EvidenceSheet

Art.32 Security of processing

Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of processing, and the risk of varying likelihood and severity for the rights and freedoms of natural persons. Those measures include, as appropriate, the pseudonymisation and encryption of personal data, the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services, the ability to restore the availability of and access to personal data in a timely manner after a physical or technical incident, and a process for regularly testing, assessing and evaluating the effectiveness of the technical and organisational measures. Assess the appropriate level of security against the risks presented by the processing, in particular accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed. Take steps to ensure that any person acting under the controller's or processor's authority who has access to personal data processes it only on instructions.

Source: GDPR, Art.32. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open GDPR in the compliance library.

Many articles apply only where their condition is met (a data protection officer under Article 37, an impact assessment under Article 35, a representative under Article 27); the condition is in each statement.

5
artefacts
0
held by a system
3
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • The security risk assessment per processing activity, expressed as risk to the rights and freedoms of individuals rather than only as risk to the organisation · Policy repository / GRC workspace
  • Restoration testing results showing personal data was actually recovered inside the intended timeframe, with the date and outcome · Backup / DR tooling
  • Evidence the measures were reassessed after material change in processing, technology or threat · Document repository

governing documentDocuments that govern the control

  • Encryption and pseudonymisation coverage at rest, in transit and in backup, with the decision recorded where either was judged not appropriate · Policy repository / GRC workspace
  • The regular testing programme Article 32(1)(d) requires: penetration tests, vulnerability scanning and control effectiveness reviews, with findings closed out · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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Art.31 Cooperation with the supervisory authority · Art.33 Notification of a personal data breach to the supervisory authority