IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships for DPOs
What does IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships require of a DPO?
IACS Recommendation No. 194 (December 2025) sets a minimum baseline of fourteen cybersecurity controls for existing ships (contracted before 1 July 2024, over 100 GT), which the class rules of UR E26 and E27 do not cover: an OT asset inventory; network segmentation into OT, IT and crew zones; malware protection, access control, wireless limits, controlled remote access, USB and portable device protection, crew training and managed updates; network monitoring; shore contacts, incident reporting and response with network isolation; and backup and restore. Under IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships, which defines 14 controls, a DPO's work is deciding which controls you own outright, which you share and which belong to another team, then holding the evidence for the first group.
Which IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships controls land on the DPO
Data Protection Officers oversee privacy compliance, manage data subject rights requests, conduct privacy impact assessments, and serve as the point of contact with data protection authorities. The role is mandatory under GDPR for many organisations.
IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships defines 14 controls across 1 domains that directly affect the DPO role. Understanding which controls fall within your ownership, which are shared, and which are owned by other teams is the foundation of effective compliance management.
What a DPO is accountable for under IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships
Advising the organisation on data protection obligations and best practices
Managing data subject access requests (DSARs) and privacy complaints
Conducting data protection impact assessments (DPIAs) for new processing activities
Maintaining records of processing activities and data flow maps
Serving as the liaison with data protection supervisory authorities
Where DPOs lose time on IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships
These are the most common obstacles DPOs face when managing IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships compliance, and how to address them:
Challenge 1
Maintaining visibility over all personal data processing across the organisation
Challenge 2
Managing cross-border data transfer compliance (SCCs, adequacy decisions)
Challenge 3
Keeping privacy notices and consent mechanisms current across all channels
Challenge 4
Responding to DSARs within regulatory timeframes at scale
Challenge 5
Assessing privacy implications of AI and automated decision-making systems
A working order for a DPO starting on IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships
1. Readiness Assessment
Take a 5-minute readiness assessment to identify your organisation's current gap profile against IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships. Get a prioritised action plan tailored to your specific situation.
2. Cross-Framework Mapping
Use our platform to map IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships controls against other frameworks you already comply with. IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships maps to 2 other frameworks in our database.
3. Build Your Toolkit
Equip yourself with IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships toolkits, self-assessments, and implementation guides from our store. Resources designed specifically for DPOs managing compliance programmes.
4. Continuous Monitoring
Establish ongoing compliance monitoring using our platform's gap analysis tools. Track your maturity over time and demonstrate progress to stakeholders.
IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships in your sector
Who else owns part of IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships
Questions DPOs ask about IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships
What does a DPO need to know about IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships?
How does IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships affect the DPO role?
What are the biggest IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships challenges for DPOs?
How should a DPO prepare for a IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships audit?
What tools help DPOs manage IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships compliance?
DPO: How ready is your organisation for IACS Recommendation No. 194 - Cybersecurity Controls for Existing Ships?
Answer 25 questions and get a professional readiness report with gap analysis, maturity scores, and prioritised action items. Results in 5 minutes.