GDPR Article 32: Technical and Organisational Security Measures

What this means

Article 32 mandates that organizations implement a comprehensive security program reflecting current best practices and risk levels. You must balance technical controls (encryption, access controls, monitoring) with organizational measures (policies, training, incident response procedures). The 'state of the art' standard means your controls should reflect industry practices for your sector and organization size. Implementation costs are relevant—you're not required to deploy enterprise-grade solutions if proportionality justifies lighter approaches—but this cannot justify inadequate protection for high-risk processing.

How to comply

1. 1.Conduct a data protection impact assessment (DPIA) to identify processing risks and required security levels
2. 2.Implement technical controls: encryption at rest and in transit, access logging, authentication mechanisms, and network segmentation
3. 3.Establish organizational measures: security policies, employee training, incident response procedures, and vendor management protocols
4. 4.Document all controls in your Records of Processing Activities (ROPA) and security inventory
5. 5.Regularly review and update controls as threats evolve and your processing scope changes
6. 6.Ensure access controls limit who can process personal data and what they can access
7. 7.Implement monitoring and audit logging to detect unauthorized access or anomalies
8. 8.Define data retention and secure deletion procedures

Evidence auditors look for

• Encryption policies for databases containing personal data
• Multi-factor authentication (MFA) implementation logs and configuration documentation
• Network segmentation diagrams isolating sensitive data systems
• Annual security awareness training completion records for all staff
• Data Processing Agreements (DPAs) with vendors requiring equivalent security
• Incident response plan with documented procedures and contact lists
• Access control matrices and role-based permission documentation
• Vulnerability assessment reports and remediation timelines
• Backup and disaster recovery test results
• Pseudonymization or anonymization procedures for non-essential processing

Frequently asked questions

GRCWatch automates your Article 32 security inventory, maps controls to identified risks, tracks technical evidence automatically, and generates the proportionality justification that regulators expect—eliminating manual spreadsheets and fragmented documentation.

See how GRCWatch handles this control automatically

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