GDPR Article 32 Security Measures: Technical and Organisational Controls Implementation Matrix
In short
GDPR Article 32 requires appropriate technical and organisational measures but lacks specific implementation guidance. This comprehensive matrix maps Article 32 requirements to ISO 27001:2022 controls and provides actionable steps for demonstrating compliance through measurable security controls.
What specific security measures does GDPR Article 32 require?
GDPR Article 32 mandates "appropriate technical and organisational measures" including pseudonymisation, encryption, confidentiality, integrity, availability, and resilience of processing systems. However, the regulation deliberately avoids prescriptive technical specifications, leaving organisations to determine appropriate measures based on risk assessment outcomes.
The ambiguity creates implementation challenges for compliance teams. Article 32(1) lists four specific categories: pseudonymisation and encryption of data, ensuring ongoing confidentiality and integrity, ensuring availability and access to data following incidents, and regular testing of security measures. The "appropriate" standard depends on processing risks, technology costs, implementation complexity, and potential impact on data subject rights.
How do you map Article 32 requirements to ISO 27001:2022 controls?
ISO 27001:2022 provides concrete implementation guidance for GDPR Article 32's abstract requirements through its Annex A controls. The mapping creates a practical framework for demonstrating compliance with measurable security controls.
Pseudonymisation and Encryption Requirements:
- ISO 27001:2022 Control A.8.24 (Use of cryptography) directly addresses encryption requirements
- Control A.8.12 (Data leakage prevention) supports pseudonymisation implementation
- Control A.5.33 (Protection of records) covers data classification supporting pseudonymisation decisions
Confidentiality, Integrity, and Availability:
- Control A.5.15 (Access control) establishes confidentiality measures
- Control A.8.16 (Monitoring activities) provides integrity verification
- Control A.5.29 (Information security in project management) ensures availability planning
Incident Recovery and Business Continuity:
- Control A.5.26 (Response to information security incidents) addresses Article 32(1)(c) requirements
- Control A.5.30 (ICT readiness for business continuity) ensures processing system resilience
What technical controls satisfy Article 32 encryption requirements?
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