Security of processing
Description
Implement appropriate technical and organizational measures to ensure security of personal data processing, including encryption and access control.
⚠️ Risk Impact
Inadequate security leading to data breaches can result in regulatory fines and reputational damage.
🔧 Remediation
Encrypt personal data at rest and in transit. Implement access controls. EchelonGraph scans for encryption misconfigurations.
💀 Real-World Attack Scenario
A marketing automation company processed EU personal data in production databases without encryption. An SQL injection vulnerability exposed 4.7M EU resident records including email addresses, purchase history, and location data. The Irish DPC imposed a €8.5M fine specifically for Art 32 violations — inadequate technical measures.
💰 Cost of Non-Compliance
British Airways 2020: £20M fine for Art 32 violations. Marriott 2020: £18.4M fine. Average Art 32 enforcement action: €5.2M. Art 32 fines are calculated based on what measures SHOULD have been implemented.
📋 Audit Questions
- 1.What technical measures protect personal data at rest?
- 2.What measures protect data in transit?
- 3.How is access to personal data controlled?
- 4.What is your security testing methodology?
🎯 MITRE ATT&CK Mapping
⚡ Common Pitfalls
- ⛔Encryption implemented but not verified across all data stores
- ⛔Access controls at application level but not at infrastructure level
- ⛔Security measures documented but not actually enforced
📈 Business Value
Art 32 compliance prevents the most common type of GDPR enforcement action — inadequate security leading to data breaches. It's where technical controls directly prevent regulatory penalties.
⏱️ Effort Estimate
16-40 hours for comprehensive security measures assessment
EchelonGraph scans for encryption, access control, and security misconfigurations continuously
🔗 Cross-Framework References
Automate GDPR Art32 compliance
EchelonGraph continuously monitors this control across all your cloud accounts.
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