Article 24: Responsibility of the controller

Article 24: responsibility of the controller requirement means you must implement risk-appropriate technical and organisational measures for each processing activity, and you must be able to prove those measures work in practice and stay current. Operationalize it by tying every processing purpose to owned controls, documented decisions, and recurring reviews with retained evidence. (Regulation (EU) 2016/679, Article 24)

Key takeaways:

• Build a controller “accountability pack” per processing area: risk rationale, controls, owners, and operating evidence. (Regulation (EU) 2016/679, Article 24)
• Treat “able to demonstrate” as an evidence requirement: logs, approvals, review records, and exception handling. (Regulation (EU) 2016/679, Article 24)
• Re-review and update measures when processing changes, incidents happen, or risk shifts; document the trigger and outcome. (Regulation (EU) 2016/679, Article 24)

As a Compliance Officer, CCO, or GRC lead, Article 24 is the GDPR requirement that turns privacy compliance from “we have a policy” into “we can show it works.” The text is short, but the expectation is broad: controllers must select and run measures that fit their processing, and they must keep those measures current as the business changes. (Regulation (EU) 2016/679, Article 24)

In practice, Article 24 becomes your accountability operating system. It forces clarity on (1) what processing you do, (2) why you do it, (3) what could go wrong for individuals, (4) what controls you run to prevent harm and meet GDPR obligations, and (5) what evidence you keep so a regulator, customer, or auditor can verify the story quickly. (Regulation (EU) 2016/679, Article 24)

This page gives you requirement-level implementation guidance you can assign to owners. It focuses on practical execution: defining scope, mapping controls to risks, setting review triggers, and building evidence packets that hold up under scrutiny.

Regulatory text

GDPR Article 24(1) excerpt (controller responsibility):
“Taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation. Those measures shall be reviewed and updated where necessary.” (Regulation (EU) 2016/679, Article 24)

What the operator must do

Article 24 creates two non-negotiables for controllers:

1. Implement appropriate measures that fit your processing and its risk to individuals. (Regulation (EU) 2016/679, Article 24)
2. Be able to demonstrate compliance, meaning you can produce evidence that measures exist, are owned, operate as designed, and get updated when needed. (Regulation (EU) 2016/679, Article 24)

The “taking into account…” clause is your design standard. You are expected to calibrate controls based on what you do (nature/purpose), how much and how often (scope), where and with whom (context), and what could happen to people (risk). (Regulation (EU) 2016/679, Article 24)

Plain-English interpretation

You are responsible for making GDPR real in operations, not just in documents. For each meaningful processing activity, you should be able to answer:

• What personal data are we processing, and for what purpose?
• What could go wrong for individuals if we process, share, retain, or secure it poorly?
• Which technical and organisational measures reduce those risks and support GDPR compliance?
• Who owns those measures, how do we know they run, and when do we revisit them? (Regulation (EU) 2016/679, Article 24)

“Appropriate” does not mean “maximal.” It means defensible: a reasoned selection of measures that match the activity and risk, with proof. (Regulation (EU) 2016/679, Article 24)

Who it applies to (entity and operational context)

In scope

• Any organisation acting as a controller for personal data processed in a GDPR context. (Regulation (EU) 2016/679, Article 24)
  You are a controller where you decide the purposes and means of processing (for example: deciding to collect customer contact data for account creation).

Typical operational contexts where Article 24 shows up

• New products or features that introduce new data uses.
• Marketing and analytics data flows (consent, opt-out handling, tracking governance).
• HR and employee monitoring tooling.
• Customer support tooling that exposes identity, communications, or sensitive complaint data.
• Third party relationships where you disclose personal data or allow access to it.

Even if processing is outsourced, controllers still need measures to ensure and demonstrate GDPR-compliant processing across their ecosystem. (Regulation (EU) 2016/679, Article 24)

What you actually need to do (step-by-step)

Step 1: Define your Article 24 scope by processing area

Create a simple “role-and-scope register” that lists, per processing area:

• Controller/processor role decision (at least for the major activities)
• Processing purposes
• Categories of personal data
• Systems involved
• Key third parties with access or disclosures
• Business owner and control owner (can be different)

This is your anchor for designing and proving “appropriate measures.” (Regulation (EU) 2016/679, Article 24)

Practical tip: If you cannot state the processing purpose in one sentence, your controls will sprawl. Force the purpose statement first.

Step 2: Perform a risk-to-rights assessment that is usable

Article 24 explicitly ties measures to risks to individuals. Build a lightweight assessment per processing area that captures:

• Likely harm scenarios (unauthorized disclosure, misuse, excessive retention, incorrect decisions, loss of access)
• Severity and likelihood (use your internal scale; keep it consistent)
• Risk drivers (volume, special categories, children, profiling, cross-border access, public exposure)

Output: a short decision record that explains why the chosen measures are appropriate for that risk profile. (Regulation (EU) 2016/679, Article 24)

Step 3: Map “appropriate technical and organisational measures” to the risks

Don’t try to restate the full GDPR. Instead, build a control map that covers the operational control families most teams can evidence:

Organisational measures

• Clear ownership (named accountable roles for each processing area)
• Operating procedures for intake/change management (who approves new uses, new disclosures, new retention)
• Workforce access governance (joiner/mover/leaver controls; role-based access rationale)
• Third party due diligence and contracting workflow (access approval, ongoing oversight)
• Incident and request handling (how privacy incidents and data subject requests flow to resolution)

Technical measures

• Access controls and logging for systems handling personal data
• Data minimisation in collection and fields
• Segregation between environments and least-privilege design
• Retention and deletion mechanisms that execute (not just policy)
• Secure transfer methods and controls for exports

Then explicitly tie each measure to the processing area and the risks you documented. That mapping is what makes “appropriate” defensible. (Regulation (EU) 2016/679, Article 24)

Step 4: Convert the requirement into an operating procedure (with triggers)

Write an Article 24 operating procedure that answers:

• What events trigger review/update? Examples: new system, new data category, new third party access, new purpose, incident, material audit finding.
• Who must approve? Business owner, Security, Privacy/Legal, Data Governance, depending on your model.
• What must be produced? Updated scope record, updated risk decision, control updates, rollout plan, and evidence packet. (Regulation (EU) 2016/679, Article 24)

Keep it short and executable. The goal is repeatability.

Step 5: Build “demonstrate compliance” evidence packets

For each processing area, retain an evidence packet that can be handed to an auditor or regulator. Include:

• Role-and-scope register entry (current version)
• Risk decision record (why measures are appropriate)
• Control mapping (controls to risks)
• Proof of operation (samples): access review outputs, logging configuration screenshots/exports, retention job reports, training completion for relevant teams, third party approval records
• Exceptions and remediation: accepted risks, compensating controls, closure evidence
• Review/update record: what changed, why, and who approved (Regulation (EU) 2016/679, Article 24)

This is where many programs fail. Policy without operating evidence does not satisfy “be able to demonstrate.” (Regulation (EU) 2016/679, Article 24)

Step 6: Run recurring governance and change control

Article 24 requires measures be “reviewed and updated where necessary.” Implement:

• A standing review forum (privacy, security, product, IT) that evaluates trigger events
• A change intake path (ticket or workflow) for new processing or third party access
• A consistent documentation standard (templates and required fields)
• A way to track open gaps and remediation ownership across teams

If you use Daydream, treat Article 24 as a requirement with explicit owners, trigger events, and evidence checklists so evidence packets stay audit-ready without manual scrambling. (Regulation (EU) 2016/679, Article 24)

Required evidence and artifacts to retain (audit-ready list)

Maintain these artifacts in a controlled repository:

• Article 24 operating procedure with named owners and approval workflow (Regulation (EU) 2016/679, Article 24)
• Role-and-scope register for processing areas (controller decision, purpose, systems, third parties) (Regulation (EU) 2016/679, Article 24)
• Risk decision records tied to “rights and freedoms” risk analysis (Regulation (EU) 2016/679, Article 24)
• Control map linking risks to technical and organisational measures (Regulation (EU) 2016/679, Article 24)
• Operating evidence: logs, review outputs, access approvals, retention/deletion execution evidence, exception tickets, remediation closures (Regulation (EU) 2016/679, Article 24)
• Review/update history and trigger documentation (Regulation (EU) 2016/679, Article 24)

Common exam/audit questions and hangups

Expect reviewers to probe these areas:

• “Show me how you decided measures are appropriate.” Provide risk decision records and control mapping. (Regulation (EU) 2016/679, Article 24)
• “How do you know controls operate?” Produce operational outputs, not policy statements. (Regulation (EU) 2016/679, Article 24)
• “What triggers updates?” Show change control triggers and examples where you updated measures. (Regulation (EU) 2016/679, Article 24)
• “Where are your controller/processor role decisions?” Demonstrate role clarity per processing area. (Regulation (EU) 2016/679, Article 24)
• “What happens with third parties?” Show approvals, oversight, and how third party access is governed as part of your measures. (Regulation (EU) 2016/679, Article 24)

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails Article 24	What to do instead
Treating Article 24 as a policy-only requirement	You cannot “demonstrate” processing is compliant with a document alone. (Regulation (EU) 2016/679, Article 24)	Build evidence packets with operating outputs and review records.
No role clarity (controller vs. processor)	Control duties and proof points vary by role; ambiguity weakens accountability. (Regulation (EU) 2016/679, Article 24)	Maintain a role-and-scope register and require role selection during intake.
One-size-fits-all controls	Article 24 expects measures calibrated to nature/scope/context/purpose and risk. (Regulation (EU) 2016/679, Article 24)	Document risk drivers and map measures to those drivers per processing area.
Reviews happen only after incidents	Measures must be “reviewed and updated where necessary,” including proactive change triggers. (Regulation (EU) 2016/679, Article 24)	Define trigger events and route them through a repeatable workflow.
Evidence is scattered across tools	You lose time and credibility during audits and customer diligence. (Regulation (EU) 2016/679, Article 24)	Centralize evidence packets and standardize what “good evidence” looks like.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this page, so this section is omitted by design.

Operationally, treat Article 24 as a multiplier: if you cannot demonstrate compliance, any underlying gap (access, retention, sharing, incident response) becomes harder to defend because the accountability layer is missing. Article 24 also increases customer diligence pressure because sophisticated customers often ask for proof of governance and control operation, not just written policies. (Regulation (EU) 2016/679, Article 24)

Practical execution plan (30/60/90-day)

You asked for speed. Use phases rather than calendar promises.

First 30 days: Establish accountability scaffolding

• Assign an executive owner and a program owner for Article 24 evidence readiness. (Regulation (EU) 2016/679, Article 24)
• Stand up the role-and-scope register and populate the highest-impact processing areas first. (Regulation (EU) 2016/679, Article 24)
• Publish an Article 24 operating procedure: triggers, approvers, required outputs, and where evidence lives. (Regulation (EU) 2016/679, Article 24)
• Define the evidence packet template and repository structure. (Regulation (EU) 2016/679, Article 24)

Days 31–60: Build defensible control mapping and initial evidence

• Complete risk decision records for priority processing areas (the ones with broad access, heavy sharing, or sensitive contexts). (Regulation (EU) 2016/679, Article 24)
• Map existing controls to risks; identify gaps where you lack operating proof. (Regulation (EU) 2016/679, Article 24)
• Collect operating evidence samples and fix “paper controls” that do not produce outputs. (Regulation (EU) 2016/679, Article 24)
• Implement exception handling: how you approve, time-box, and remediate deviations. (Regulation (EU) 2016/679, Article 24)

Days 61–90: Operationalize recurring review and change triggers

• Embed the trigger workflow into product/IT change management and third party onboarding so updates happen as part of normal work. (Regulation (EU) 2016/679, Article 24)
• Run a tabletop “demonstrate compliance” drill: pick a processing area and produce the full evidence packet within a short internal SLA you set. (Regulation (EU) 2016/679, Article 24)
• Add recurring governance: review open gaps, upcoming system changes, and third party access changes; document outcomes. (Regulation (EU) 2016/679, Article 24)
• If you use Daydream, configure requirement owners, evidence checklists, and recurring evidence requests so Article 24 stays continuously demonstrable instead of project-based. (Regulation (EU) 2016/679, Article 24)

Frequently Asked Questions

Do we need a separate “Article 24 control” or is our GDPR program enough?

You need evidence that your GDPR controls are appropriate to specific processing risks and that you can demonstrate operation and review. If your program already produces that mapping and evidence consistently, Article 24 is covered. (Regulation (EU) 2016/679, Article 24)

What does “able to demonstrate” mean in an audit?

It means you can produce artifacts that link processing to risk-based measures and show those measures operate in practice (outputs, logs, reviews, approvals). A policy statement alone usually does not meet the bar. (Regulation (EU) 2016/679, Article 24)

How granular should the scope be ¹?

Pick a level where a single business owner can explain purpose, data, systems, third parties, and controls without hand-waving. If one entry mixes unrelated purposes or multiple owner teams, split it. (Regulation (EU) 2016/679, Article 24)

How do we prove measures are “reviewed and updated where necessary”?

Define trigger events and keep a review/update log that shows what changed, why it changed, and who approved it. Also retain at least one example where a trigger caused a real control or process update. (Regulation (EU) 2016/679, Article 24)

Does Article 24 apply if all processing is done by third parties?

Yes, if you are the controller deciding the purposes and means. You still need appropriate organisational and technical measures to ensure compliant processing and to demonstrate oversight, including how you govern third party access and changes. (Regulation (EU) 2016/679, Article 24)

What is the fastest “minimum viable” evidence packet we can assemble?

Start with a role-and-scope register entry, a short risk decision record, a control map, and a small set of operating outputs that prove key controls run. Expand from there as you identify gaps in demonstrability. (Regulation (EU) 2016/679, Article 24)

Footnotes

1. Regulation (EU) 2016/679, Article 24