DTCF

One objective. Many frameworks. Honest gaps.

DTCF normalises what an organization must achieve into 31 objectives across 10 families, then maps each to the frameworks practitioners face. Mappings are graded: fully addressed, partially addressed, or deliberately absent with the reason recorded. An empty cell is a finding about the framework, not a gap in your programme.

DTCF 2026.1 · published 10 Sep 2026 · CC BY 4.0 · free to use with attribution

31Objectives
312Graded mappings
49Deliberate absences
8Frameworks
GOV-01Governance and Accountability

Accountable owner for digital trust

A named individual is accountable for the digital trust programme, with the authority and budget to direct it.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ◐ HIPAA ● GDPR ◐ EUAIACT ◐ AIRMF ●
GOV-02Governance and Accountability

Approved policy set

Policies covering the organization's obligations are approved, dated, owned and reviewed on a stated cycle.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ○ AIRMF ●
GOV-03Governance and Accountability

Roles and responsibilities defined

Security, privacy and compliance responsibilities are assigned and communicated to the people who hold them.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ◐ AIRMF ●
RSK-01Risk and Decisions

Risk assessment performed and repeated

Risks to objectives are identified and assessed on a defined cadence and on material change.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ● AIRMF ●
RSK-02Risk and Decisions

Risk register with owners and treatment

Risks are recorded with inherent and residual judgement, an owner, a treatment decision and a review date.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ◐ HIPAA ● GDPR ○ EUAIACT ● AIRMF ●
RSK-04Risk and Decisions

Appetite and indicators

Risk appetite is stated in terms someone can measure, with indicators and thresholds that trigger action.

SOC2 ◐ ISO27001 ◐ NISTCSF ● PCIDSS ○ HIPAA ○ GDPR ○ EUAIACT ◐ AIRMF ●
OBL-01Obligations and Compliance

Obligation inventory

Legal, regulatory and contractual obligations that apply are identified, owned and kept current.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ◐ HIPAA ◐ GDPR ◐ EUAIACT ◐ AIRMF ●
OBL-02Obligations and Compliance

Scope decided and documented

What is in scope for each framework or certification is decided, justified and recorded, including deliberate exclusions.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ◐ EUAIACT ◐ AIRMF ●
OBL-03Obligations and Compliance

Training and awareness

People receive role-relevant training on joining and at a defined cadence, and completion is evidenced.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ● AIRMF ●
DAT-01Data and Privacy

Data inventory and classification

Data held is inventoried, classified and assigned an owner.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ● EUAIACT ◐ AIRMF ●
DAT-03Data and Privacy

Deliberate data sharing

Data leaves the organization only through a decided channel, with a defined end and a record of what was shared.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ● EUAIACT ○ AIRMF ◐
DAT-04Data and Privacy

Complete disposal

Data is removed from primary systems, backups, caches, exports and third parties when it is no longer needed or on request.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ● EUAIACT ○ AIRMF ○
ACC-01Identity and Access

Joiners, movers, leavers

Access is provisioned on a documented request, changed when a role changes and removed promptly on departure.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ○ AIRMF ◐
ACC-02Identity and Access

Access reviewed on a cadence

Entitlements are reviewed by someone who can judge them, with revocations tracked to completion.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ○ AIRMF ○
ACC-03Identity and Access

Strong authentication

Authentication is proportionate to risk, with multi-factor authentication on administrative and remote access.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ◐ EUAIACT ○ AIRMF ○
ACC-04Identity and Access

Privileged access controlled

Administrative access is limited, separately approved, monitored and time-bound where possible.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ○ EUAIACT ○ AIRMF ○
OPS-01Secure Operations

Change management

Changes to production are requested, reviewed, tested and recorded, with emergency changes reconciled afterwards.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ○ EUAIACT ◐ AIRMF ◐
OPS-02Secure Operations

Vulnerability management

Vulnerabilities are discovered, prioritised by risk and remediated within stated timeframes, with exceptions recorded.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ◐ EUAIACT ◐ AIRMF ◐
OPS-03Secure Operations

Logging and monitoring

Security-relevant events are logged, retained and reviewed, with alerts that reach a person who acts.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ● AIRMF ●
OPS-04Secure Operations

Endpoint and device protection

Devices with access to organizational data are hardened, patched, encrypted and recoverable.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ○ AIRMF ○
OPS-05Secure Operations

Secure development

Security requirements, review and testing are part of how software is built and released.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ○ GDPR ◐ EUAIACT ● AIRMF ◐
TPR-01Third Parties and Supply Chain

Third-party inventory

Third parties with access to data or systems are inventoried with an owner and a criticality judgement.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ● EUAIACT ◐ AIRMF ●
TPR-02Third Parties and Supply Chain

Due diligence proportionate to risk

Third parties are assessed before onboarding and periodically thereafter, at a depth proportionate to what they touch.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ● EUAIACT ◐ AIRMF ●
TPR-03Third Parties and Supply Chain

Contractual terms and offboarding

Contracts carry security, privacy and breach terms, and access and data are recovered when the relationship ends.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ● EUAIACT ◐ AIRMF ◐
RES-01Resilience and Response

Incident response plan and roles

An incident response plan exists, names roles, and is exercised.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ◐ AIRMF ●
RES-02Resilience and Response

Breach notification within statutory time

Reportable incidents are assessed and notified to regulators and affected people within the applicable deadlines.

SOC2 ◐ ISO27001 ◐ NISTCSF ● PCIDSS ◐ HIPAA ● GDPR ● EUAIACT ● AIRMF ○
RES-03Resilience and Response

Backups that restore

Backups exist, are protected from the same failure as production, and restoration is tested.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ◐ HIPAA ● GDPR ● EUAIACT ○ AIRMF ◐
RES-04Resilience and Response

Continuity and recovery objectives

Critical processes have recovery objectives, a continuity plan and a tested route back to service.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ○ HIPAA ● GDPR ◐ EUAIACT ○ AIRMF ◐
ASR-01Assurance and Evidence

Controls have owners

Every control has one accountable owner and named performers for its tasks.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ○ EUAIACT ○ AIRMF ●
ASR-04Assurance and Evidence

Independent testing and reporting

Controls are tested by someone other than the person who performs them, and results are reported without softening.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ● GDPR ◐ EUAIACT ◐ AIRMF ●
ASR-05Assurance and Evidence

Findings are closed with evidence

Findings carry an owner, a date, a remediation and evidence that the fix works.

SOC2 ● ISO27001 ● NISTCSF ● PCIDSS ● HIPAA ◐ GDPR ○ EUAIACT ◐ AIRMF ●

How DTCF is governed

First edition. Objectives are normalised statements of what an organization must achieve. Mappings are graded: full, partial, or a recorded absence with the reason it is absent. An empty cell is a finding about the framework, not about the objective.

  • authorAssociation of Digital Trust Practitioners Authors and maintains DTCF. The framework is published free under CC BY 4.0 and is not tied to any product.
  • sponsoring contributorA sponsoring contributor A sponsoring contributor to the 2026.1 edition contributed mapping research and review. Sponsors do not own or control DTCF; like any vendor they may state conformance to it.

Framework names and references are the property of their publishers. DTCF is an independent mapping and is not endorsed by them. Corrections are welcome through the contact form and are published in the edition changelog.