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GDPR Article 32 and the Security of Processing

The General Data Protection Regulation (GDPR) is one of the strongest security and privacy frameworks in operation in the world. Of this regulation, Article 32 stands out among its numerous guidelines as it deals explicitly with the “security of processing” of personal data.

This piece aims to demystify GDPR Article 32, breaking down its requirements and their implications for businesses of all sizes. Whether you’re a business owner, a data protection officer, or a GDPR enthusiast, this article will provide the insights you need to grasp and implement the crucial aspects of Article 32.

 

GDPR and Data Processing Security

Article 32 of the General Data Protection Regulation refers to the security of processing personal data–a critical part of the overall mission of the regulation to protect consumer data. Broadly, the article defines some of the responsibilities that compliance organizations must take on and execute to meet GDPR requirements. 

According to GDPR Article 32, the controller and the processor shall implement appropriate technical and organizational measures to ensure security appropriate to the risk. These measures include:

Organizations must take into account risk and context when assessing the appropriate levels of security to implement in line with these requirements. These risks should include accounting of the fallout from destruction or unauthorized disclosure of data. 

Additionally, controllers and processors must ensure that anyone processing data under their direction must do so only by instruction of those entities in accordance with the law. 

 

Pseudo-Anonymization and Encryption of Data

Pseudonymization is a de-identification process where personally identifiable information (PII) is replaced by one or more alternative identifiers to ensure that a person cannot be identified from a given record. The objective of pseudonymization is to render the data record less identifiable and, therefore, less sensitive.

Several different forms of pseudonymization include:

Remember that pseudonymized data is still considered personal data under GDPR Article 32 as the data can be re-identified with additional information (e.g., the secret key). This contrasts with anonymization, where re-identification should not be possible.

Also, implementing pseudonymization requires careful planning and handling. It’s essential to ensure the security of the pseudonyms, as the re-identification of data can lead to privacy breaches.

 

Confidentiality, Integrity, Availability, and Resilience

Also known as the CIA triad, confidentiality, integrity, and availability are models designed to guide policies for information security within an organization. Here’s what each component means:

Additionally, there is the concept of “resilience.” Resilience is the ability of a system to essentially “bounce back” during times of stress or disaster. These times can include cyberattacks, natural disasters, or heavy use periods. 

Organizations often have to implement a combination of policy, technology, and training to ensure the CIA triad in a data system. It’s important to note that this is a fundamental concept in IT security and an essential requirement in many compliance guidelines, including but not limited to GDPR, HIPAA, PCI-DSS, etc.

 

Restoration and Recovery

Maintaining sufficient IT recovery capabilities under GDPR Article 32 is crucial for an organization to respond to and recover from events that could disrupt its IT systems, such as hardware failures, software bugs, cyber-attacks, or natural disasters. Here are several strategies an organization can employ to ensure effective IT recovery capabilities:

Remember that a good disaster recovery strategy involves technology, people, and processes. It’s a continuous process that needs regular review and updating to remain effective as the organization and its environment evolve.

 

Testing

Regular testing is a key component of an effective IT security strategy under GDPR Article 32. It helps you uncover vulnerabilities and weaknesses before attackers do. Here are some of the best practices for regularly testing enterprise IT systems for security:

Remember, these tests aim to improve your organization’s security posture continually. After conducting these tests, it’s essential to analyze the results, remediate detected issues, and adjust your security policies and controls. Working with a reputable cybersecurity firm for these tests is beneficial, as they can provide the required expertise and an outside perspective.

 

Are Your Processing Controls Up to GDPR? Ensure They Are with Continuum GRC.

Continuum GRC is a cloud platform that can take something as routine and necessary as regular vulnerability scanning and reporting under FedRAMP and make it an easy and timely part of business in the public sector. We provide risk management and compliance support for every major regulation and compliance framework on the market, including:

And more. We are the only FedRAMP and StateRAMP Authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP Authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and find out how we can help your organization protect its systems and ensure compliance.

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