Article 32: Security of processing

To meet the article 32: security of processing requirement, you must implement and operate technical and organizational measures that match the risk of your personal data processing, considering “state of the art,” implementation cost, and your processing context. You operationalize this by scoping systems and data, performing a risk-based control selection, assigning owners, and retaining auditable evidence of operation. (Regulation (EU) 2016/679, Article 32)

Key takeaways:

• Start with scope and role clarity (controller vs. processor) so you know which processing you must secure and evidence.
• Build a risk-based control baseline tied to actual systems, not policy language, and document why it is “appropriate to the risk.”
• Keep an evidence packet that proves controls operate: configuration outputs, test results, exceptions, and remediation records.

Article 32 is the GDPR’s operational security requirement. It does not ask for a specific certification or a single “GDPR security checklist.” It asks you to make defensible, risk-based choices about security controls for personal data processing, then prove those controls are implemented and working. The tricky part for a CCO or GRC lead is that “appropriate to the risk” is contextual: the same control set can be adequate for one processing activity and inadequate for another, depending on data sensitivity, scale, access patterns, and downstream impacts to individuals.

In practice, teams fail Article 32 in two predictable ways. First, they treat it as an IT policy exercise instead of an operating control requirement (policy exists, evidence doesn’t). Second, they cannot clearly show scope: which systems process personal data, who owns them, and whether the organization acts as controller or processor in each context. Article 32 is where privacy meets security engineering, procurement, and incident response.

This page translates the article 32: security of processing requirement into an execution plan a serious operator can run: role-and-scope definition, risk assessment, control selection mapped to common frameworks (ISO 27001 and NIST CSF), operating procedures, and an evidence strategy that survives audits and customer diligence. (Regulation (EU) 2016/679, Article 32)

Regulatory text

Regulatory excerpt (provided):
“Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk …” (Regulation (EU) 2016/679, Article 32)

Operator meaning (what you must do):

1. Make a risk-based determination of what “appropriate security” means for each in-scope processing context (not just the company in general). (Regulation (EU) 2016/679, Article 32)
2. Implement technical and organizational measures that match that risk, reflecting modern practice (“state of the art”) while considering proportionality and feasibility (“costs of implementation”). (Regulation (EU) 2016/679, Article 32)
3. Be able to demonstrate the rationale and ongoing operation of those measures through documentation and repeatable evidence collection. (Regulation (EU) 2016/679, Article 32)

Plain-English interpretation of the requirement

Article 32 expects you to run a security program that is anchored to real processing risk to individuals. Your controls should reduce the likelihood and impact of confidentiality, integrity, and availability failures for personal data, and you should be able to explain your choices in business terms: what you process, where it lives, how it could harm people, and how your controls reduce that risk. (Regulation (EU) 2016/679, Article 32)

Who it applies to (entity and operational context)

Applies to:

• Controllers processing personal data under GDPR scope. (Regulation (EU) 2016/679, Article 32)
• Processors processing personal data on behalf of a controller. (Regulation (EU) 2016/679, Article 32)

Operational contexts where Article 32 gets tested:

• New product launches that introduce new data flows (telemetry, behavioral data, location, identity proofing).
• Cloud migrations, identity/provider changes, and data warehouse consolidation.
• Third party onboarding where a provider will store, access, or transmit personal data.
• Incident response readiness for systems holding customer, employee, or user data.

Practical scoping rule: If a system can store, access, transform, transmit, or delete personal data, it is in-scope for your Article 32 control baseline and evidence expectations. (Regulation (EU) 2016/679, Article 32)

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

Step 1: Establish role-and-scope for Article 32 execution

Create a role-and-scope register for Article 32 with, at minimum:

• Processing activity name (aligned to your RoPA if you have one).
• Controller/processor role for that activity.
• Data categories and approximate sensitivity (e.g., identifiers, financial, health).
• Systems involved (applications, databases, endpoints, SaaS tools).
• Third parties involved and access type (hosting, support access, subprocessors).
• Named system owners and control operators.

This register is the anchor that prevents “security program drift” where controls exist but do not clearly cover personal data processing. (Regulation (EU) 2016/679, Article 32)

Step 2: Perform an Article 32 risk determination per processing context

Document a risk evaluation that addresses the Article 32 factors:

• Nature, scope, context, purposes: what you do with the data and why.
• Likelihood and severity to rights and freedoms: realistic harm scenarios (identity theft, discrimination, loss of confidentiality, inability to access services).
• State of the art and cost: why you selected a control approach given modern norms and feasibility.

Keep this practical. A one-page “security appropriateness memo” per major system or processing cluster often works better than an abstract enterprise risk statement. (Regulation (EU) 2016/679, Article 32)

Step 3: Define your minimum “appropriate security” baseline, then add risk-based deltas

Build a baseline control set mapped to common frameworks so you can execute consistently:

Suggested mapping (use what your org already runs):

• ISO/IEC 27001 Annex A: access control, cryptography, operations security, supplier relationships, incident management.
• NIST Cybersecurity Framework (CSF): Identify/Protect/Detect/Respond/Recover.

Then, for each in-scope processing context, add “deltas” where risk is higher (e.g., stronger encryption controls, stricter admin access, enhanced logging, additional resilience and recovery testing). Your deliverable is a control applicability matrix: control, scope, owner, evidence source, and review cadence. (Regulation (EU) 2016/679, Article 32)

Step 4: Translate the baseline into an operating procedure with owners and triggers

Write a requirement-specific operating procedure that answers:

• Who approves security exceptions for systems processing personal data?
• What triggers a reassessment (new data category, new third party, architectural change)?
• What is the minimum evidence to collect and where it is stored?
• How do security requirements enter engineering work (tickets, change approvals, CI/CD gates)?

This is where many teams stall: they can describe controls but cannot show the operational handoffs that make controls real. (Regulation (EU) 2016/679, Article 32)

Step 5: Operationalize third party coverage (processors and subprocessors)

Article 32 applies to processors too, so you must ensure your third party ecosystem supports your risk posture:

• Contractually require security measures aligned to your baseline for any third party that processes personal data.
• Validate security claims during due diligence (questionnaires alone are weak evidence for high-risk processing).
• Require change notification for material security changes and new subprocessors where relevant to your processing.

For many organizations, Daydream becomes the practical system of record here: one place to tie third party due diligence evidence to specific processing contexts and Article 32 control expectations, rather than storing disconnected files across procurement and security tools. (Regulation (EU) 2016/679, Article 32)

Step 6: Build an evidence packet and run it on a cadence

Your goal is simple: when asked “show me Article 32,” you can produce a coherent packet per major processing context.

Include:

• Role-and-scope register extract for the system/activity.
• Risk determination memo and control applicability matrix.
• Control outputs (see “Evidence” section below).
• Exceptions log with approvals and remediation timelines.
• Proof of periodic review (meeting notes, sign-offs, tickets closed).

This converts Article 32 from a narrative requirement into repeatable compliance operations. (Regulation (EU) 2016/679, Article 32)

Required evidence and artifacts to retain

Maintain an “Article 32 evidence packet” with:

Governance and scope

• Role-and-scope register (controller/processor, systems, data categories, owners).
• Data flow diagrams or system context diagrams for key processing.

Risk and control design

• Risk determination memo referencing Article 32 factors.
• Control applicability matrix (baseline + deltas).
• Security exception process and current exceptions list.

Control operation (examples)

• Access control reviews (admin access lists, approvals, removals).
• Encryption configuration evidence (at-rest and in-transit settings, key management ownership).
• Logging/monitoring outputs (log sources list, alerting rules, sample alert triage records).
• Vulnerability management evidence (scan outputs, remediation tickets, closure proof).
• Backup/recovery evidence (restore test records, recovery procedures, incident runbooks).
• Incident response integration (on-call, escalation paths, post-incident reviews for relevant systems).

Article 32 does not prescribe the format; regulators and auditors look for completeness, traceability, and proof of operation. (Regulation (EU) 2016/679, Article 32)

Common exam/audit questions and hangups

Use these as your internal readiness checklist:

1. “Show me how you decided your security measures are appropriate to the risk.” Expect to provide your risk determination and control rationale. (Regulation (EU) 2016/679, Article 32)
2. “Which systems process personal data, and who owns them?” If you cannot answer cleanly, your scope control is failing. (Regulation (EU) 2016/679, Article 32)
3. “How do you ensure processors/subprocessors apply adequate security?” Auditors will test contracts, due diligence, and ongoing monitoring. (Regulation (EU) 2016/679, Article 32)
4. “Prove the controls operate.” Screenshots, exports, tickets, and test results beat policy statements every time. (Regulation (EU) 2016/679, Article 32)

Frequent implementation mistakes and how to avoid them

Mistake 1: Treating “state of the art” as a buzzword.
Fix: Document your control selection logic, including why you chose a given standard pattern (e.g., MFA for privileged access, encryption for portable media) and where you accepted residual risk. (Regulation (EU) 2016/679, Article 32)

Mistake 2: One enterprise security policy, zero system-level scoping.
Fix: Maintain the Article 32 role-and-scope register and tie every control to systems that actually process personal data. (Regulation (EU) 2016/679, Article 32)

Mistake 3: “We have a SOC 2” as the whole answer.
Fix: Use SOC 2 or ISO 27001 outputs as supporting evidence, but still produce GDPR-specific scoping, risk determination, and control applicability for personal data processing. (Regulation (EU) 2016/679, Article 32)

Mistake 4: No exception discipline.
Fix: Track exceptions with explicit owner, compensating controls, and an exit plan. Auditors accept exceptions; they don’t accept invisible exceptions. (Regulation (EU) 2016/679, Article 32)

Enforcement context and risk implications

No public enforcement sources were provided in the source catalog for this page, so this section stays practical rather than case-driven. The risk is straightforward: if security measures are weak or cannot be evidenced, the organization faces regulator scrutiny after incidents, customer complaints, or due diligence escalations. Article 32 is also a multiplier during incident response because it frames whether your security posture matched your processing risk. (Regulation (EU) 2016/679, Article 32)

A practical 30/60/90-day execution plan

Days 0–30: Scope, ownership, and “minimum defensible”

• Build the Article 32 role-and-scope register for top processing systems first (customer data platform, core product DBs, HRIS).
• Assign control owners and name an executive approver for security exceptions.
• Draft the operating procedure: triggers, approvals, evidence locations.
• Produce the first risk determination memo for your highest-risk processing context. (Regulation (EU) 2016/679, Article 32)

Days 31–60: Control baseline and evidence automation

• Create the control applicability matrix (baseline + deltas) and map it to system inventory.
• Stand up evidence capture: access review exports, encryption settings, log source inventory, vulnerability remediation workflow.
• Bring third party processing into scope: identify which third parties act as processors for your personal data and collect core evidence and contract clauses. (Regulation (EU) 2016/679, Article 32)

Days 61–90: Prove operation, close gaps, and prepare for audit asks

• Run a tabletop test of “show me Article 32” for one critical system: can you assemble the packet quickly and consistently?
• Close the biggest control-operation gaps (missing logs, unclear access ownership, weak backup testing evidence).
• Normalize exception handling and ensure remediation tracking is visible to security, privacy, and procurement.
• If you are scaling, centralize your evidence packets and third party proof in Daydream so audits do not depend on individual file owners. (Regulation (EU) 2016/679, Article 32)

Frequently Asked Questions

Does Article 32 require encryption everywhere?

Article 32 requires measures “appropriate to the risk,” and encryption is a common measure, but it is not mandated in the provided excerpt. Document where you encrypt, where you don’t, and why the residual risk is acceptable. (Regulation (EU) 2016/679, Article 32)

We’re a processor. Do we still need our own Article 32 program?

Yes. The excerpt explicitly applies to both controllers and processors. Your program should align to the processing you perform for controllers and produce evidence you can share during diligence. (Regulation (EU) 2016/679, Article 32)

Can we rely on ISO 27001 or SOC 2 to satisfy Article 32?

You can reuse the underlying controls and audit artifacts, but Article 32 still expects risk-based scoping tied to personal data processing and proof the controls cover those systems. Keep a GDPR-facing scope register and control applicability matrix. (Regulation (EU) 2016/679, Article 32)

What’s the minimum evidence we should keep if we’re resource-constrained?

Keep the role-and-scope register, a short risk determination memo for key systems, the control applicability matrix, and a curated set of operating evidence (access reviews, encryption configs, logging inventory, vulnerability remediation). This is the smallest packet that still tells a coherent story. (Regulation (EU) 2016/679, Article 32)

How do we handle “state of the art” without arguing about tools?

Treat it as a decision record, not a tool debate. Write down the control objective, the approach selected, and why it is reasonable for your threat model and processing risk, then revisit it when systems or threats change. (Regulation (EU) 2016/679, Article 32)

How should Article 32 influence third party onboarding?

Any third party that processes personal data should be scoped into your Article 32 register, assessed for security alignment to your baseline, and covered by contract terms that match the risk. Keep the diligence evidence with the processing context so you can retrieve it fast. (Regulation (EU) 2016/679, Article 32)