GDPR A32-05: Process for Testing Security Measures
Article 32 of the GDPR requires organizations to implement security measures that are regularly tested and evaluated. GDPR A32-05 mandates a documented process for assessing the effectiveness of your technical and organizational controls—ensuring your security posture remains current against evolving threats.
What this means
This control requires you to establish and maintain a systematic process for testing and evaluating the effectiveness of your security measures. Rather than implementing controls once, you must continuously validate that they work as intended through regular assessments, penetration tests, vulnerability scans, and control reviews. This demonstrates to regulators that your organization takes a proactive, evidence-based approach to data protection.
How to comply
- 1.Document your security testing process, including frequency, scope, and responsible parties
- 2.Conduct regular vulnerability assessments and penetration testing at least annually
- 3.Perform periodic security audits of technical controls (encryption, access logs, firewalls)
- 4.Review organizational measures (policies, training, incident response) for continued effectiveness
- 5.Maintain testing schedules and incident logs to demonstrate consistent evaluation
- 6.Update your security measures based on test findings and emerging threat intelligence
- 7.Assign clear accountability for executing and reporting test results to leadership
Evidence auditors look for
- Penetration test reports with dates and remediation tracking
- Vulnerability scan results and remediation timelines
- Annual security assessment checklists signed off by management
- Incident response drill documentation and lessons learned
- Third-party SOC 2 or ISO 27001 audit reports
- Internal control effectiveness reviews with evidence of updates
- Security training completion records and phishing test results
- Change logs showing updates to security configurations based on test findings
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
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