Crosswalk pair

GDPR and US Employment Law - Federal Baseline, control by control

A shared set of canonical controls in Keel’s library satisfy clauses of both GDPR and US Employment Law - Federal Baseline. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.

GDPR counts as one of your plan’s paid frameworks, or from $39/mo as an add-on. US Employment Law - Federal Baseline counts as one of your plan’s paid frameworks, or from $19/mo as an add-on. See plans and pricing.

The overlap

What the two libraries have in common

Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.

  • GDPR 2016/679 4%

    Share of the 50+ controls in Keel’s library for GDPR that also map to US Employment Law - Federal Baseline.

  • US Employment Law - Federal Baseline 1.1 13%

    Share of Keel’s US Employment Law - Federal Baseline controls that also map to GDPR.

The mapping

Controls that satisfy both

Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.

GDPR and US Employment Law - Federal Baseline controls that satisfy both, with the clauses each maps to
Canonical control GDPR clauses US Employment Law - Federal Baseline clauses
Data retention & secure disposal Data is retained per policy and securely destroyed when no longer needed. Retention periods are set against the purpose the data was collected for and any legal or contractual obligation to keep it, recorded per category of data rather than left to whoever is looking at the record, and enforced when they run out - data goes because its period ended, not because somebody finally objected to keeping it. Destruction leaves it unrecoverable rather than merely removed from an index, and what was destroyed, when, by what method and on whose authority is recorded. The hardware and media that held it reach a defined final disposition at end of life, by a route the organization has decided in advance rather than by whatever happens to the box; and any media that stays in service is cleared of that data before it is reused, reassigned, or passed to anyone else. Disposal is not confined to data and media: the documentation, the tools and the system components the organization has defined as needing it are disposed of by techniques and methods it has approved in advance - so a decommissioned appliance, a retired build server, a set of network diagrams or a licensed utility leaves the organization by a route somebody chose, and the route is recorded on the same terms as a data destruction. A retention period has two ends and both are stated: the minimum the organization must keep the data for, and the maximum beyond which it may not be kept - so retention is bounded in the direction of keeping too long as well as of destroying too early. Death does not take a record out of scope. Where a regime continues its protections over the information of a person who has died, that continuation is recorded on the schedule as a SCOPE fact and not as a retention period: for as long as it runs, those records are governed on the same terms as a living person’s, and it is measured from the DATE OF DEATH rather than from the last transaction, so the category cannot quietly be treated as out of scope once the file stops moving. It is not an instruction to keep anything. How long the records are held is still decided by the purpose they were collected for and by whatever law actually sets a retention minimum over them; disposing of them when that period ends stays available, and what the continuation governs is how they are handled for as long as they are held - disposal included, so the destruction of a deceased person’s record has to meet the same requirements as any other. Under HIPAA that continuation runs for FIFTY YEARS after the date of death. It is a separate duty from the six-year period the same regime places on the documentation an organization keeps about its own compliance, which is a real retention minimum over compliance records and not over a person’s health record, and NEITHER of them sets a minimum retention period for the health record itself - so a schedule that reads either as one is working from a rule the regime does not state. Art.5(1) us.recordkeeping.eeo, us.recordkeeping.i9-retention
Personnel security (HR) Background screening, confidentiality agreements, and onboarding/offboarding security steps. Before a person is given access to sensitive data, and again whenever their role changes, a documented determination is made that the access their work calls for is appropriate to it - the screening informs that decision but is not the decision. What screening may ask is itself bounded: inquiries about a candidate’s health, disability or medical history are not made, and medical examinations are not required, before a conditional offer of the role has been made, and where such inquiries or examinations are made after an offer they are applied to everyone entering that role rather than to the individuals somebody chose to ask. Access is ended when their employment, or any other arrangement under which they worked for the organization, comes to an end, and whenever that determination says they should no longer hold it. The security responsibilities a person carries are stated in the terms under which they are engaged - in the employment contract or the equivalent agreement for a contractor or temporary worker - together with the organization’s own obligations to them, the duties that continue after the engagement ends and for how long, and what happens if the terms are broken; the terms are accepted before access is given. At the end of an engagement, and on a change of role that removes the need, every asset the person holds is returned and the return is recorded against the inventory rather than assumed - devices, media, tokens and keys, documents and any organization information held on equipment they own - and where information exists only on equipment the organization is not taking back, its transfer and deletion are performed and confirmed before the person leaves. The practice is governed by a documented personnel security policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed on a defined cadence. Security and privacy responsibilities are written into the POSITION DESCRIPTION for each role rather than only into the contract everybody signs, so what a particular job is accountable for is visible when it is advertised, filled, evaluated and re-scoped - and the descriptions are revised when the responsibilities change. Where a regime requires any NATIONALITY condition attaching to a role or to an account type to be written down, the organization documents the condition, and documents explicitly that there is none where none applies. Silence and a recorded absence are not the same record, and only the second can be verified. Art.32(4) us.hiring-onboarding.ada-preoffer, us.hiring-onboarding.fcra-background

Beyond the pair

Where else this work counts

A framework is lit when a shared control above also maps to it. Unlit means none of them do, which is an absence rather than a judgment about that standard.

Also reached by these controls

  • AI Governance Essentials not reached
  • Amazon Appstore Child-Directed Apps not reached
  • Apple App Store Kids Category not reached
  • CIS Critical Security Controls also reached
  • COPPA also reached
  • ESG Essentials not reached
  • EU AI Act not reached
  • FedRAMP 20x also reached
  • FedRAMP Consolidated Rules not reached
  • FedRAMP Rev5 Class B also reached
  • FedRAMP Rev5 Class C also reached
  • FedRAMP Rev5 Class D also reached
  • Google Play Families not reached
  • HIPAA also reached
  • ISO 9001 not reached
  • ISO/IEC 27001 also reached
  • ISO/IEC 42001 not reached
  • NIST AI Risk Management Framework not reached
  • NIST Cybersecurity Framework also reached
  • NIST SP 800-171 also reached
  • NIST SP 800-53 also reached
  • PCI DSS also reached
  • PIPEDA also reached
  • SOC 2 also reached
  • SOX (Sarbanes-Oxley) Section 404 also reached

The thesis

Why this is one project, not two

On a crosswalk-native model, US Employment Law - Federal Baseline mostly lights up controls you already built for GDPR. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.

Next step

Add US Employment Law - Federal Baseline to the work you already did

Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.