GDPR Article 32 Guide

GDPR Article 32 is one of the most important (and closely examined) regulations for any company handling personal data. This section of the regulations defines how businesses must protect data; not just with policies, but also with organisational and technical safeguards that truly protect personal data.

This guide explains what Article 32 requires, why it matters, and how your team can align with its principles while building a sustainable compliance program.

What is GDPR Article 32?

Article 32 of the General Data Protection Regulation (GDPR) requires organizations to implement “appropriate technical and organizational measures” to ensure a level of security appropriate to the risk.

In practice, this means:

• Assessing risks to data processing.
  
  
• Putting controls in place to mitigate those risks.
  
  
• Demonstrating the ability to ensure confidentiality, integrity, availability, and resilience of processing systems.
  
  
• Being able to restore data availability in the event of an incident.
  
  
• Regularly testing and evaluating security measures.

GDPR does not offer a list of precise controls, in contrast to prescriptive frameworks (like PCI DSS). Rather, it requires that companies modify their security measures in accordance with the risks and the sensitivity of the data.

Why Article 32 Matters

• Regulatory expectations: Supervisory authorities focus heavily on Article 32 when investigating breaches. Failure to comply can lead to fines of up to €10M or 2% of annual turnover. (Even up to €20 million or 4% of turnover for more serious violations).
  
  
• Customer trust: Security is now a competitive differentiator. Demonstrating strong GDPR compliance builds confidence with customers, investors, and partners.
  
  
• Future-proofing: Many modern frameworks (NIS 2, ISO 27701) align closely with Article 32 principles. Getting this right helps meet multiple requirements at once.

Key Security Requirements

Article 32 highlights several key security themes. While not exhaustive, organizations are expected to consider:

• Encryption & pseudonymization: to protect personal data at rest and in transit.
  
  
• Confidentiality, integrity, and availability: ensuring systems and services remain secure and resilient.
  
  
• Incident response & recovery: the ability to restore access to data in a timely manner after an incident.
  
  
• Testing & validation: regular review and evaluation of security controls to ensure they remain effective.
  
  
• Risk-based approach: tailoring controls to the level of risk posed by the processing activity.

GDPR Compliance at a Glance

To align with Article 32, organizations should ensure they:

1. Conduct a data protection risk assessment for systems handling personal data.
   
   
2. Document security controls (technical + organizational).
   
   
3. Apply encryption and pseudonymization where appropriate.
   
   
4. Maintain an incident response plan and disaster recovery procedures.
   
   
5. Perform regular security testing (vulnerability scans, penetration tests).
   
   
6. Train employees on security and data handling practices.
   
   
7. Maintain audit-ready evidence of all the above.

GDPR vs ISO 27701

Many organizations pair GDPR Article 32 with ISO 27701, the international privacy extension to ISO 27001.

Key Takeaway

Article 32 is the backbone of GDPR’s security requirements. It requires organizations to adopt a risk-based, adaptable security posture (not a one-size-fits-all checklist).

With compliance automation platforms like Complyance, teams can:

• Map GDPR controls against multiple frameworks (ISO 27001, ISO 27701, SOC 2).
  
  
• Automate evidence collection for encryption, IAM, and incident response.
  
  
• Continuously monitor controls, ensuring readiness for audits and regulator inquiries.

Book a demo with Complyance to see how automation makes GDPR Article 32 compliance faster, easier, and more scalable.

FAQs

Does Article 32 mandate encryption? It doesn’t mandate encryption in all cases, but requires you to consider it based on risk. For sensitive data, encryption is expected.

Can small businesses comply with Article 32? Yes. “Appropriate measures” scales with your risk profile. For small businesses, this might mean access controls, staff training, and backups.

How often should controls be reviewed? Best practice is annually, and whenever you introduce new systems or processing activities.

Is Article 32 compliance enough on its own? No, GDPR requires broader privacy governance (e.g., lawful basis, transparency). Article 32 focuses specifically on data security.