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Audit: GDPR filter — validate Article-to-800-53 mappings #27

Description

@aanishs

What

Independent audit of nist/gdpr-filter.json — verify that each GDPR article correctly maps to the right NIST 800-53 controls.

Why

GDPR-to-800-53 mapping is less standardized than HIPAA or SOC 2. This filter was created by an AI using ENISA guidance and ISO 27001 crosswalks. It especially needs expert review because:

  • GDPR has privacy-specific requirements (consent, right to erasure, DPO) that don't map cleanly to 800-53 security controls
  • Some articles may need interview-only controls that aren't captured
  • The mapping scope (which articles to include) is debatable

What to audit

The file is nist/gdpr-filter.json (~40 lines). For each mapping:

  1. Is the Article reference correct? (Art. 5(1)(f), Art. 32(1)(a), etc.)
  2. Are the right 800-53 controls mapped?
  3. Are privacy-specific articles (Art. 6, Art. 15, Art. 17) adequately represented?
  4. Should more articles be included?

How to contribute

  1. Read nist/gdpr-filter.json
  2. Cross-reference against ENISA guidelines or NIST Privacy Framework
  3. Open a PR with corrections, or comment with findings
  4. Test: bin/comply-db init --framework gdpr

Current state

19 GDPR articles → 22 unique 800-53 controls. Likely incomplete — GDPR has ~99 articles.

Who should review

  • GDPR DPOs (Data Protection Officers)
  • EU privacy lawyers
  • Engineers who've implemented GDPR compliance
  • Anyone familiar with ENISA's GDPR technical guidance

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    auditIndependent review of compliance mappingsframework:gdprGDPR compliance frameworkhelp wantedExtra attention is needed

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