPs). Here is how much overlaps, control by control.

20% of Australian Privacy Principles (APPs) you already have

PCI SSF already covers about 20% of Australian Privacy Principles (APPs), leaving 16 of 20 controls as genuinely new work.

Already covered 0 Likely covered 4 New work 16

No control in PCI SSF maps directly to one in Australian Privacy Principles (APPs). 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 PCI SSF reaches these. This is the list to scope.

APP-10
APP 10 - Quality of personal information
APP-11
APP 11 - Security of personal information
APP-12
APP 12 - Access to personal information
APP-13
APP 13 - Correction of personal information
APP-2
APP 2 - Anonymity and pseudonymity
APP-4
APP 4 - Dealing with unsolicited personal information
APP-6
APP 6 - Use or disclosure of personal information
APP-7
APP 7 - Direct marketing
APP-9
APP 9 - Adoption, use or disclosure of government related identifiers
COMP
Complaints handling
GOV-PO
Privacy officer and accountability
NDB
Notifiable Data Breaches scheme
PIA
Privacy Impact Assessment
REG
Records of disclosures
TRN
Privacy training and awareness
VEN
Vendor and contracted service provider management
Show the 4 you already have
APP-1
APP 1 - Open and transparent management of personal information
APP-3
APP 3 - Collection of solicited personal information
APP-5
APP 5 - Notification of the collection of personal information
APP-8
APP 8 - Cross-border disclosure of personal information

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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