What is Control Mapping

Control mapping transforms compliance from a checkbox exercise into strategic risk management. When you map controls properly, one SOC 2 control might satisfy requirements across ISO 27001, GDPR Article 32, and NIST CSF simultaneously.

Most organizations waste resources implementing duplicate controls for each framework they face. A financial services firm might have separate controls for PCI DSS encryption, GLBA safeguards, and SOX IT general controls—when one properly designed encryption control could satisfy all three.

Third-party risk compounds this challenge. Your vendors operate under their own control frameworks, and you need assurance their controls map to your compliance obligations. Without standardized control mapping, vendor assessments become guesswork. You can't determine if their ISO 27001 certification actually covers your GDPR processor requirements or if their SOC 2 Type II addresses your specific HIPAA safeguards.

Technical Definition and Core Components

Control mapping documents the relationships between:

1. Control objectives - The specific risk or requirement being addressed
2. Control activities - The actual technical or procedural implementation
3. Framework requirements - Regulatory or standard clauses requiring the control
4. Evidence artifacts - Documentation proving control operation
5. Testing procedures - Methods to validate control effectiveness

A properly mapped control includes:

• Unique control identifier (e.g., AC-2.1)
• Control description and implementation details
• Frequency (preventive/detective, automated/manual)
• Responsible party or system
• Related framework requirements (with specific clause numbers)
• Testing methodology and schedule

Regulatory Requirements for Control Mapping

SOC 2 Trust Services Criteria

TSC CC6.1 requires entities to "identify and assess risks that would affect the entity's ability to achieve its objectives." Control mapping directly supports this by documenting how controls address identified risks.

ISO 27001:2022

Clause 6.1.3(c) requires organizations to "determine and apply criteria for risk evaluation." Annex A provides 93 controls that must be mapped to your specific risk treatment plans.

GDPR Article 32

Requires "appropriate technical and organisational measures" with consideration for "the state of the art." Control mapping demonstrates how your measures align with industry standards.

NIST Cybersecurity Framework

The Framework Core explicitly uses control mapping through its Functions, Categories, and Subcategories structure. Version 2.0 emphasizes mapping to Informative References.

HIPAA Security Rule

45 CFR §164.308(a)(1) requires covered entities to "conduct an accurate and thorough assessment." Control mapping documents how safeguards address specific vulnerabilities.

Practical Implementation: The Control Mapping Process

Phase 1: Control Inventory

Document every control currently implemented:

• Access controls (authentication, authorization, monitoring)
• Network controls (firewalls, segmentation, encryption)
• Data controls (classification, retention, disposal)
• Physical controls (badges, locks, environmental)
• Administrative controls (policies, training, incident response)

Phase 2: Framework Analysis

For each applicable framework, extract specific requirements:

Framework	Requirement	Control Domain
PCI DSS 4.0	Firewall configuration standards	Network Security
ISO 27001 A.9.1.2	Access to networks and services	Access Control
SOC 2 CC6.6	Logical access controls	Access Control

Phase 3: Crosswalk Development

Create the mapping relationships:

Control ID: NET-001

• Description: Firewall ruleset review and update
• Frequency: Quarterly
• Satisfies:
  • PCI DSS 1.1.6 (Firewall rule review)
  • ISO 27001 A.13.1.1 (Network controls)
  • NIST CSF PR.AC-5 (Network integrity protection)
  • SOC 2 CC6.6 (Boundary protection)

Phase 4: Gap Analysis

Identify framework requirements without mapped controls:

1. List all framework requirements
2. Mark requirements with existing control coverage
3. Highlight gaps requiring new controls
4. Prioritize based on regulatory deadlines and risk exposure

Vendor Control Mapping Challenges

Third-party control mapping introduces complexity:

Scenario: Your organization requires GDPR compliance from all data processors. A vendor provides SOC 2 Type II certification.

Mapping Challenge: SOC 2 doesn't explicitly address GDPR requirements like:

• Right to erasure (Article 17)
• Data portability (Article 20)
• Cross-border transfer mechanisms (Chapter V)

Solution: Develop supplemental control requirements:

1. Map SOC 2 controls to relevant GDPR articles
2. Identify GDPR gaps not covered by SOC 2
3. Request additional vendor attestations for gap areas
4. Include specific control requirements in contracts

Common Control Mapping Mistakes

Over-Mapping

Claiming one generic control satisfies 15 different requirements dilutes effectiveness. Each mapping must demonstrate specific coverage.

Under-Documentation

"We have antivirus" isn't control mapping. Document:

• Which antivirus solution
• Update frequency
• Coverage percentage
• Alert mechanisms
• Response procedures

Static Mapping

Frameworks update regularly:

• ISO 27001:2022 replaced ISO 27001:2022
• PCI DSS 4.0 replaced 3.2.1
• NIST CSF 2.0 expanded from 1.1

Your mappings need version control and update procedures.

Ignoring Compensating Controls

When perfect mapping isn't possible, document compensating controls. If you can't meet specific technical requirements, show how alternative controls achieve the same objective.

Industry-Specific Control Mapping Considerations

Financial Services

• Map to multiple overlapping frameworks (SOX, GLBA, FFIEC)
• Consider state-specific requirements (NYDFS Cybersecurity)
• Account for international standards (Basel III operational risk)

Healthcare

• Balance HIPAA Security Rule with state privacy laws
• Map clinical system controls to FDA cybersecurity guidance
• Consider HITRUST CSF as common mapping framework

Technology/SaaS

• Map development practices to secure SDLC requirements
• Consider customer contractual requirements beyond regulations
• Account for global operations (GDPR, LGPD, PIPEDA)

Building Your Control Mapping Program

Start with these steps:

1. Tool Selection: Choose between spreadsheets (immediate start, limited scale) or GRC platforms (investment required, better automation)

2. Taxonomy Development: Establish naming conventions

   • Control families (AC = Access Control, IR = Incident Response)
   • Numbering schemes (AC-1, AC-1.1, AC-1.1.1)
   • Version tracking (v1.0, v1.1, v2.0)

3. Responsibility Assignment

   • Control owners: Implement and maintain controls
   • Compliance team: Maintain mappings and identify gaps
   • Internal audit: Validate mapping accuracy
   • External auditors: Confirm framework compliance

4. Update Procedures

   • Quarterly framework update reviews
   • Annual complete remapping exercise
   • Change control for new controls or requirements

5. Vendor Integration

   • Standard control assessment questionnaires
   • Mapping templates for vendor completion
   • Automated inherent control documentation

Frequently Asked Questions

How detailed should control descriptions be in a control mapping exercise?

Control descriptions need sufficient detail for an auditor to understand implementation without additional explanation. Include the what (specific technology/process), who (responsible party), when (frequency), and how (step-by-step procedure).

Can one control satisfy requirements across different framework types (privacy vs. security)?

Yes, but document how. Data encryption controls can satisfy both GDPR Article 32 (security) and CCPA §1798.150 (breach safe harbor), but you must explicitly show how the implementation addresses each requirement's specific elements.

What's the difference between control mapping and a RACI matrix?

Control mapping links controls to compliance requirements. A RACI matrix assigns responsibility (Responsible, Accountable, Consulted, Informed) for control activities. You need both—control mapping shows what's required, RACI shows who does it.

How often should we update our control mappings?

Review quarterly for framework updates, test control effectiveness per your defined frequency (monthly to annually), and perform complete remapping when adopting new frameworks or after significant organizational changes.

Should vendor-provided controls be mapped separately from internal controls?

Maintain separate sections for internal vs. inherited controls, but map them to the same requirements. This clarifies your reliance on vendors and highlights where you need compensating controls if vendor coverage gaps exist.

What evidence should we maintain for control mappings?

Keep three types: design evidence (policies, procedures, system configurations), operational evidence (logs, reports, test results), and mapping documentation (crosswalk matrices, gap analyses, update histories).